You have been assigned to support the Padgett-Beale Merger & Acquisition (M&A) team working under the direct supervision of Padgett-Beale’s Chief Information Security Officer (CISO). The M&A team is in the planning stages for how it will integrate a new acquisition, Island Banking Services, into the company as its financial services arm (PBI-FS). Initially, PBI-FS will function as a wholly owned subsidiary which means that it must have its own separate cybersecurity program.
Your first major task (Project #1) will be to help develop a Cybersecurity Strategy & Plan of Action for PBI-FS. Island Banking Services never had a formal cybersecurity program so you’re starting from scratch. You will need to research best practices as well as relying heavily upon what you learned in your undergraduate studies in Cybersecurity Management and Policy. The CISO has provided detailed instructions for this task. (These appear after the Background section below.)
Background
After five years of operation, Island Banking Services -- a non-U.S. firm -- was forced into bankruptcy after criminal money laundering charges were filed against the company and its officers. Padgett-Beale, Inc. purchased the digital assets and records of this financial services firm from the bankruptcy courts. The purchased assets include licenses for office productivity software, financial transactions processing software, database software, and operating systems for workstations and servers. Additional assets included in the sale include the hardware, software, and licensing required to operate the company’s internal computer networks.
Figure 1. Island Banking Services IT Infrastructure Purchased by Padgett-Beale, Inc.
Padgett-Beale’s legal counsel successfully negotiated with the bankruptcy court and the criminal courts for the return of copies of the company’s records so that it could restart Island Banking Service’s operations. The courts agreed to do so after Padgett-Beale committed in writing to reopening the customer service call center (but not the branch offices) on the island. Reopening the call center will provide continued employment for 10 island residents including 2 call center supervisors. Padgett-Beale intends to relocate the call center to a company owned property approximately 10 miles away from the current location and adjacent to a newly opened Padgett-Beale resort.
Padgett-Beale’s Risk Manager has recommended that the Merger & Acquisition plan be amended such that Island Banking Services would be operated as a wholly owned subsidiary for a period of 5 years rather than being immediately and fully integrated as an operating element of Padgett-Beale. The company’s attorneys agreed that this would be the best approach given the potential for additional legal troubles related to the actions of the previous owners and employees. The Board of Directors has signed off on this amendment to the M&A plan and stipulated that the new subsidiary will be named PBI Financial Services (PBI-FS). The company officers and senior managers for PBI-FS will be named at a later date. For now, the leader of the M&A Team will serve as the Chief Operating Officer. Padgett-Beale’s Chief Information Security Officer will be loaned to PBI-FS while a search is conducted for a dedicated CISO for the subsidiary.
CISO’s Detailed Instructions to You
The CISO has given you and your team mates a set of instructions (below) which you should follow as you complete this task.
Task #1: Read and Analyze the Background Materials
If you have not already done so, read the Background information in this file. Next, review the Padgett-Beale M&A Profile 2020 which was posted to the LEO classroom. You should also review all materials from the classroom for Weeks 1 – 4 as these provide needed information about the Financial Services industry and the legal and regulatory requirements which apply to this industry.
Task #2: Perform a Gap Analysis & Construct a Risk Register
Using the information available to you, determine the most likely information technology/security gaps which existed at Island Banking Services prior to its being acquired by PBI. Next, determine which of these, if not addressed, will likely exist in the newly formed subsidiary PBI-FS. Document your analysis and evaluation in a Gap Analysis.
Your Gap Analysis should address operating issues relating to confidentiality, integrity, and availability (CIA) of information, information systems, and information infrastructures owned or used by PBI-FS. Your analysis should also consider and use the People, Process, and Technology framework.
Intro/Overview: Provide an excellent overview of the security strategy. Introduction must be clear, concise, and accurate. Writer appropriately used information from 3 or more authoritative source
Step 1: Identify 10 or more significant cybersecurity issues/challenges/risks which the background information and M&A profile indicate currently exist at PBI-FS / Island Banking Services. You are allowed to “read between the lines” but must be able to map your analysis and findings to specific statements from these documents. These items will become your “Gaps” for the Gap Analysis. Use one or more cybersecurity frameworks or standards (e.g. NIST CSF; People, Processes, and Technologies; Confidentiality, integrity, availability) to organize your analysis.