– Akber Datoo, Founding Partner, D2 Legal Technology
Damaged reputation. Financial loss. Punitive capital adequacy provision. Silent cyber is one of the biggest issues facing the insurance industry. Yet despite the Prudential Regulatory Authority’s (PRA) demands for robust action plans, few firms have put in place the document digitisation required to truly understand the level of risk. Further, it is somewhat ironic that an industry that is predicated on pricing risk, is failing to assess and understand this risk that exists today in its back catalogue. From determining the current silent cyber position to identifying policy wording changes and analysing the legacy book, Akber Datoo, Founding Partner, D2 Legal Technology, highlights the need to digitise policy documents.
Non Affirmative Loss
“Silent Cyber” is the term given to cyber related losses that may/or may not fall under a traditional property and liability policies that were not designed for that purpose.
The concerns of silent cyber have recently come to the fore and the shock waves created by the Mondelez / Zurich Insurance case have reverberated around the market. Whilst publicity may have temporarily abated over the past few months, very few insurance companies have begun to truly address the risk posed by silent cyber. In an industry predicated on strong reputation, the decision by Zurich to reject a claim from a client whose business had been devastated by the NotPetya cyber-attack in 2017 made headlines around the world – not least for citing exclusion for ‘hostile or warlike action in time of peace or war’ by a ’government or sovereign power’.
Yet as the cost of such attacks are being counted, the impact of silent cyber on the industry as a whole is becoming painfully apparent. PCS Global Cyber has recently attributed 90% of the insurance industry’s losses relating to the NotPetya cyber-attack to non-affirmative (silent) cyber, and the rest to affirmative losses.
Certainly, the PRA believes the UK insurance industry can do more to ensure the effective management of affirmative and non-affirmative cyber risk exposures. It has ordered firms to develop an action plan, with clear milestones and dates by which action will be taken.
Despite the cost to the industry, there remains a concerning lack of consistency in terms of risk awareness and planning as well as risk appetite and understanding. The PRA’s own survey in 2018 revealed significant divergence in firms’ views of the potential exposure to silent cyber. Within Marine, Aviation and Transport (MAT), Property and Miscellaneous lines, exposure was rated at anywhere between zero and the full limits.
With PCS Global Cyber believing the cost to the industry of NotPetya associated claims has now exceeded $3 billion, there is ever greater focus on insurance companies’ cyber stress tests. Fears that gross losses could run into the multiples of annual cyber premiums are very real. However, to date such exercises are based on minimal fact: firms lack robust or reliable claims data relating to silent cyber. As a result, models are immature and there is little faith in the resultant capital adequacy calculations. Just how much capital should the regulator demand firms to set aside against possible exposures when the silent cyber risk is so poorly understood?
In addition to the model and assessment demanded by the PRA, firms need to look closely at existing policy documentation to gain better insight into risk. What is the current position? Does wording need to be amended to address silent cyber risk? How can the legacy book be analysed and key data and wording from the contracts extracted to assess the potential silent cyber exposure going forward?
In many ways, the insurance industry is better placed than many for the challenges ahead. Document digitisation has been on the agenda for some time and the industry has already created clause libraries to make it easier for firms to gain access to vetted policy wordings and regularly used clauses. However, the low take-up of these libraries is disappointing. Not only do firms have a somewhat confusing choice – between the Lloyd’s Wording Repository, the IUA (International Underwriting Association) Clauses Document Library and the Xchanging Model Wordings Library, but the checklist structure is not providing the required solution.
Insurance companies and brokers need to better understand how to use these clause libraries within current business models, preferably in tandem with a document generation tool to improve data management. The goal is to create data driven contracts, where documents are drafted based on known outlooks. But to get to that point, firms need to actively embrace document digitisation to gain a better handle over the current risk position and create a foundation for rapidly changing wording to avoid any ambiguity regarding silent cyber. Moreover, we need the link wordings in clause libraries to classified business outcomes, and then derive business intelligence from policy portfolios.
