Working Practices

Cyber Security Policies – A Must Have or a Nice to Have

I’ve written about this a couple of times now but it’s worth reminding people that policies and attendant processes are a cost-effective necessity in terms of cyber security.  How important are policies and processes in comparison with technology, when it comes to Cyber Security and its sister discipline, data protection.  The clue is that in Cyber Security we refer to People, Process and Technology, in that order.

Top of this list is People, and I’ve written extensively about how important cyber awareness training is for all, managers and employees alike.  This piece is all about policies and processes.  First and foremost, policies have to be relevant to the organisation and not just downloaded from the internet, maybe with a few modifications, before applying a tick in the box and moving on.  Policies have to mean something and have a purpose.  Many organisations I go to either have some very scant policies or actually, none at all.

I often talk about risk in terms of cyber security and how managing that risk is extremely important.  And that means understanding what those risks actually are, and then taking steps to mitigate them.  When I talk about this, I can often see the wheels turning and the audience thinking technology and how much is that going to cost them.  Well, it’s often the case that technology is not the answer.  There are many risks where a good policy, promulgated to, and understood by all, can save the company money.

A good example of that is a fairly common scam that tends to costs SMEs between 5 and 50K depending upon the size of business.  How this is achieved is that the scammer or let’s call him/her what he/she is, the criminal, spends some time profiling the company, using various social engineering techniques to work out how the company is organised and who is who.  You may be surprised as to how much of that information is freely available on the company website, companies house and other sources. Having discovered who the boss is, and who looks after invoice payments, the criminal then ‘spoofs’ the bosses email.  Email spoofing, in simple terms, is sending an email purporting to come from someone else.  So, it arrives purporting to come from the boss, but it’s from the scammer.  Such an email is sent to the person who pays invoices, with an invoice attached, saying please pay this as a matter of urgency.  This happened not so lo g ago to someone I know, and when it arrived in the accounts department it didn’t look genuine to the payments clerk, who replied to the email asking if the boss was sure.  Of course, she got an email back saying yes, I’m sure.  She paid it and the company lost over 30K.  The accounts clerk was clearly switched on but she made a basic error, because she didn’t know any different.  If she had sent a fresh email to the boss querying the invoice, it would have gone to the boss who could have stopped the transaction.  Instead, she replied to the email and her reply went back to the scammer.  A policy which dictates fresh emails rather than using the reply function, and known to all, would have saved the company a lot of money.

Policies and attendant processes are essential for the protection of company data and the bottom line, company money.  What needs to be covered and in what depth, depends on the risks that the company is facing, and will differ company to company depending on its type.  In broad terms, and as an absolute minimum, the following are required:

  • Overarching IT security policy – often this only needs to say very clearly what responsibilities employees have in regard to security and data protection, lay down a requirement and responsibility for cyber awareness training, and state that all employees are to be cognisant of all the policies and are to sign that they have read and understood them.  And most importantly, it must be signed off at board level making it clear that this is a crucial requirement.
  • IT Acceptable Use Policy – what is, and what is not, an acceptable use for company IT.
  • IT Email Policy
  • IT password policy
  • IT Mobile working policy – essential for mobile workers who may be tempted to work from a coffee shop, and of course, working from home.  This latter might be a separate policy or can be part of the mobile working policy.
  • Data Protection Policies – a whole other subject.
  • Social media policy – this can be really important.  Probably 100% of your employees will have a social media presence and will use it daily. How important is it that they don’t associate themselves with the company on their private social media?  Depends on the person but it could be damaging in reputational terms.  The company might also do some digital marketing on social media.  Who is, and who is not, allowed to get involved with that function.

This is not an exhaustive list.  It depends very much on risks that needs mitigating.  They will also be accompanied by processes to support the policy.

Cyber Security Strategies for SMEs

What is a Cyber Security Strategy

A cyber security strategy is a plan that outlines an organisation’s approach to protecting its information systems and data from cyber threats. This strategy typically includes measures such as implementing security controls, conducting regular risk assessments, training employees on security best practices, monitoring network activity for suspicious behaviour, and responding to security incidents in a timely manner. The goal of a cyber security strategy is to minimise the risk of cyber-attacks and protect the confidentiality, integrity, and availability of an organisation’s sensitive information.

Do I really need that – I’m an SME and not really a target, am I?

Well yes, you are a target and there are a ton of statistics available which shows that SMEs globally are a very real target for cyber-attacks and can in fact, be very profitable for cyber criminals.  There are a lot of reasons for that but one of the top reasons is that typically, SMEs spend very little on cyber defence and generally have very weak defences.  Add to this that they don’t tend to carry out cyber awareness training for their staff, have limited resources and generally don’t have a good grasp of the issues.

Not their fault.  Most are focused on their core business, trying make a quid or two and are pressed for time.  They tend to rely on whatever company, usually local, that supplied their network, hardware and software, generally on a retainer.  The problem is that those companies don’t really have a good grasp of the issues either, concentrating on technology, and then, not necessarily the right technology.

When it comes to cybersecurity governance and management, there is no “one size fits all” approach.  In today’s threat landscape we need to fully understand that cyber security is not a purely technical problem, focused on hardware and endpoint protection and on operations within the organisational perimeter.  Today we are dealing with cloud storage, in office and remote working, data at rest and in transit, involving security at every point along the route.

