If there’s one thing we’ve learned over the years when it comes to security, it’s that there’s a whole lot more to creating a secure hedge fund (or any business for that matter) than robust technology. Before identifying infrastructure components and implementing operational policies, a firm must first be clear on what its attitude is toward security. This attitude will filter through the company from the top down, and will therefore dictate how employees and the business as a whole operate on a daily basis.
To give you a clearer understanding of what we mean, we’ve created three security profiles that cover a wide spectrum in terms of security attitudes and practices.
Under the Radar: Low Security
If you’re attitude toward security is low, odds are you’re barely scraping the surface in terms of what practices and policies you should be employing to maintain proper security firm-wide. You likely rely on quick fixes to solve problems instead of looking at the bigger picture and thinking strategically about how security can both benefit and protect your business. You’ve employed minimal preparedness efforts and could be in for a difficult task if faced with a serious security incident. You probably take a “it won’t happen to me” attitude and don’t take security seriously enough – a stance that could endanger your firm in the long term.
Categorized under: Security Launching A Hedge Fund Cloud Computing Disaster Recovery Hedge Fund Due Diligence Hedge Fund Operations Hedge Fund Regulation Infrastructure Communications Outsourcing Business Continuity Planning Trends We're Seeing Videos And Infographics
Mobile devices have transformed the way we manage our everyday lives: from how we track our bank accounts, to interacting with friends and family to booking travel, and so on. Everything you need is at your fingertips, but are you taking the proper security measurements to protect your device? Below are a few tips to help keep your smartphone’s data safe.
Set a Password: When you do not set a password to lock your phone, anyone who obtains possession of the device has instant access to all of your apps that automatically log-in upon launching. This is a simple security measure to take and yet, according to Consumer Reports' annual State of the Net Survey, only 36 percent of smartphone owners have a passcode. From a business use perspective, any device that accesses corporate email or networks should have a complex password and be managed by mobile device management tools such as AirWatch or Good Technology.
Mobile Security Apps: Looking to the future, we expect the adoption of mobile device security apps that provide antivirus, privacy and anti-malware protection to increase. And for good reason. According to the June 2014 McAfee Labs Threat Report, mobile malware has increased by 167 percent in the past year alone. Companies, such as AirWatch, aim to ensure your enterprise mobility deployment is secure and corporate information is protected with end-to-end security.
Hedge fund marketing and advertising has greatly evolved in the past few years, both with regulatory changes taking effect (in the US, the JOBS Act now allows public advertising) and new forms of media emerging, particularly social platforms such as Twitter, Facebook, LinkedIn and YouTube.
In the UK this week, the Financial Conduct Authority (FCA) took steps to further regulate how financial services firms market to consumers by launching guidance consultation on social media usage. As evidenced by FCA Director of Supervision Clive Adamson, the consultation is intended to ensure financial promotions on social media platforms protect consumers and are disseminated in a way that fairly balances both benefits and risks.
“The FCA sees positive benefits from using social media but there has to be an element of compliance. Primarily, what firms do on social media must ensure customers are at the heart of their business. Our overall approach is that financial promotions, whether on social media or traditional media, should be fair, clear and not misleading. We have had extensive industry engagement on this issue and we believe our guidance is a sensible approach that doesn’t affect industry’s ability to innovate using new forms of media. We recognise social media are constantly evolving. We, therefore, welcome feedback to [the] consultation and look forward to continuing the discussion with industry."
The last five years has seen an increase in reliance on technology among financial institutions. IT outsourcing has become more attractive to the financial services industry - but against the backdrop of increased reliance on complex IT systems and operations is the heightened risk of cyber-attacks and system disruptions.
In June 2013, the Monetary Authority of Singapore (MAS) issued the Technology Risk Management Guideline (TRMG), which addresses existing and emerging technology risks within financial institutions.
The objective of the TRMG is for financial firms to establish a sound and robust technology risk management framework, strengthen system security, reliability, resiliency, recoverability and deploy strong authentication to protect customer data and systems.
In today’s blog article we will take a look at some of the key guidelines covered in the guide:
The competition amongst firms in the financial services industry is ever burgeoning, and in order to achieve differentiation, it is imperative for firms to create and maintain robust, manageable, scalable and reliable technology infrastructures. Increasingly, we’re seeing more than just emerging managers opting for a cloud solution and established hedge funds and alternative investment firms shifting gears from traditional on-premise IT infrastructures to cloud services.
If you missed our webinar yesterday on Why the Billion Dollar Club is Going Cloud, read our recap below or scroll down to watch the full webinar replay, featuring Eze Castle’s Managing Directors Bob Guilbert and Vinod Paul.
The Business Case for the Cloud: Why Established Firms are Making the Move
Across the industry, established firms that have been in business for several years are moving away from physical infrastructures and adopting the cloud. Traditionally, investment firms would allocate substantial capital budgets to build on-premise Communication (Comm.) Rooms. These cost-intensive infrastructures can take months to build out, and specific expenses can vary depending on a firm’s unique needs. For example, at minimum, investment firms require file services, email capabilities, mobility services and remote connectivity, as well as disaster recovery and compliance. Beyond those, many firms also require systems and applications such as order management systems (OMS), customer relationship management tools (CRM), and portfolio management or accounting packages.
