Appendix. Key Areas of Concern. i. Inadequate coverage of cybersecurity risk assessment exercises

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1 Appendix Key Areas of Concern i. Inadequate coverage of cybersecurity risk assessment exercises The scope coverage of cybersecurity risk assessment exercises, such as cybersecurity control gap analysis and benchmarking, were insufficient when they were conducted with a main focus to assess only the risks associated with LCs Internet-facing systems and infrastructure. Mission critical systems and networks residing within the LCs internal environments, or other non-internet facing systems and environments which might also be the enticing targets for cyber-attacks by insiders, were not sufficiently covered in the cybersecurity risk assessment. Moreover, these cybersecurity risk assessment exercises only tested the effectiveness of controls in place to guard against basic types of cyber-attacks. Furthermore, the approach of conducting these cybersecurity risk assessments was not frequently updated to cover the latest cybersecurity threat landscape with some advanced/sophisticated cyber-attacks (e.g. Advanced Persistent Threats with the aid of stealthy malwares that facilitate sensitive data transfer activities). ii. Inadequate cybersecurity risk assessment of service providers LCs did not seem to take a pro-active approach to integrate the systems and control environments supported/maintained by service providers into the LCs cybersecurity risk management frameworks. LCs did not have any formal procedures or guidelines detailing the requirements of conducting cybersecurity risk assessment or on-site audit, if needed, on service providers. LCs only placed heavy reliance on the attestations, without documentation provided by the service providers or regular on-site audit to confirm that the service providers had performed cybersecurity risk assessments on their control environments. In addition, LCs did not further enquire or scrutinize the scope, approach and results of the cybersecurity risk assessments and/or the follow up actions taken by the service providers to mitigate cybersecurity risks identified. iii. Insufficient cybersecurity awareness training Despite the regular cybersecurity awareness training provided to staff, the content of the training did not seem to be updated with the latest cybersecurity related issues (e.g. any latest findings identified and recommendations proposed during the latest cybersecurity review) to keep the staff abreast of the latest cyber threats. iv. Inadequate cybersecurity incident management arrangements The coverage of cybersecurity incidents in the incident response plan and crisis management procedures were inadequate to address the risks imposed by the latest cybersecurity threats. The cybersecurity incident response plan did not properly include some serious or catastrophic, yet common, cyber-attack scenarios (e.g. loss of sensitive data, simultaneous cyber-attack to both primary and backup IT infrastructures). In addition, the coverage of the regular drills on cybersecurity incident response plans and crisis management was insufficient. Most of these drills were performed primarily to test the failover of some specific technical components only, instead of testing the

2 viability and adequacy of the end-to-end crisis management process which should cover, but not be limited to, incident management process and reporting and escalation of issues. Furthermore, when LCs performed regular drills or simulation exercises on the cybersecurity incident response plan and crisis management procedures, they only performed these drills/simulation exercises on a global level without the involvement of local LCs in Hong Kong. Additionally, some LCs might have performed these drills or simulation exercises locally, however, only technology staff were involved. v. Inadequate data protection programs Data protection programs were inadequate to address the latest cybersecurity threat landscape. For example, LCs did not include the following controls and procedures into their data protection programs: identify and document the data flow to keep track of both approved and emergency channels for internal and external data exchange; tailor the data protection processes and technologies (e.g. appropriate configurations and parameters of applicable tools and appliances to prevent unauthorized bypass of the data protection controls) according to their security policies, protection needs and regulatory requirements (e.g. personal data with privacy impact) to prevent data leakage from identified data flows; and appropriate responses (e.g. block or suspend the data flow) based on the sensitivity of data upon detection of suspicious data transfer activities. 2

3 Suggested Cybersecurity Controls i. Establish a strong governance framework to supervise cybersecurity management a. Designated resources should be adequately allocated to operate, govern and audit the controls in place to mitigate cybersecurity risks. b. Cybersecurity topics should be included as a regular agenda item in senior management level meetings in order to set the direction and cybersecurity strategy for LCs. Regular evaluation of staff s understanding and compliance with LCs policies should be conducted to ensure the alignment of staff s behaviour with the LCs cybersecurity strategy. c. Cybersecurity awareness training should be regularly provided to all staff, from senior to junior levels, and service providers, if applicable, followed by assessments (e.g. a simulated phishing exercise) to assess whether staff and/or service providers are equipped with a strong cybersecurity awareness culture. ii. Implement a formalized cybersecurity management process for service providers a. Cybersecurity risk management for service providers should be formalized and integrated into the LCs cybersecurity control frameworks. b. In addition to cybersecurity risk assessments conducted by the LCs during evaluation, on-boarding and/or termination of service providers, it is also crucial for the LCs to incorporate cybersecurity requirements in the agreements with service providers and to perform on-going cybersecurity risk assessments or on-site audits when necessary throughout the engagements. iii. Enhance security architecture to guard against advanced cyber-attacks Process a. Cybersecurity should be considered in the software development life cycle ( SDLC ) to allow early identification and remediation of security vulnerabilities prior to the launch of software (e.g. involve security specialists at the beginning of the planning stage, assess the protection needs and security requirements in the collection of system requirements stage, adopt security best practices in the design and implementation stages, perform security acceptance test in the testing stage, etc). Network b. Multi-tier network defences (e.g. firewall, Intrusion Detection System, Intrusion Prevention System and access controls on network level) and multi-layered security covering physical perimeters, network, operating systems, applications and data (e.g. internal network monitoring, application whitelisting 1, restriction of channels for data transfer and encryption, etc) should be implemented to enforce on-going monitoring and timely detection of abnormal system/network activities and user behaviour so as to mitigate the risk of advanced and persistent attacks. 1 Approve a list of applications which are allowed to be installed or run in operating systems to ensure only authorized applications could be executed in the LCs systems. 3