It is critical that someone within the organisation has to take responsibility for cyber security and that person must have a seat on the Board. A Board-level response is not just appropriate; it is essential.

Secure by default and design

Now that’s an interesting title, but what does it mean?  Secure by default and design means that a system or product is inherently built with security measures in place from the start. This ensures that security is a priority throughout the development process and that users can trust that their data and information will be protected. It also means that security features are enabled by default, reducing the risk of vulnerabilities or breaches. This approach helps to create a more robust and resilient system that is better equipped to withstand potential threats.

It applies as much to your network and systems as it does to software development and possibly more importantly to you, it is a legal requirement under the Data Protection Act 2018, or as it is becoming known, UK GDPR.

The first problem many people come up against is that they already have a network, probably connected to the cloud of some sort, very possibly for SMEs, MS365, but when the design was done, there wasn’t a full risk assessment undertaken which is a requirement to underpin that design.  In other words what we in the cyber security industry refer to as Security Architecture Design (SAD), wasn’t a prominent consideration.

Not unusual and the common technologies were probably set up, firewalls and anti-virus, but not much else.  And that is where a well thought out strategy comes into play.

What should I be considering in my Cyber Security Strategy

We’ve already said you are an SME, so do you need the sort of comprehensive cyber security strategy that we would see in a major corporate?  No, but it should still cover off the major points and should continue to be reviewed alongside things like your Health and Safety policy and other industry standards that are required to be reviewed for you to stay in business, usually annually.

You need to be thinking about the key components needed to effectively protect an organisation’s digital assets and data. These components may include:

1. Risk assessment: Assessing potential cybersecurity risks and vulnerabilities to identify areas of weakness and prioritise areas for improvement.

      2. Security policies and procedures: Establishing clear and enforceable policies and procedures for data protection, access control, incident response, and other security-related activities.

      3. Employee training: Providing ongoing training and education to employees on cyber security best practices, such as password management, phishing awareness, and safe browsing habits.

      4. Security tools and technologies: Implementing robust security tools and technologies, such as firewalls, intrusion detection systems, encryption software, security monitoring tools and data protection tools, and endpoint protection solutions.

      5. Incident response plan: Developing a detailed incident response plan that outlines the steps to be taken in the event of a security breach or cyber-attack, including communication protocols, containment measures, and recovery strategies.

      6. Regular audits and testing: Conducting regular security audits and penetration testing to assess the effectiveness of existing security measures and identify any vulnerabilities that need to be addressed.

      7. Collaboration with external partners: Establishing a partnership with cyber security company that understands the issues that affect SMEs and who themselves can establish a solid working relationship with the IT provider that is providing and administering your network and IT resources, will enhance your protections, significantly improve your employee and managerial awareness of the issues, and provide you with the peace of mind you need, allowing you to concentrate on your core business.

      Cyber Maturity

      What do we mean by cyber maturity?  It’s not just about the protections you may have in place, but more about how well your organisation understands the importance of it and its place in your overall business strategy.  It is after all a business issue, not a technical issue and needs to be treated as such. Modern security solutions are increasingly complicated and challenging. These complexities change all the time and with the changes in working patterns and the introduction of AI now at the hands of the cyber criminals, they require a broad understanding of cyber security. Very few SMEs possess this level of expertise and can find themselves struggling to protect themselves and rectify security risks discovered within their business. In a climate of frequent, and potentially devastating, malicious activity organisations need targeted, rapid remediation and effective solutions. In doing this they will improve specific areas of their security systems, reduce their level of exposure and minimise potential losses, which can be very significant.

      Many small and mid-size businesses struggle to combat the threat that cybercrime poses. A simple piece of malware or a social engineering event, can result in the loss of sensitive company and client data, disrupt business and waste staff time. Such incidents are commonly sensationalised by the media, causing client defection and damage to hard-earned reputations, resulting in significant loss of business.

      I’ve described the risk management process before, and I know it can be a bit daunting, and many would fear it’s costs and complexity.  That is why we have designed and taken into use the Cyber Maturity Assessment (CMA), specifically for SMEs which will enable them to go down the risk management road at a pace and price they can afford.  The CMA is designed to obtain a view of where a client sits currently in terms of their Cyber Security posture. It is obtained from the results of interview with the staff, examination of current policies and procedures, including their effectiveness, security architecture and technical controls, and observations to gain an understanding of cyber security by management and staff. It is designed to provide a report which shows a client exactly where they sit in terms of Cyber Risk in a way that is demonstrable and east to understand. It gives a client a starting point from which H2 consultants will be able to scope any problems.

      What Does a Cyber Maturity Assessment Give Me?

      In brief, the CMA is designed to:

      • Understand and define the target state of the system i.e., where does the client want to be in terms of Cyber maturity – in defining the target state there must be a clear understanding of the business drivers, future business demands and business dependencies affecting the organisational area under examination.
      • Understand the current level of Cyber maturity – At this point the matter of cyber maturity will be a somewhat subjective view, obtained from the results of interviews with staff and initial observations by H2 consultants. This element is not intended to replace a detailed understanding, but to provide an initial view and start point, from which H2 consultants will be able to scope the problem and recommend any remediation required, in a phased way.

