Second Line Cyber Risk Review Program
Governance Control: Second Line Independent Review
1. Purpose
Define the second line of defence's program for independently reviewing and challenging the cyber risk assessments, control activities, and risk management practices conducted by the first line of defence.
2. Scope
This program covers all second-line independent review activities related to first-line cyber risk management, including risk assessments, control self-assessments, risk acceptance decisions, incident management, and compliance activities.
3. Program Content
3.1 Program Mandate and Independence
The [CUSTOMIZE: Cyber Risk Management / Enterprise Risk Management / Compliance] function, operating as the second line of defence, is mandated to provide independent oversight of first-line cyber risk management activities.
Second-line independence is maintained through: separate reporting lines from first-line operations, authority to access all relevant information and personnel, and the ability to report directly to [CUSTOMIZE: Executive Risk Committee / Board] without first-line filtering.
First-line management shall cooperate with second-line reviews and provide timely access to personnel, documentation, and systems as requested.
3.2 Review Scope and Coverage
The second line shall conduct the following types of reviews on a risk-based schedule:
| Review Type | Scope | Frequency | Output |
|---|---|---|---|
| Risk Assessment Quality Review | Assess completeness, accuracy, and methodology compliance of first-line risk assessments | [CUSTOMIZE: Quarterly] | Quality scorecard and findings report |
| Control Effectiveness Review | Independent testing of critical security controls to validate first-line self-assessments | [CUSTOMIZE: Semi-annually] | Control effectiveness report |
| Risk Acceptance Review | Review risk acceptance decisions for appropriate authority, completeness, and ongoing validity | [CUSTOMIZE: Quarterly] | Acceptance review report |
| Compliance Monitoring Review | Verify first-line compliance with policies, standards, and regulatory requirements | [CUSTOMIZE: Monthly/Quarterly] | Compliance status report |
| Incident Management Review | Assess quality of incident handling, root cause analysis, and lesson implementation | [CUSTOMIZE: After major incidents / Quarterly] | Incident review findings |
| Thematic Review | Deep-dive review of specific risk domains or emerging risk areas | [CUSTOMIZE: 2-3 per year] | Thematic review report |
3.3 Review Methodology
Reviews shall be conducted using a documented methodology that includes: review planning and scoping, information gathering and analysis, independent testing and validation, findings development and risk rating, and reporting and recommendations.
Findings shall be rated using the following severity levels: Critical (material control failure or regulatory breach requiring immediate action), High (significant gap requiring remediation within [CUSTOMIZE: 60 days]), Medium (improvement needed within [CUSTOMIZE: 120 days]), Low (best practice recommendation within [CUSTOMIZE: 180 days]).
All findings shall include: finding description, root cause analysis, risk implication, recommendation, and agreed remediation plan with owner and target date.
First-line management shall provide a formal response to all findings within [CUSTOMIZE: 15 business days] of report issuance.
3.4 Reporting
The second line shall report review results to [CUSTOMIZE: CISO / Executive Risk Committee] at least [CUSTOMIZE: quarterly], including: summary of reviews completed, key findings and themes, remediation status for open findings, and assessment of first-line risk management effectiveness.
An annual report on the overall effectiveness of first-line cyber risk management shall be presented to [CUSTOMIZE: Board Risk Committee / Board Audit Committee].
Critical findings shall be reported to [CUSTOMIZE: CISO / Executive Risk Committee] immediately upon identification, without waiting for the regular reporting cycle.
4. Compliance
Compliance with this program is mandatory for all personnel and functions within its scope. Compliance will be monitored through periodic audits, management review, and second line of defence oversight.
Exceptions to this program must be documented with a business justification, approved by [CUSTOMIZE: CISO/Executive Risk Committee], and reviewed at least annually.
5. Review and Revision
This program shall be reviewed at least annually by [CUSTOMIZE: CISO/Document Owner] and updated as necessary to reflect changes in the threat landscape, regulatory requirements, organizational structure, or risk appetite.
All revisions shall be documented with version number, date, author, and description of changes.
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