It is also vital to:
- review and internalise regulator guidance relating to cyber security, such as the CBEST paper issued by the Bank of England in 2023 and the National Cyber Security Centre's cyber incident guide for chief executives;
- consider and implement board-level guidance relating to governance, such as the UK government’s draft cyber governance code of practice for boards;
- ensure effective defensive protection is in place should it ever be needed, including support from specialist legal counsel and appropriate liability insurance.
Clearly, the stakes are higher than ever when it comes to cyber security risk and how to manage it, and increasingly that applies to the individuals involved as well as to the entities they run.
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A&O Shearman is running a programme of events relating to its cyber security practice throughout October.
Ffion Flockhart is global head of cyber security and Steven Hadwin is counsel at A&O Shearman
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