      We measure both the starting point and the end point using the Carnegie Melon Cyber Maturity Model.  I know other consultancies will use other models for this, but this is one that we have found to be effective, both for SMEs and in the corporate world.  It looks like this:

      I mentioned earlier that this is something used in the corporate world and whilst that’s true it is a matter of scale and need.  Most corporates would have the requirement and budget to aim high, say at around CMMI4 (5 is rarely hit).  For most SMEs that’s a step too far and as a rule of thumb, when we do this, we tend to find we’re starting at around 0.8 to 1.5 with the aim to get to CMMI 2 as soon as is feasible, with the end game at CMMI 3 which is affordable for most SMEs if a phased approach is taken.

      At the end of this initial process and SME is rarely able to just jump in and accept the recommendations and get on with fixing them.  It can be a complex issue requiring a hard look at their staff in terms of cyber awareness training, their policies and processes and their technical solutions, all aimed at prioritising the protections required for each asset in accordance with their vulnerabilities and threats.

      A phased approach is almost always needed, often aligned with budgets.  It can look a bit like this:

      The first transformation project tends to be what we term the Quick Wins Phase ie what can we do relatively easily, quickly and therefore affordably, to give the client the most urgent fixes.  It often, but not always, looks like this:

      This has just been a very quick cantor through the CMA process, and we need to emphasise that each client has a different set of requirements, and we can often jump into the process at a different stage. Call us if you want to know more.

      Cyber Security is a Business Issue

      This is a subject I return to quite often and it’s all about how cyber security is viewed by many SMEs, and I’ll explore why that view appears to be paramount.  I am pretty much of the view that the attitude I’m about to expand on, is as much the fault of the cyber security industry, as anything else.

      We tend to flood potential clients with adverts and articles, mainly focused on technology.  Many of this comes from sales, rather than from the seasoned cyber security experts, that you might wish it did.

      Let me give you a couple of quotes.  The first comes from a renowned Harvard scientist and cyber security specialist.  He says, ‘If you think technology can solve your security problems, then you don’t understand the problems and you don’t understand the technology’.’  The second comes from Stephane Nappo, Vice President and Global Chief Information Security Officer for Groupe SEB, ‘It takes 20 years to build a reputation and a few minutes of cyber-incident to ruin it.’

      Boil that down and they are saying that this is not an IT issue, it’s a business issue.  That’s not discounting technology’s role but without integrating it with PEOPLE and PROCESS, we’re only curing half the ailment. When advising a company’s leaders, we must not only identify the threats but also gauge vulnerability to these threats and ascertain the risk to the business. Only then can we craft a solution that harmoniously unites People, Process, and Technology.

      Perhaps because there is a considerable amount of what we call FUD, fear, uncertainty and doubt, doing the rounds constantly, it concentrates people on thinking about specifics, instead of looking at the bigger picture.  Whilst there is no doubt that phishing, ransomware, and other scams have certainly concentrated the mind somewhat, and these attacks are most definitely not confined to the large enterprise businesses, but have been attacking, with a lot of success, the small to medium business market, this causes vendors to try and exploit the issues around that and push their technology solutions and of course, SMEs rarely, if ever, have the expertise to judge whether or not a particular product will actually give them the protection they need.  We now must add into the mix AI and its capacity for increasing cyber-attacks at all levels, making the production of code, so much easier and making it available to those perhaps less skilled than heretofore.

      As we travel around and visits clients or potential clients, it is common to find that they have the view that adequate security is provided by technology.  They rely on their IT provider to give the guidance they need which tends to involve firewalls, anti-malware software and perhaps a backup regime.  All well and dandy.  Let’s just remind ourselves of the quote from Bruce Schneier:

      If you think technology can solve your security problems, then you don’t understand the problems and you don’t understand the technology’. 

      So, what does he mean?  As he’s not here to ask I suggest what he’s saying is that essentially the technology available can be an essential part of your protection but it has to be targeted in the right way, which not only means you have the right piece of kit doing the right thing, but that you are targeting your IT spend to support your business goals and give a maximum return on investment (ROI).  It should also be married to good policies and processes that are enforceable and auditable and fully understood by your work force.  To do this you have to understand exactly what your risks, vulnerabilities and threats are to ensure that your solution to those risks, vulnerabilities, and threats, is targeted for maximum effect and ROI and that the technology is supporting the policies and processes, all of which is underpinned with good security awareness training.

      It’s also necessary to have some form of measuring the effectiveness of your solutions through a protective monitoring solution.  Such solutions for SMEs have long been considered too expensive to even consider, even though it provides a set of cybersecurity practices and measures aimed at safeguarding an SMEs digital assets and sensitive information.

      But first and foremost, you need to identify the risks that you face. How can you identify that risk and then mitigate it?  Taking risks is a part of business.  You assess risk every day when doing business.  Do you want to do this deal?  What happens if it goes not as expected?  Do I want to take this person on?  Etc etc etc.  Whether you formally undertake a risk assessment or whether you assess that risk informally, you are working out what is appropriate to a level that is consistent with the risk that your organisation is prepared to take.  Failure to do that will almost certainly be damaging to your business, perhaps fatally so. 

