The US Securities and Exchange Commission (SEC) Division of Investment Management has issued cybersecurity guidance (PDF) to registered investment companies (“Funds”) and registered investment advisers (“Advisers”). The SEC has identify cybersecurity as an issue for both Funds and Advisers.
Both funds and advisers increasingly use technology to conduct their business activities and need to protect confidential and sensitive information related to these activities from third parties, including information concerning fund investors and advisory clients. This guidance update highlights the importance of the issue and discusses a number of measures that funds and advisers may wish to consider when addressing cybersecurity risks. Because of the rapidly changing nature of cyber threats, the Division will continue to focus on cybersecurity and monitor events in this area.
The SEC recommends the following measures in addressing cybersecurity risk:
- Conduct a periodic Security Risk Assessment – which 1) identifies where sensitive information is stored, accessed or processed; 2) identifies threats and internal and external vulnerabilities to the firm’s information and technology systems; 3) identifies existing security measures that are currently in place; 4) determines impact on data and systems if systems were compromised.
- Create a strategy to prevent, detect and respond to cybersecurity threats – measures include 1) controlling access to data and systems; 2) data encryption 3) evaluating the risk of portable media; 4) data backup and retrieval; 5) implementing an incident response plan
- Implement written policies and procedures and training – provide guidance to officers and employees concerning threats and measure to prevent, detect and respond to the threats.
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