Cybersecurity is an overwhelming problem—so overwhelming that it seems impossible to address. From the legal and compliance perspective, the problem is compounded by a lack of clear regulatory rules or judicial precedent about what kinds of measures might be sufficient to mitigate the risk of liability for a data breach or other cybersecurity incident. One important step every business can take, however, is to implement a cyber-security compliance training program.
Training as a Component of Legal Compliance
The “gold standard” for managing cybersecurity risk is the NIST Cybersecurity Framework. See Framework for Improving Critical Infrastructure Cybersecurity, Version 1.0 (Feb. 12, 2014), available at https://www.nist.gov/sites/default/files/documents/cyberframework/cybersecurity-framework-021214.pdf. The NIST Framework identifies four “tiers” of cybersecurity compliance, with Tier 1 representing the lowest degree of compliance and Tier 4 the highest. A principal driver of how an organization can move up from Tier 1 through Tier 4 is organizational knowledge. In Tier 1, according to the Framework,
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