      Within SMEs the difference between assessing day to day business risk and assessing risk to information assets, is one of understanding.  What is an information asset?  Note the word ‘information’ rather than IT.  It is the information contained within the IT system that is the important asset, not the piece of hardware it is sitting on.  You understand your business risk, after all it is your business, but do you understand information risk?  Do you have a clear idea of what information assets you have and where they are?  Before you answer that think it through.  Do you really know where all the data is?  OK, you know that you have a server or servers and that somewhere in those servers there is a bunch of data which runs your business.  How much of that data has been saved onto staff workstations when they needed it to carry out some work?  How much has been copied off somewhere else for what was probably a very good reason at one point?  How well is your firewall functioning?  Can malware work its way onto the network because the firewall does not have Universal Threat Management installed and can therefore be probing the servers and workstations.  I could go on.

      The first thing to understand is that these risks are owned by the board, and if you don’t have a formal board, then the management team.  That needs to be understood fully by those at the top.  That team needs to understand what level of risk is acceptable and agree what risks you are prepared to tolerate to achieve your business aims.   You need to ensure that supporting policies are produced, implemented, understood by employees, and regularly reviewed and updated.  At H2 we tend to produce an information security and data protection handbook which can run into many pages.  Producing these policies is not as easy as it sounds.

      You may also wish to look at some recognised standards by which you can regulate your risk management.  One such is the international standard for information security, ISO 27000 series but perhaps the most appropriate for SMEs is the Cyber Essentials Scheme which will help you demonstrate an appropriate level of information security and risk management within your company.

      Once you have a risk management framework in place, owned from the top, then you can identify your information assets and assess the risk to your business should those assets be compromised in some way.  Then and only then can you adequately assess what processes and technologies you need to mitigate the risks identified for each asset thus targeting your spend for maximum effectiveness.

      Sadly, that’s not the end.  User education is probably the most important element of all for an SME.  Ensuring that your staff are aware of the policies and why they exist.  Protect yourself against scams which sadly, form the biggest danger to SMEs rather than hacks.  Scams can be very low tech or high tech using malware, but however they come in, your staff need to be aware of them.

      Scams v Hacks

      We hear a lot about the consequences of cyber-attacks and data breaches but not a lot about the specific threats against SMEs, rather than the generic threats against all businesses.  In general businesses are more likely to be targeted by scammers (social engineering attacks) than by purely technical attacks.  But why?  Attacks against individual SMEs are not going to bring in a lot of profit for the criminal, so they often go after multiple targets all at once.  How they do that is to craft an attack which can be automated and directed at many SMEs all at once.  The easiest way to do that is via a social engineering attack.  Let’s take a look at what we mean by that.

      Scams and social engineering attacks rely heavily on human error.  Not only do SMEs have weaker defences than their corporate cousins, but they spend little, if anything, on cyber awareness training.  The attack that brought down Knights of Old, reducing a once thriving business to bankruptcy in a frighteningly short time, was the result of a weak password being cracked.  That suggests that OK, a stronger password protocol and the use of MFA would have been of great benefit but so would educating the users about social engineering and how they can protect the company and their jobs.

      Typically, we see:

      • Phishing emails that trick employees into giving credentials or downloading malware.
      • Business email compromise (BEC) — attackers impersonate executives to request bank transfers or the immediate payment of an invoice.
      • Fake invoices or supplier fraud.

      It’s done this way simply because it’s easier and cheaper to execute than a technical attack.  It’s scalable with scammers sending thousands of phishing emails, and it often bypasses technical defences by exploiting people directly.

      In addition to the traditional attacks, we are now facing AI generated attacks, enabling criminals to design scams that are even more scalable and to be produced more quickly.  Some examples include:

      Deepfake CEO Fraud (AI-Generated Voice or Video)

      A finance employee receives a video call from someone who appears to be the CEO instructing them to urgently transfer funds to a supplier. The video and voice are AI-generated deepfakes using real footage and voice samples taken from public online sources.  This has happened in the UK causing a UK based firm to lose over £20m in early 2025.  Obviously not an SME but the attack was not difficult to generate.

      Another AI attack was an upscale of the Business Email Compromise:

      Criminals use AI to monitor and mimic email communication styles. They craft perfectly worded emails from a company executive asking the accounting team to update supplier bank details or pay fake invoices.  What is new in 2025 is that AI now personalises these scams based on internal speech patterns and tone scraped from Slack or Teams (when credentials are compromised and that list is not exhaustive – other online messaging systems are available).

      One scam that we are now seeing more of is the fake job applicant scam targeting HR departments and IT onboarding teams.  Scammers apply for remote jobs using fake CVs and AI-generated video interviews. Once hired, they gain access to internal systems and exfiltrate data or install malware.  They’re playing the long game here, but it can really pay off.

      There are lots of examples and I’ll just put in a couple more:

      How many of you use Software as a Service (SaaS) and pay a subscription? In this case a fake renewal notice is sent for services like Microsoft 365, Zoom, or Slack. The email contains a link to a spoofed portal, which steals company admin credentials when they try to “log in.”   A new twist in 2025 is that the phishing emails are personalised with real invoice numbers and recent usage data scraped from prior breaches.

      Most of you are probably on LinkedIn, even if you are not particularly active on there.  We are now seeing more of the LinkedIn Clone Attack.  What happens here is that the scammers clone the LinkedIn profile of a known business leader and use it to reach out to employees or partners, proposing urgent collaborations or investment opportunities that include malicious links.  In a more advanced tactic, they use AI-generated responses in real-time chats that make these accounts seem very real.