Categorized under: Cloud Computing Disaster Recovery Security Hedge Fund Due Diligence Hedge Fund Operations Hedge Fund Regulation Infrastructure Communications Outsourcing Trends We're Seeing Videos And Infographics
Your hedge fund's information security plan likely includes details on where information is stored, how it is accessed and who it is accessible to. But a critical component of this plan often overlooked is how and why data is destroyed when it is no longer needed. Including data destruction procedures in your WISP or as a separate document is vital to ensuring your firm’s sensitive data and intellectual property does not fall into the hands of the wrong people. Unfortunately, in today’s technology-driven, cyber-aware environment, simply hitting the delete key is not enough.
There are a few different scenarios that warrant secure data destruction maneuvers:
Changing service providers
Retiring a service/product
Your methods and policies for secure destruction may vary according to the above scenarios, or they may be standard across the firm. Your hedge fund should also consider if there are any regulatory implications. Do you need to maintain/archive data for a prescribed period of time in order to comply with state, federal or other compliance or auditing standards?
In any case, you’ll want to consider a variety of methods in the beginning to ensure your firm’s confidential data (e.g. investment portfolio, investor contact information, etc.) is thoroughly destroyed, preventing unwanted breaches or thefts.
When most people envision Business Continuity Planning (BCP) and testing, they conjure up images of conference rooms, hardcopy documents, projectors and key personnel. But the real world is a different reality.
In recent memory, there have been many situations that have disrupted businesses - be it by natural disaster or as a result of human interference. In either event, people need to be able to reestablish essential business functions, communicate, and make decisions as quickly and easily as possible.
Although many organizations do an annual BCP review, the big question is whether they truly test the process, ease of accessibility, and the time it takes an organization/leadership group to go from unsure about the situation to confidently executing a thoughtful game plan.
What can make a considerable difference in terms of functionality and familiarity with the plans and recovery procedures is to practice -- not only verbally in the conference room setting, but also by taking time to troubleshoot and brainstorm to determine what works and what may need a second look. There is a lot that can be learned from being unplugged and “kicked” out of the conference room and asked to assume a role outside of the comfort zone. This can be done simply by taking away some of the accepted norms during a test. The following scenario illustrates issues that arise when the accepted norms are chipped away.
We spend a lot of time educating our clients about security best practices and encouraging them to implement comprehensive security policies and procedures to mitigate risk and protect both the firm and its employees. And for good reason. Just today, New York Attorney General Eric Schneiderman released a report stating data breaches across the state more than tripled from 2006 to 2013 and cost businesses more than $1.37 billion last year alone.
While companywide policies should reflect long-range expectations and corporate best practices, they should also include tactical recommendations that employees can follow to ensure they are complying with the company’s overall risk strategy. In addition to providing employees with security best practices they should follow, don’t forget to also include a list of actions they should not. Here are just a few pieces of advice we regularly offer our investment firm clients:
Lock your computer and mobile phone(s) when you leave your desk and/or office
Use care when entering passwords in front of others
Create and maintain strong passwords and change them every 60-90 days (We recommend a combination of lowercase & uppercase letters and special characters)
One of the first questions on the SEC’s cybersecurity questionnaire for financial firms asks firms to "indicate whether they conduct periodic risk assessments to identify cybersecurity threats, vulnerabilities and potential business consequences", and if so, who conducts them and how often. Clearly the goal behind this question is to ensure that firms are taking a proactive approach to security. But what exactly does this assessment entail?
Here’s a quick overview.
The type of risk assessment typically associated with information technology/security is an external vulnerability assessment. Essentially, this is the process of identifying and categorizing vulnerabilities related to a system or infrastructure. Typical steps associated with a vulnerability scan or assessment include:
Identifying all appropriate systems, networks and infrastructures;
Scanning networks to assess susceptibility to external hacks and threats;
Classifying vulnerabilities based on severity; and
Making tactical recommendations around how to eliminate or remediate threats at all levels.
We continue to speak with clients and prospects on a regular basis on the topic of cybersecurity, and with the expectation that the SEC will start security exams sometime around September, it’s evident that firms are working diligently to answer the questionnaire and shore up internal practices.
To continue fostering education around this topic, we hosted two events last week dedicated to cybersecurity for hedge funds and investment firms. For your convenience, you can read a brief recap of some of the key topics discussed or scroll down to watch our full webinar replay.
Cybersecurity a Hot Topic on State & Federal Level
By now, we all know the SEC has taken steps to assure that hedge funds and investment advisers put security mechanisms and practices in place to protect against cyber threats. SEC Commissioner Luis Aguilar said there is “substantial risk that a cyber-attack could cause significant and wide-ranging market disruptions and investor harm.” Even beyond the federal level, some states are chiming in on the cybersecurity front. Earlier this month, Massachusetts and Illinois acknowledged that they were polling investment advisers about their security practices, and that based on responses, state regulations could be impacted.
Categorized under: Launching A Hedge Fund Security Hedge Fund Due Diligence Hedge Fund Operations Hedge Fund Regulation Infrastructure Communications Outsourcing Business Continuity Planning Trends We're Seeing Videos And Infographics