NIS Directive: are you ready?

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Governments across Europe recognised that with increased interconnectiveness a cyber incident can affect multiple entities spanning across a number of countries. Moreover, impact and frequency of cyber attacks is at all-time high with recent examples including:

  • 2017 WannaCry ransomware attack
  • 2016 attacks on US water utilities
  • 2015 attack on Ukraine’s electricity network

In order to manage cyber risk, the European Union introduced the Network and Information Systems (NIS) Directive which requires all Member States to protect their critical national infrastructure by implementing cyber security legislation.

Each Member State is required to set their own rules on financial penalties and must take the necessary measures to ensure that they are implemented. For example, in the UK fines, can be up to £17 million.

And yes, in case you are wondering, the UK government has confirmed that the Directive will apply irrespective of Brexit (the NIS Regulations come into effect before the UK leaves the EU).

Who does the NIS Directive apply to?

The law applies to:

  • Operators of Essential Services that are established in the EU
  • Digital Service Providers that offer services to persons within the EU

The sectors affected by the NIS Directive are:

  • Water
  • Health (hospitals, private clinics)
  • Energy (gas, oil, electricity)
  • Transport (rail, road, maritime, air)
  • Digital infrastructure and service providers (e.g. DNS service providers)
  • Financial Services (only in certain Member States e.g. Germany)

NIS Directive objectives

In the UK the NIS Regulations will be implemented in the form of outcome-focused principles rather than prescriptive rules.

National Cyber Security Centre (NCSC) is the UK single point of contact for the legislation. They published top level objectives with underlying security principles.

Objective A – Managing security risk

  • A1. Governance
  • A2. Risk management
  • A3. Asset management
  • A4. Supply chain

Objective B – Protecting against cyber attack

  • B1. Service protection policies and processes
  • B2. Identity and access control
  • B3. Data security
  • B4. System security
  • B5. Resilient networks and systems
  • B6. Staff awareness

Objective C – Detecting cyber security events

  • C1. Security monitoring
  • C2. Proactive security event discovery

Objective D – Minimising the impact of cyber security incidents

  • D1. Response and recovery planning
  • D2. Lessons learned

Table view of principles and related guidance is also available on the NCSC website.

Cyber Assessment Framework

The implementation of the NIS Directive can only be successful if Competent Authorities  can adequately assess the cyber security of organisations is scope. To assist with this, NCSC developed the Cyber Assessment Framework (CAF).

The Framework is based on the 14 outcomes-based principles of the NIS Regulations outlined above. Adherence to each principle is determined based on how well associated outcomes are met. See below for an example:

NIS

Each outcome is assessed based upon Indicators of Good Practice (IGPs), which are statements that can either be true or false for a particular organisation.

Whats’s next?

If your organisation is in the scope of the NIS Directive, it is useful to conduct an initial self-assessment using the CAF described above as an starting point of reference. Remember, formal self-assessment will be required by your Competent Authority, so it is better not to delay this crucial step.

Establishing an early dialogue with the Competent Authority is essential as this will not only help you establish the scope of the assessment (critical assets), but also allow you to receive additional guidance from them.

Initial self-assessment will most probably highlight some gaps. It is important to outline a plan to address these gaps and share it with your Competent Authority. Make sure you keep incident response in mind at all times. The process has to be well-defined to allow you report NIS-specific incidents to your Competent Authority within 72 hours.

Remediate the findings in the agreed time frames and monitor on-going compliance and potential changes in requirements, maintaining the dialogue with the Competent Authority.

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Vienna Cyber Security Week 2018

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I’ve spend last week in Vienna at the annual intergovernmental conference focused on protecting critical energy infrastructure.

The first two days were dedicated to the issues of security and diplomacy.

A number of panel discussions, talks and workshops covered the following topics:

  • Implementing the EU strategy for safe, open and secure cyberspace
  • Cyber-threats to critical energy infrastructure
  • Operational resilience
  • Reducing the risks of conflicts stemming from the use of cyber-capabilities
  • Cyber-diplomacy: developing capacity and trust between states

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For the rest of the conference we moved from the Diplomatic Academy of Vienna to Tech Gate, a science and technology park and home to a number of local cyber startups.

We’ve discussed trends in technology and cyber security, participated in Cyber Range simulation tutorial and a scenario-based exercise on policy development to address the growing cyber-threat to the energy sector.

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AIT Austrian Institute of Technology together with WKO Austrian Economic Chambers, ASW Austrian Defence and Security Industry, and the Austrian Cyber Security Cluster hosted a technology exhibition of latest solutions and products as well as R&D projects.

Participants had an opportunity to see state-of-the-art of next generation solutions and meet key experts in the field of cyber security for protecting critical infrastructures to fight against cyber-crime and terrorism.

Talks continued throughout the week with topics covering:

  • Securing the energy economy: oil, gas, electricity and nuclear
  • Emerging and future threats to digitalised energy systems
  • Cyber security standards in critical energy infrastructure
  • Public sector, industry and research cooperation in cyber security
  • Securing critical energy infrastructures by understanding global energy markets

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The last day focused on innovation and securing the emerging technologies. The CIO of City of Vienna delivered an insightful presentation about on cities and security implications of digitalisation.  A closing panel discussed projected trends and emerging areas of technology, approaches and methods for verifying and securing new technologies and the future of the cyber threat.