      So, in conclusion, whilst we cannot rule out the more technical attack on an SME, we can say that the most likely attack will come via some sort of scam, often nowadays using AI.  The defences need to be in depth and will include some technical defences but often the best defence against social engineering is cyber awareness training and this is generally ignored by SMEs.

      Do CISOs have a role in the Small to Medium Enterprise?

      A Chief Information Security Officer or CISO, is a post you almost never find in an SME, even those at the top end of that sector.   This has contributed to the growth of what is known as fractional appointments i.e. appointments that are not full time with the incumbents often taking roles in more than one organisation, thus the term Fractional.

       Anyone taking any role in an SME management team will need to be pragmatic, practical and bring cost effectiveness to their discipline.  The CISO role is no different and is all about managing risk, enabling the business and ensuring trust in a very cost sensitive environment.

      The CISO can play a crucial role in an SME by ensuring that the organisation’s information and data assets are secure. While the CISO role in a large corporation may be more siloed or focused on strategy, in an SME the CISO often wears multiple hats, balancing strategy, operations, and hands-on technical work.

      Challenges Unique to SMEs

      I’ve often talked about the challenges that SMEs face, focusing as I do on cyber security.  Let’s just have a quick recap looking at where the CISO fits in with these unique challenges.

      • Limited budget and staff: This is the main reason why SMEs will not employ a full time CISO, they simply can’t afford it.  The other being that an SME probably doesn’t require a full-time resource anyway.  Because of this lack of resource the CISO may also act as a hands-on security engineer or IT lead, perhaps liaising with a contracted IT outsourcer.
      • Lack of security culture: Many SMEs don’t prioritise security until after a breach.  The CISO will be able to raise awareness and provide advice and guidance before the fact.
      • Rapid growth and change: Scaling securely is a key challenge as SMEs expand and there are often gaps left because of overlooking the need to embed security at the design stage.  The CISO can plug that gap.

      Let’s take a look at the potential elements of a job description for the role of a CISO, or a Fractional CISO, in an SME.  Of course, these may not fit everyone and it’s more of a menu for SMEs to choose from:

      1. Developing and Leading the Cybersecurity Strategy
      2. Define the overall information security roadmap aligned with the SME’s business goals.
      3. Balance security with business agility, in other words making sure security does not get in the way of business and keeping in mind budget constraints typical in SMEs.
      4. Ensure the strategy addresses risk management, compliance, and data protection.
      • Risk Management and Assessment
      • Identify and assess cyber risks relevant to the SME (e.g., phishing, ransomware, insider threats).
      • Conduct regular vulnerability assessments and penetration tests.
      • Prioritise risks based on business impact and likelihood.
      • Policy and Compliance Management
      • Develop and enforce security policies, standards, and procedures.
      • Ensure compliance with relevant regulations (e.g., GDPR, PCI-DSS etc depending on industry).
      • Prepare for audits and provide documentation to demonstrate compliance.
      • Security Awareness and Training
      • Conduct regular security awareness training for employees.
      • Create a culture of security by promoting best practices (e.g., strong passwords, phishing awareness).
      • Incident Response and Business Continuity
      • Develop and maintain an incident response plan.
      • Lead the response to security breaches and minimise damage.
      • Ensure business continuity and disaster recovery plans are in place and tested.
      • Technology Oversight and Vendor Management
      • Evaluate and implement cybersecurity tools (e.g., firewalls, endpoint protection etc).
      • Manage relationships with third-party vendors, especially cloud providers and MSSPs.
      • Ensure that vendors comply with the SME’s security requirements.
      • Ensure the SME itself is not in conflict with any security requirements of larger organisations if it is in that organisations supply chain.
      • Board and Executive Communication
      • Translate technical risks into business language for senior management.
      • Report regularly on security posture, incidents, and needs.
      • Advocate for security budget and resources in line with organisational risk appetite.

      I hope that gives a feel as to why an SME might want to consider a Fractional CISO or Board Advisor.  Cyber-attacks are becoming more sophisticated, faster and harder to repel.  It is no longer just the corporates who are in the firing line.  Modern, often AI driven attacks have put everyone in the sights of the modern cyber-criminal and even from those criminal organisations that are nation state funded.  It’s never been more crucial to have professional advice and guidance on tap.

      Cyber Resilience – What Does It Entail?

      The Cyber Security and Resilience Bill

      Following the fallout last year, from the CloudStrike sensor failure that led to significant outages worldwide, we wrote a piece questioning whether we are truly addressing Cyber challenges. Subsequently, the UK introduced The Cyber Security and Resilience Bill, which was debated in Parliament in 2025. This legislation seeks to enhance the UK’s cyber defences and bolster resilience across essential services, infrastructure, and digital offerings. It will revise current cyber security regulations, including the NIS Regulations, and broaden the scope of protected digital services and supply chains.

      The primary goal of this bill is to safeguard the UK’s digital economy, positioning it as one of the most secure in the world while protecting services, supply chains, and citizens. Additionally, it aims to enhance our cyber resilience and stimulate growth and prosperity. With an expanded scope, it encompasses a wider array of essential digital services beyond those currently covered by the NIS regulations and builds upon them. The bill includes mandatory reporting requirements and emphasises the UK’s Critical National Infrastructure (CNI).


      Ministerial Policy Statement


      You can read more about it here: https://www.gov.uk/government/publications/cyber-security-and-resilience-bill-policy-statement/cyber-security-and-resilience-bill-policy-statement.

