In the 21st Century, many of our essential services—health, transport, energy, water and digital infrastructure in particular—have become heavily reliant on networks, technology and internet connected service delivery. As such, it has become vital to ensure that services dependent upon technology are resilient to any kind of disruption—hostile or pure technological failure.
Out of this need, the government adopted the NISD—or Network Information Security Directive. NISD was incorporated into UK law in May 2018 with the aim of establishing a common security baseline for network and information systems to enable continuity of essential services, aligning the UK to the EU regulatory framework.
The NISD isn’t just about information, it is about operational resilience.
How is the NISD regulated?
The National Cyber Security Centre (NCSC) has set out an overarching set of principles and outcome-based objectives to which operators of essential services (OES) should demonstrate adherence. However, the NCSC recognise that they are not experts in the sectors and subsectors, so they have delegated the regulatory control to each sector’s Competent Authority (CA) who act as the regulators for each of the operators.
It is the job of the Competent Authority to develop their own Cyber Assessment Framework and inform those affected organisations whether they need to comply with the Directive. An organisation is denoted as an OES based on sector capacity and capability thresholds. For example, the Civil Aviation Authority (CAA) and The Department for Transport (DfT) are the joint Competent Authorities for airports.
This format of devolved regulatory management to the CA ensures that the set of common principles can be interpreted differently based on the idiosyncrasies of each sector, enabling the development of specific Cyber Assessment Frameworks for regulatory and audit purposes.
How do the thresholds work?
For example, one of the threshold criteria for the transport subsectors is based on number of passengers. For gas or electricity, some thresholds are based on holding capacities and the number of households supplied. Each subsector has its own thresholds; you can find detailed information here.
It is important to bear in mind that these thresholds are likely to change in the future, as are the sectors required to comply with the Directive.
Complying with the NISD
The world of cyber security is fraught with scaremongering and confusion. This means many consultancies take advantage of overwhelmed organisations that may not have the in-house skills and knowledge needed to implement the controls. Many of these consultancies see new regulations as a license to print money; the type of advice they give can often be totally disproportionate, incredibly expensive and unnecessarily disruptive.
With so much conflicting advice, it’s no wonder many organisations dread new cyber regulation – often seeing the expense and disruption before any positive corporate benefit. But it shouldn’t be that way because many organisations are often unaware of how far they already comply.
In PGI’s experience, NISD organisations tend to fall into the below categories:
- Mature – have in-house expertise and already have necessary controls are already in place.
- Need help – know they need to address the NISD but don’t have the full in-house knowledge, aren’t aware of their current maturity and need simple advice on how to achieve compliance.
- Haven’t started – aware of the NISD but may not have the time or resources to begin addressing the controls or review their existing compliance levels.
- Slightly below the threshold – the NISD does not apply now but will likely apply based upon projected growth.
Regardless of the category, many organisations have some element of information security controls in place, such as ISO 27001, GDPR and PCI DSS. These controls serve as a foundation for implementing NISD requirements, which means there is no need for completely new frameworks that can potentially involve unnecessary costs and resources. If a consultancy suggests starting from scratch, especially without reviewing your level of maturity, show them the door.
Implementing NISD with minimal disruption
Using what you have in place already as a foundation requires looking at risk management and decision making and controls that sit around your existing information security management, and ensuring that principles of the new directive are met. For example, all organisations have business continuity plans and disaster recovery plans in place. If you look at what you have and realign those to what the NISD requires, you will be on your way to compliance without the headache of a completely new set of controls.
But what if you don’t have anything in place or don’t have the in-house knowledge to make the links?
Good advice is absolutely critical to implementing the NISD. Even if you don’t have the knowledge and skills in-house, a good consultancy will work closely with your teams who have the specific knowledge of your business. A good consultancy will examine what your organisation has in place and work with you to fill the gaps, because it’s the most effective, cheapest and smoothest way to achieve compliance.
A platform to share advice - the NISD Community of Interest
We know that organisations across all sectors are struggling with many of the same issues – specifically, how to implement the controls effectively, smoothly and with minimum disruption. Ideally, we don’t want to see a repeat of GDPR – it was poorly introduced, and advice was inconsistent, resulting in significant operational disruption for many organisations.
We believe that with the NISD there is an opportunity to get the implementation right first time. While GDPR is applicable to every business, the NISD is relevant to a smaller number and specific set of organisations, allowing for a more controlled and planned implementation.
PGI have launched a community of interest to allow operators of essential services to share knowledge, resources, and best practice on implementation of the Directive’s principles. The community of interest allows professionals—regardless of OES—to speak to likeminded colleagues and seek advice on the implementation and ongoing maintenance of NISD. We hope this community forum will facilitate a better, more collegiate and less disruptive implementation process for all applicable organisations.
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