On 17 September 2015, the Hedge Fund Standards Board (HFSB) published a memo on cyber-security for hedge fund managers.
The memo provides:
- A brief overview (in Appendix B) of existing high level cyber-risk management tools, guidance and certification standards that hedge fund managers (and others) can use to develop a tailored approach to cyber-security.
- A framework to identify a firm’s key digital assets, including client data, proprietary algorithms or strategies, trading book and ongoing ability to execute trades.
- A list of practical “quick win” cyber-security action items.
- An overview of cyber-security projects that can be undertaken to enhance a firm’s resilience, including the development of an incident response plan.
- Information on financial services regulators’ requirements, guidance and approaches in relation to cyber-security. Appendix A to the memo sets out an overview of regulatory resources for financial regulators in a number of key jurisdictions. This includes reference to relevant FCA rules and Principles and accompanying FCA materials, including a data security factsheet and one-minute guide.
- A set of recommendations to help firms develop their own cyber-security strategy.
The HFSB has added the memo to its “toolbox” materials, which are intended to complement its hedge fund standards.