No firm wants to risk the reputational damage associated with refusing a high profile claim – nor endure the huge losses associated with attacks such as NotPetya. With the rise in cyber attacks, this is an issue that has to be addressed immediately: firms need to act now and embrace the opportunity of digitisation strategies within policy documentation to mitigate the potentially devastating silent cyber risk.
HOW TO KEEP DIGITAL TRANSFORMATION ON TRACK AFTER THE PANDEMIC
Ashley Coker, CEO and founder, Slate
The global coronavirus health emergency has made it abundantly clear how dependent we are on digital services for business continuity and social cohesion. When physical contact must be minimised, digital businesses are in a better position to rapidly adapt and continue their services and respond to customers’ needs.
This is perhaps why Chancellor, Rishi Sunak, was prompted to delay the introduction of IR35 Off-Payroll working rules to the UK private sector until April 2021, as part of his package of measures to support British businesses through the COVID-19 crisis.
While some businesses expressed relief at the delayed introduction of IR35 rules in the private sector, many financial enterprises had already terminated contracts with IT contractors in preparation for the original deadline, with the risk of digital transformation programmes stalling.
What is IR35?
Inland Revenue legislation 35 (IR35) is a tax law designed to prevent individuals from using intermediaries, such as their own limited company, in order to avoid paying their fair share of tax and national insurance contributions (NICs). By setting up a limited company, some people were able to leave their employment in a bank on a Friday and return to the same job on a Monday as an IT contractor, with no change in their role, duties, or place of employment. HMRC wants to put a stop to this.
However, with an estimated 170,000 contractors working through their own personal service companies, HMRC has not had the resource to address cases individually and decided to put the onus on the organisations that hire contractors.
From April 2021, the responsibility for assessing whether a contractor is genuinely self-employed (outside of IR35) will fall on every medium and large private sector organisation with a turnover of over £10.2 million, a balance sheet of £5.1 million, and more than 50 employees. This means that every contract will have to be reassessed to decide whether an individual’s work falls inside or outside IR35. Contractors must be provided with a Status Determination Statement (SDS) for each contact that they undertake, confirming the organisation’s assessment of their status for IR35 purposes.
How has the financial sector prepared for IR35?
To avoid the time and resource required to scrutinise thousands of contractor contracts, many financial services organisations took a blanket decision which deems that all contractors are working inside IR35. Several prominent organisations have taken this route and terminated all contracts with contractors who bill for their services via limited companies.
Being deemed to be working inside IR35 has the effect of making hiring organisations liable for paying contractors’ income tax and National Insurance contributions at source, as though they were employees, without contractors benefiting from the sick pay and holiday pay benefits of the organisations’ employees. Tax experts have calculated that working inside IR35 will reduce contractors’ incomes by approximately 25 per cent. This makes projects less attractive to IT contractors who might be working on delivering digital change.
How does IR35 affect Digital Transformation?
Prior to the IR35 deadline extension, HSBC, Lloyds bank and Barclays bank were reported to have taken a uniform decision to classify all contractors as working within IR35. It was also reported that Deutsche Bank risked losing 50 out of 53 contractors working in its London-based change management team after taking the decision to cease working with contractors via personal service companies and asking them to join the payroll of a recruitment outsourcing agency used by the bank.
If IT contractors stop working with their financial service industry clients, to avoid falling foul of IR35 after April 2021, this could have a devastating impact on digital transformation projects that depend on the specialist skills of external contractors.
A number of contractors have reported that they plan to seek employment overseas after IR35 comes into force in the private sector, so that they can carry on enjoying the flexibility, job satisfaction and remuneration of working off-payroll. This could result in a brain drain for many sectors, such as banking, which relies heavily on the skills of external IT contractors to deliver digital transformation.
Fast track to digital delivery:
While IR35 could pose serious challenges for digital change programmes in the UK financial services sector after April 2021, some CIOs we have spoken to see the contract renewal phase as an opportunity to clear the decks, refocus and keep their best people on the pitch.