4 c. Security zones (e.g. demilitarized zone) should be considered within LCs networks for compartmenting systems and components according to their required level of cybersecurity protection (e.g. sensitivity of information resided in/processed by the systems). Control mechanisms should be in place to monitor, detect and restrict the connections established for unauthorized data transfer between different security zones. Operating Systems d. In order to protect computers and networks from cyber-attacks by malicious applications (e.g. some sophisticated malwares might not be effectively detected by anti-virus software), privileged user access to the operating system should be restricted to prevent installation of malicious applications, unauthorized manipulation of system configurations or removal of security tools in the users computers. LCs may also consider strengthening the control environment by implementing additional safeguards (e.g. application whitelisting) to prevent execution of unauthorized applications on users computers. iv. Formulate information protection programs to ensure sensitive information flow is protected a. Data protection programs should be established to ensure the data flow of sensitive information has been defined, identified, documented and protected. The deployment of data protection processes and technologies (e.g. Data Loss Prevention solutions) should provide adequate coverage for the identified data flows and trigger appropriate responses (e.g. block exchange of restricted data, suspend transfer of potential confidential data or escalate suspicious data transfer activities to designated personnel, etc.) according to the sensitivity of data. b. LCs should tailor the solutions and their underlying parameters to enable detection of malicious activities by behavioural monitoring (e.g. monitoring the data exfiltration over certain types of information, such as customer identifiers, source codes and large volume of encrypted files, after normal office hours) by taking into consideration different types of cyber-attacks and applicable regulatory requirements. c. Formal policies and procedures should be established for information security and data classification in order to classify data based on its level of sensitivity value and criticality to LCs. Data protection and baseline security controls should be established and determined based on the data classification to ensure sufficient controls are applied to meet the protection needs. Furthermore, formal data disposal and physical device destruction procedures should be established for disposing of confidential documents and physical devices to prevent data leakage. d. Recertification should be performed periodically on removable media access (e.g. removable hard disk) to monitor and restrict data exchange through the use of removable media according to a need-to-have basis. e. Mobile secure containers should be implemented in staff s mobile devices to create an encrypted environment and separate the firms applications and information from other personal data and applications in mobile devices. Data wipe-out functions should be enforced to remove the firms applications and information when the loss of mobile device is reported. 4

5 v. Strengthen threat, intelligence and vulnerability management to pro-actively identify and remediate cybersecurity vulnerabilities a. Cybersecurity risk assessment, including cybersecurity control gap analysis and benchmarking exercises, should be regularly conducted, with coverage of cybersecurity controls over both Internet-facing and internal systems/environments, taking into consideration the latest cybersecurity threat landscape. Such cybersecurity controls should also be adequately designed and regularly tested. b. Simulations of real-life cyber-attack scenarios (e.g. in a form of red team versus blue team in which red team would launch the cyber-attacks and blue team should defend the cyber-attacks and protect the systems and networks of the LCs) and the latest trends of cyber-attacks should be carried out to validate the effectiveness of the cyber-attacks defence mechanisms. c. Management should supervise the implementation of improvement initiatives when deficiencies are identified during cybersecurity risk assessment. Implementation timeline and milestones at a more granular level for each of the improvement initiatives should be defined. Management should make enquiries where there is any delayed implementation of improvement initiatives or prolonged period of implementation timelines. d. Vulnerability and security patch management process and procedures to implement bug fixes or upgrade for technologies should be formalized to remediate vulnerabilities identified in a timely fashion. Sufficient risk assessment and testing should be conducted before applying security patches to prevent unexpected system and business disruption. e. Effective controls should be implemented to prevent and detect any unauthorized devices being connected to LCs networks to access sensitive information or launch cyber-attacks within LCs networks. f. Anti-distributed denial of service ( DDoS ) mechanisms should be deployed to prevent DDoS attacks by filtering high volume and suspicious incoming traffic/cyberattacks. vi. Enhance incident and crisis management procedures with more details of latest cyberattack scenarios a. Incident response plan and crisis management procedures should include cyberattack scenarios which might seriously affect the business operations of LCs (e.g. loss of data, simultaneous attacks to both primary and backup IT infrastructures) and be tested by regular drills or simulation exercises to ensure all key stakeholders (including relevant representatives from the local business) have a good understanding of the cybersecurity incident and crisis handling procedures. vii. Establish adequate backup arrangements and a written contingency plan with the incorporation of the latest cybersecurity landscape a. A written contingency plan to cope with emergencies and disruptions due to cyberattacks should be established. Review and update of the written contingency plan should be performed regularly to ensure the latest cyber-attack scenarios and the 5

6 corresponding contingency handling procedures are incorporated into the contingency plan. b. The contingency plan with emergencies and disruptions related to cyber-attacks should be periodically tested covering the end-to-end cyber crisis management process with local stakeholders involvement to ensure the plan is viable and adequate to deal with cybersecurity incidents. c. Disaster recovery drill for mission critical systems should be performed to validate the switch over capabilities of IT components in the event of emergency. d. All backup tapes should be encrypted and protected physically (e.g. use of locked box for storage transportation) to ensure secure storage and transportation between locations. viii. Reinforce user access controls to ensure access to information is only granted to users on a need-to-know basis a. User access controls, including privileged users and recertification process, should be enforced to ensure user access rights are granted on a need-to-know basis with segregation of incompatible duties in place so that only appropriate personnel are authorized to access the data and information required for their job duties. b. Measures (e.g. virtual private network connection and two-factor authentication) should be taken for securing remote access from external networks to LCs internal networks. 6

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