Update On The Central Bank Themed Inspections On Cyber-Security

Background

Further to our previous bulletin in May 2015, the Central Bank of Ireland ("Central Bank") has, on 23 September 2015, published the findings of its review of the management of cyber security and related operational risks across investment firms, funds service providers and stockbrokers. The objective of the review was to examine the status of firms' control environments, (including policies and procedures), to detect and prevent cyber-security breaches, as well as to assess board oversight of cyber-security.

Relevance of Cyber-Security

While the review focused on the entity types highlighted above, it is also very relevant to investment funds, banks and insurance companies. Indeed, while cyber-security is a current theme for the Central Bank, it should, in any case, be a central focus for all firms. Weaknesses in this area expose a firm to significant risks, including breaches of data security and client confidentiality provisions, failure to make