Our experience of providing corporates with highly-skilled software engineers who are born problem-solvers, who work in small, capped teams on a 5 in 50 model, has shown that they are often fundamental to getting stalled digital change programmes back on track. These developers work alongside enterprise IT teams, on a Seed, Scale, Succeed process, bringing fresh coding skills and transforming project thinking into product thinking, with continuous delivery of digital service iterations. They are technology specialists who relish the challenge of working on high profile digital journeys, but who do not wish to work as corporate employees and are therefore hard for financial services organisations to hire.
We now have another twelve months to prepare for IR35. In the meantime, as financial services organisations adapt to the demands of the pandemic, this is the time for small, agile teams of problem-solvers to shine.
IN CONSUMER BIOMETRICS WE TRUST: AUTHENTICATION FOR THE DATA PRIVACY AGE
Jonas Andersson, Head of Standardization at Fingerprints
Data privacy is high on the global agenda. In the wake of data protection policies such as Europe’s GDPR, ensuring the integrity of personal data is an increasingly pertinent subject. This is a governmental and corporate policy reflection of the fact that our lives are moving increasingly online and, with it, our personal data is facing new and increased threats.
For all access to private data or services, we must be authenticated – this is the basis of privacy in the online world. But as PINs and passwords are increasingly viewed as insufficient to tackle this new reality, the world is looking to stronger authentication solutions, such as biometrics.
When implemented in the right way, biometrics will bring multiple benefits. It already enabled consumers to add layers of authentication to personal data previously unsecured in their owned devices – from apps and e-commerce, to our homes and devices. But its potential is phenomenal. Consumer-driven authentication via our phones and tablets is already today by far the largest application of biometrics in the world, with figures in the billions that dwarf government-led identification schemes such as India’s Aadhaar and the FBI database.
Crucially though, it’s a privacy and security measure that consumers have the power and choice to implement. And as third parties, such as financial services, healthcare and enterprise organizations, increasingly accept consumer biometrics authentication for their services, supporting the market’s continued adoption is an important and timely topic. But first, as biometrics creates its own sensitive personal data, there are a few points to clarify and discuss…
Consumers need confidence!
Undeniably, the success of existing applications of consumer biometrics is based on the advantages they offer consumers. Just look at the penetration and use of fingerprint biometrics in smartphones. But the success of future adoption will be determined by how confident consumers continue to feel in new situations. We’re frequently reminded not to use the same password or PIN multiple times, so it’s only natural consumers are beginning to feel concerned of their biometrics integrity as they start to utilize their fingerprint on multiple devices and apps: their phone, tablet, card, USB dongle…
In fact, consumer device authentication utilizes a ‘privacy by design’ approach that inherently protects end-user biometric data with an on-device authentication approach – where biometric data is enrolled, stored and managed all on the same device. The following principles have been fundamental to biometrics’ privacy protection in mobile and are what will enable new benefits for consumers in other personal device-based scenarios:
Translating images to templates
It’s a common misconception that biometric data, such as fingerprints, are stored as images. And in turn, if this image is accessed, the corresponding fingerprint is permanently compromised and unable to be restored or used securely on other applications. You’ll have heard the argument about biometrics: “I can change my password any time, but I only have ten fingerprints; what happens if they’re all hacked?”
In fact, data from a biometric sensor is captured and stored as a template in binary code – or encrypted 0s and 1s. This mathematical representation makes hacking basically pointless as, even if fraudsters could access the template, they can’t do anything with it. Template code cannot be reverse engineered into the original fingerprint image, nor can it be linked to other services and, in turn, other personal data. Moreover, this template is unique to the device it is on, making it impossible to re-use between devices, even if the same fingerprint has been enrolled!
The consumer is in control
This neatly leads on to my next point regarding storage. In consumer authentication use cases, information remains solely on the unique consumer device on which the template was created, remaining physically in control of the user.
Our recent consumer research found 38% were unwilling to share their biometric data but, with this approach, no data needs to be shared with third parties or cloud-based databases as everything is stored, and the authentication process is contained, within a single personal device.
Layers of security
Layering defense mechanisms is standard best practice for a range of security implementations – biometrics is no different. In addition to the transformation of biometric data into an irreversible template, these templates are also later encrypted and further protected by hardware and software both at rest and during the matching process.