      Relationship with EU Regulations


      Although the UK’s Cyber Security and Resilience Bill is tailored for the UK, it draws inspiration from the EU’s Cyber Resilience Act (CRA) and the NIS2 Directive. The CRA emphasises cybersecurity for products with digital elements, whereas the UK’s legislation focuses on fostering overall resilience within its digital ecosystem. Furthermore, it aims to align with principles found in the NIS2 Directive adopted by the EU in 2024.

      How will SMEs navigate this?

      In the cybersecurity sector, there has long been a divide between product vendors and those of us focused on services. After three decades in this industry, I’ve repeatedly observed that product sales often prevail. Why? Because selling services is more challenging with a longer sales cycle compared to quicker product sales. People prefer to see a quick if not immediate return, on their investment; they like tangible products doing their job even if they don’t fully grasp how they function or whether they’re suited for their needs.

      Risk Management

      A risk managed approach remains vital. This principle hasn’t changed over my 30 years in the field. However, this bill makes it even more critical due to potential penalties for non-compliance. The focus should be on People, Process, and then Technology. I often reference Bruce Schneier, a Harvard scientist and thought leader in cybersecurity. He states, “If you think technology can solve your security problems, then you don’t understand the problems and you don’t understand the technology.” Essentially, understanding your risks begins with identifying your cyber assets, not just hardware or software but your data and your ability to maintain system access for staff and customers when needed.

      Once you recognise your assets, you must identify potential threats to them and assess how vulnerable you are to those threats. Threats combined with vulnerabilities equal risk, the risk to your business if things go awry.

      Having completed this assessment you can assign a risk score to each asset aiming to manage that risk down to an acceptable level, known as risk appetite. This will vary from business to business or even asset to asset; for instance, you wouldn’t assign the same risk level to a revenue-generating system as you would to an admin-only system lacking personal data.

      This may sound daunting and costly; hence many businesses avoid it or only partially implement it. However, without a comprehensive assessment, it’s challenging to ensure that you are allocating your limited budget toward appropriate protections in key areas. You need to determine potential damage from failures and explore ways to mitigate that damage. While consulting a lawyer after a crisis is one option, wouldn’t it be wiser to prevent or reduce issues before they escalate?

      Social Engineering

      I frequently share insights on the significance of Cyber Awareness Training and its critical role in helping organisations defend against cybercrime. Cyber awareness training is a vital aspect of contemporary security strategies for everyone. It provides employees with the essential knowledge and skills needed to identify, respond to, and reduce cyber threats. This training is particularly effective in combating social engineering.

      While many people are now familiar with the term social engineering, they may not fully understand its meaning. In the context of cybersecurity, social engineering involves manipulating, influencing, or deceiving individuals to gain unauthorised access to IT systems or to steal personal and financial information. It employs psychological tricks to lead users into making security errors or divulging sensitive data. The most prevalent form of social engineering is phishing.

      Social engineering heavily relies on the six Principles of Influence identified by Robert Cialdini, a behavioral psychologist and author of “Influence: The Psychology of Persuasion.” These six principles are: Reciprocity, Commitment and Consistency, Social Proof, Authority, Liking, and Scarcity. Simply put, what these criminals seek is information, login credentials, passwords, names, phone numbers, and more. They are profiling your organisation to identify vulnerabilities, such as who manages accounts payable or whether you have an IT support company under contract that they could impersonate. In addition to phishing, they utilise various forms including vishing (voice phishing), smishing (SMS phishing), and simply calling to ask questions.

      A rising threat that criminals are increasingly adopting is help desk social engineering tactics. In these schemes, attackers call an organisation’s IT help desk while posing as a legitimate employee, trying to convince the help desk agent to reset passwords or multi-factor authentication (MFA) for a specific account.

      In recent years, this technique has been used to access single sign-on (SSO) accounts and cloud-based application suites. Multiple criminals adopted this approach in 2024, targeting academic and healthcare institutions; in these cases, attackers utilised compromised identities to extract data from cloud-based software as a service (SaaS) applications or alter employee payroll information.

      IT help desks typically require employees requesting password and MFA resets to provide their full name, date of birth, employee ID, and manager’s name or answer a pre-set security question. However, cybercriminals attempting to socially engineer help desk personnel often answer these questions accurately. Much of this information is not confidential and can be found in public resources and social media sites. The dark web frequently harbours data that should remain private. At H2, we continuously scan the dark web for our clients to uncover any exposed information.

      Often, help desk social engineering calls occur outside of regular working hours. This tactic allows criminals to maintain access to compromised accounts for longer periods before the legitimate account owner detects any suspicious activity. Attackers using this method may register their own devices for MFA to secure ongoing access to compromised accounts. They also frequently delete emails from compromised mailboxes related to suspicious account activities or configure mail transport rules to redirect relevant emails away from the main inbox.

      Over the past year, several criminals have openly sought callers on popular forums. Advertisements typically call for English-speaking individuals familiar with RMM tools and experienced in conducting remote sessions. Some criminals are also exploring effective ways to spoof phone numbers or encrypt calls, ensuring caller IDs appear more credible. This trend suggests that phone-related social engineering will pose a significant threat in 2025 as demand for these capabilities increases.

      So how can we combat this? I began with cyber awareness training, and I’ll conclude with it as well. When your staff, regardless of their technical expertise, understand what social engineering is and its intentions, they are much more likely to recognise it when it occurs. Simple practices such as asking unknown callers to call back using a verified number instead of one provided by the caller can make a difference. If you receive an email from a senior manager or board member that seems suspicious, open a new email thread for confirmation rather than replying directly, this helps avoid potential spoofing by scammers masquerading as legitimate sources. And of course, never click on links!

      Cyber awareness training doesn’t need to be costly; it can be delivered face-to-face, online, or through automated means. At H2, we offer all these options! Regardless of your choice, please consider this training an essential component of your strategy.

      Remote or Office?  The Debate Goes On

      Barely a week goes by without the remote working v office-based argument surfaces somewhere, usually it must be said, at the corporate level, although many SME owners remain nervous of it, with others downright against it.  My client base appears to be largely OK with a hybrid model of working and only one is 100% remote based, having given up their office.

      The COVID pandemic was the catalyst for this with businesses of all sizes being forced to transform their operations to support remote work and by and large have done well, but not without many challenges, including video conferencing burn out, (along with wishing they’d taken out shares in Zoom!!), and a yearning to work together in person again, someday.  We all realise that group working, face to face, is often necessary not just for efficiency, but because we are social animals.  Experience has taught many businesses many things but are often still struggling with the potentially dire consequences in terms of cyber security and data protection.

      I should perhaps mention that in the corporate IT world, where I worked for many years for major system integrators like HP, hot desking and remote working was introduced in the early 2000s and therefore this was no problem for us.

      A distributed work environment i.e., personnel spread around various locations, office, home working, even the local coffee shop, creates critical challenges and new security threats as a result.  The speed with which this has happened has meant that many simply did not take cyber security issues into account and if they did, thought, well, this is temporary, and it won’t matter in the long run.  Well perhaps, but as many are now finding, there have been advantages to home working, not least a lowering of costs in terms of how much office space is needed to carry out the business function.  Many are now looking at Hybrid working i.e., from home with a day or two in the office during the week.  There are pros and cons to this outside of the scope of this article, and businesses will have to make their own judgements, but one thing is clear and that is that businesses need to understand the risks now inherent in distributed work and need to get better at cyber security and data protection, in those environments.

      Employees when remote working, are at much greater risk than those in offices. Since home connections are less secure, cybercriminals have an easier entry into the company network.  Furthermore, the explosion of various online tools, solutions, and services for collaboration and productivity tend to have the bare minimum of security default setting, and updates from third-party vendors can change security preferences and be easily overlooked.

      Phishing becomes an even greater threat to home workers simply because, in an office environment, they have access to colleagues and managers, who they can approach for advice and guidance.  This is much harder to replicate with remote workers, especially those who may not be particularly tech savvy and who may not wish to become ‘burdensome’ to their co-workers.

      Ransomware also enjoys an advantage in the remote working model.  If their connection to the company is blocked, it is more difficult for workers to get assistance from the right experts and authorities.  And since trust levels are lower when working from home, some workers will be concerned that they have “done something wrong” and so may be more reluctant to seek help. While this risk can be addressed by increased training, as well as messaging that vigilance and involving IT support will be rewarded, it can still be an uphill battle.

      In a study carried out by Entrust it was clear that many organisations are grasping the concept of cyber awareness training, although there are still too few amongst SMEs that take this on board.  Of those who responded to Entrust:

      • 94% said employee training has a positive impact on data security.
      • 95% agreed that they trust remote employees to comply with data security best practices and training.
      • 93% said they felt positive about the impact data security training had on them.

      Of course, this was a sampling and only 61% of employees said that their company offered training.

      Whatever system of hybrid you are proposing to use, or are using, it is clear that you will need to go beyond baseline security measures.  In this case we are almost certainly dealing with baseline protections such as multi-factor authentication, known as MFA or sometimes 2FA, and virtual private networks (VPNs).  Both have their place and will be needed. 

      The Entrust report cites a contradiction here, and it’s one I have also noted.  Many company owners/directors say they believe company data is protected with these baseline solutions, yet they also say that home internet connections, leaked sensitive company information and cyber-attacks are their top concerns.

      If organisations are going to use hybrid work models successfully over the long term, then they will need to further invest in their security strategy. MFA and VPNs, while important, should be seen as part of a larger strategy for data security in a hybrid work model. Throughout and beyond the pandemic, bad actors have exploited security deficiencies of remote environments such as insecure home tech hardware, poor password hygiene and employee use of unapproved tools.


      If you are going to adopt this new normal, or already have adopted it, then the process must start with understanding your risk posture which will inform you of what measures you need to take to secure your data.  Below is a link to a short video explaining cyber risk management, at least at a high level.

      https://bit.ly/3FdZ6x0

      Once you have a clear understanding of what your risks are, then you might like to consider a zero-trust approach to data security.

      With employees having the ability to work anywhere in a hybrid environment, the office perimeter is no longer relevant to digital security.  Zero Trust frameworks are designed to apply the concept of least privileged access to people, systems and devices, giving these entities only the access they need to fulfil their role and nothing more. Additionally, a Zero Trust approach continually monitors user and device behaviour to identify suspicious patterns and take preventive action, including a step-up authentication challenge.