The most successful example of a biometrics use case, the smartphone, utilizes the highly secure software isolation of Trusted Execution Environment (TEE) technology for storage and matching of biometric templates on device. The hardware on which it runs is intrinsically secured through its high degree of integration, complexity, miniaturization and specialization.
This approach is also championed by new use cases such as biometric payment cards. Here, the Secure Element (SE) – the chip technology that secures the financial data in your bank card – is utilized to store, process and match biometric information within the confines of the card. This treats biometric templates with the same security as the PIN and other financial data that is stored on our payment cards.
Removing the weakest link
Nothing is ‘un-hackable’, this is the reality of security. With enough time, money and effort, it’s possible to get into anything. A safe, a bank vault. However, attackers take the path of least resistance, and often it’s the end-user that is the ‘weakest link’ in the security chain when it comes to social engineering attacks.
End-users are vulnerable to attacks, such as phishing, where they can be tricked into giving away information such as a PIN or password. With consumer biometrics, the user only presents their biometrics to their personal device and can’t give anything away. This also removes the risks generated by mistakes or complacency, such as creating a password that’s easily guessed.
More authentication = more protection
Biometric authentication can protect a whole host of other sensitive personal data, far more quickly, conveniently and securely than was ever possible with PINs or passwords.
Today however, passwords and PINs remain the most used authentication methods outside of smartphones – something increasingly problematic. The friction created by asking users to create a new password has a significant impact on drop-out rates – especially as new ‘best practice’ guidelines recommend complex requirements such as including numbers, capitals, special characters and length. NIST’s digital identity guidelines outline the importance of usability challenges and stress, fundamentally, “positive user authentication experiences are integral to the success of an organization achieving desired business outcomes.”
6 out of 10 consumers feel they have too many PINs and passwords and worry about forgetting them. Unsurprisingly, 41% also admit to re-using the same PIN code or password across multiple sites, apps and devices. So, not only are PINs and passwords frustrating for consumers, they’re also becoming less secure.
Biometrics can be the authentication silver bullet as it combines security and a convenient UX, with leading fingerprint sensors authenticating in under a second. Its capacity to bring security to devices and processes previously either unsecured, poorly secured, or secured with a poor UX is phenomenal. Mobile is the perfect example of how it has been able to transform a device from being unsecured most of the time, to now only unlocked when in use. And now, just look at how your bank accepts your fingerprint authentication on your phone for access to your account.
With consumer biometrics, its quick and effortless to enroll onto new services and subscriptions. Consumers are happy to authenticate more frequently, because it’s so simple and the action is so intuitive. Plus, you cannot forget your fingerprint…
Consumer biometrics: on the agenda
It’s clear that biometrics is key to many organizations’ plans for privacy and security, but don’t just take our word for it. Many industry and government initiatives are moving quickly.
Europe’s GDPR highlighted biometrics as ‘sensitive personal data’ which clearly needs to be protected in the right way. Meanwhile, the benefits and integrity of consumer device biometric authentication were also recognized by Europe’s financial services directive, PSD2, citing biometrics as a trusted factor under its strong customer authentication (SCA) mandates.
Looking to industry bodies, FIDO Alliance is gaining significant traction in formalizing the quality and security of personal authentication with biometrics. Its work is complementing rising initiatives such as Self Sovereign Identity (SSI) models, whereby individuals or organizations are endeavoring to have sole ownership of digital identities and control how this personal data is shared and used. With an owned, FIDO-certified biometrics-secured device, users can add another authentication layer over stored digital identifiers.
For several years, we’ve also participated in industry body GlobalPlatform’s work to verify and standardize the quality of security protection on TEE. The biometric API extension defines security protections specifically around biometrics and is highly referenced in mobile implementations, and increasingly in new devices such as key fobs and home security devices too. With the dawn of the biometric payment card, we’re also supporting GlobalPlatform to define an SE specification for biometric cards.
The combination of government and industry engagement is setting the scene for so much more to be achieved with consumer authentication using biometrics. Undoubtedly, biometrics’ role in an increasingly data-conscious world has only just begun to take shape, and excitingly, it’s consumers who have the power at their fingertips – quite literally!
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