      You may need to consider other protections such as:

      • Passwordless single sign on involving Privileged Access Management (PAM) to facilitate a Zero Trust approach. 
      • Data Loss Prevention.  Whilst a VPN will protect your data in transit, file level encryption ensures that it is protected at rest, at both ends of the tunnel, so that if it does get stolen or otherwise compromised, the impact is severely lessened.  There is more information in the short video below.

      https://bit.ly/4berDPa

      • Protective Monitoring.  This has long been considered too expensive for an SME.  Well, no longer, there is now a system which is effective and affordable and is explained in the video below.

      https://bit.ly/3Qy4u0x

      If you feel a no obligation chat about this would be helpful, give us a call.

      Cyber Security Operations

      Security operations is a complex subject and there is no doubt that it can be expensive and difficult, even for corporate organisations who generally have the resource, both financial and technical, to run a security operations centre (SOC), or at least can afford to outsource.  I saw an RFP from a housing society for a SOC and I would be very interested to see if that contract gets let once the organisation gets the quotes, because I would be shocked if they could afford it.

      Their RFP based its premise on the introduction of a Security Information and Event Management system (SIEM), which.in itself, might suggest that they don’t really know what they are asking for, or indeed, what they want.  I base this on having designed, built and operated several such operations centres in the past.

      Now before the SIEM vendors and resellers pile on, let’s be clear, SIEM systems have their place and are very useful in a SOC, although I would argue that they are most certainly not the end all and be all.  My focus these days is on SMEs and for an SME there are several reasons why a SOC and an SIEM may be over the top and a cost too far.

      Whilst an SIEM system is a valuable tool for cybersecurity, it comes with several drawbacks, including:

      a. High Cost

      • Expensive Implementation – SIEM systems require significant upfront costs for software, hardware, and licensing.
      • Ongoing Costs – Maintenance, updates, and skilled personnel add to long-term expenses.

      b. Complex Deployment and Management

      • Difficult Configuration – Setting up a SIEM system to work effectively requires extensive tuning and integration with various security tools.
      • Frequent Fine-Tuning – To avoid false positives and negatives, organisations must continuously refine alert rules and correlation policies.

      c. High Volume of Alerts and False Positives

      • Alert Fatigue – SIEM systems generate numerous alerts, many of which are false positives, overwhelming security teams.
      • Difficult Prioritisation – It can be challenging to distinguish between critical threats and routine events without proper tuning.

      d. Scalability Issues

      • Performance Bottlenecks – As an organisation grows, more logs and data sources can slow down the system.
      • Expensive Scaling – Scaling a SIEM to handle increasing data volumes often requires costly upgrades.

      e. Need for Skilled Personnel

      • Expertise Required – SIEM systems need cybersecurity professionals to manage, analyse, and fine-tune them effectively.
      • Shortage of Talent – Finding skilled SIEM analysts can be challenging and expensive.

      f. Storage and Compliance Challenges

      • Log Retention Costs – Storing large volumes of logs for compliance can be expensive.
      • Regulatory Complexity – Ensuring compliance with data protection laws (e.g., GDPR) requires careful log management.

      h. Limited Threat Detection Without AI/Automation

      • Reactive Approach – Many traditional SIEMs rely on pre-set rules, making them less effective against new or sophisticated threats.
      • Lack of Automation – Without AI-driven analytics, manual investigation can be time-consuming.

      Having debunked the usefulness of an SIEM system for an SME, let’s look at what an SME could do to mitigate their cyber risks.

      A good cyber security strategy has always been founded upon strength in depth.  Sound security architecture, good cyber awareness training, solid access control and identity management, and the ability to protectively monitor your estate for threats, vulnerabilities, and risks. 

      If you are not monitoring the effectiveness of the protections that you have spent good money on, how do you know it’s money well spent?  Are those protections doing what you think they are?  Monitoring is central to the identification and detection of threats to your IT systems. It acts as your eyes and ears when detecting and recovering from security incidents and it enables you to ensure that devices are used in accordance with your organisational policies.

      Many small to medium-sized businesses struggle with stretched resources, lean budgets, and a critical technical expertise gap. This fight against sophisticated cyber threats and outdated systems turns them into easy targets for cybercriminals. Exposed and at risk, these businesses stagger on the edge of significant disruption, financial loss, and reputational damage.  Although on the surface an SIEM system might seem to be what an SME needs, it would not fit the profile of most SMEs, being too resource intensive and costly.

      We have been researching the market, looking for a way of providing a security managed service that would serve an SME, at an affordable price.  And we think we’ve found it – no, we are SURE we have found it.  Simplicity is at its core, employing enterprise-grade technology to simplify and streamline the day-to-day work. Our unified platform and onboarding process, seamlessly detects, prevents, and responds to cyber threats in the most holistic, hassle-free, and cost-effective way.

      We are offering a 14 day free trial and will cover:

      1. Email security.
      2. Cloud data.
      3. Automated cyber awareness training.
      4. External risk.
      5. Endpoint security.
      6. Secure browsing.
      7. Phishing simulation.
      8. And as an added bonus we can provide cyber insurance at a price which is directly linked to your risk score within or system.  The lower your risk, the cheaper the insurance.

      This system is deliberately aimed at 1-250 IT users in any business.  Most SMEs come in around 10 to 15 IT users, but we’re not precious about it.  It is a managed service, and we have our eyes on the glass and can mitigate your risks automatically, or in concert with you, depending on how you wish to tailor the service.  All this for a mere £12 per user per month.

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