Building an Information Security Program in a Bank – Part 3: The Essential Building Blocks

So now you know where you are. You have looked under the hood, poked around in the corners, and hopefully had at least one brutally honest conversation about your current risk environment. That is not easy. Most folks skip it because it is uncomfortable, messy, and often not flattering. But if you have done it-and done it honestly-then congratulations. You are already ahead of a lot of your peers.

Now the question becomes: what exactly are you building?

Let us talk about the essential building blocks of a real information security program. Not the kind that just sits on a shelf in a binder labeled “InfoSec,” but the kind that actually works. The kind your staff can live with, your regulators can respect, and your customers will never know exists-but benefit from every single day.

Seven Core Components – No More, No Less

Every effective information security program, whether it belongs to a $30 billion regional or a $300 million community bank, boils down to these seven core components. Miss one, and the whole thing starts to lean sideways.

1. Governance
2. Risk Assessment
3. Access Control
4. Vendor Management
5. Incident Response
6. Business Continuity
7. Cybersecurity

You can dress these up, break them down further, or map them to your favorite framework, but these are the seven areas every program has to cover.

Let me walk through each one briefly, and in future posts, we will drill deeper.

1. Governance: Who Is Driving the Bus?

If no one owns it, no one does it. I cannot tell you how many times I have walked into a bank and asked, “Who is responsible for information security here?” and gotten the most uncomfortable silence you can imagine. It is not always because no one cares. Sometimes it is because everyone cares-and therefore, no one owns it.

Governance means:

• Someone owns the program.
• Someone is accountable to leadership.
• There is a structure in place-committees, reporting, oversight.
• The board gets updates that make sense (not just alphabet soup and red/yellow/green charts).

If your program is a ship, governance is the captain and the navigation crew. Without them, you are just drifting.

2. Risk Assessment: Know Your Weak Spots

This was the focus of the last article, but I will say it again here for emphasis: do not skip it. Risk assessment is not about checking off boxes. It is about understanding what matters most in your environment-and what can go wrong.

If you want to spend your limited resources wisely, you need this map. Otherwise, you are just playing security whack-a-mole.

3. Access Control: Doors, Keys, and Common Sense

This is where most security programs get too technical and too rigid too fast. Access control is not just about passwords and two-factor authentication. It is about who has access to what, and why.

• Are former employees still in your system?
• Do tellers have access to wire systems?
• Are there dual controls on critical functions?
• Are you enforcing least privilege or just going with “whatever works”?

Access control is not about making people miserable-it is about limiting exposure when things go wrong.

4. Vendor Management: The Friends You Pay For

If you outsource a service, you do not outsource the risk. Your core provider, your internet vendor, your cloud backup company-if they touch your systems or your data, they are inside the tent. You cannot just assume they are doing it right.

You need:

• Contracts with clear security expectations
• Periodic due diligence (and yes, someone has to actually read those SOC reports)
• An inventory of vendors and what data they access

And for the love of all things secure, if a vendor says, “Trust us, we are certified,” ask them to prove it. Trust but verify. Reagan said it. Still holds up.

5. Incident Response: Plan for the Worst Day

Hope is not a strategy. Incidents will happen. The only question is whether you will be calm, collected, and effective-or in total chaos.

You need a plan:

• Who does what?
• When do you involve legal, insurance, or law enforcement?
• How do you notify customers or regulators?

And most importantly, test it. A plan that has never been exercised is just a bedtime story. It will not help you when you are up at 2 a.m. staring at a screen that says “ALL FILES ENCRYPTED.”

6. Business Continuity: Because Tornadoes and Hackers Do Not Care About Your Schedule

Can you operate your bank when things go sideways? Can you get your systems back online? Serve customers? Pay employees?

This is not just a disaster recovery question. It is about your entire operation:

• Can you reroute calls if your main office goes down?
• Do you have offline access to customer contact info?
• Have you thought through cash access in a widespread outage?

Remember: your customers will not care why you are down. They will just remember that you were.

7. Cybersecurity: The Buzzword That Gets the Spotlight

Let me be clear-cybersecurity is important. Firewalls, patching, endpoint protection, threat intel, all of it. But it is only one piece of the puzzle.

I have seen banks obsess over phishing simulations while ignoring the fact that the cleaning crew has the keys to the server room. A secure firewall means nothing if your admin password is still “Password123!”

Cyber is sexy, but comprehensive is safer.

Put It All Together – Then Grow It at Your Pace

Think of these seven blocks like a foundation. You do not have to build a castle overnight. Start small. Do it right. Then grow.

The key is balance:

• Do not let consultants turn your program into an unmanageable monster.
• Do not let complacency turn it into a paper tiger.

And always keep your goals front and center. This is about protecting your customers' trust. You do not need to be flashy. You just need to be real.

Coming Next: Defining Your Information Security Governance Structure

In the next post, we will dig into governance-what it looks like in a small bank, how to make it work even if you are wearing six hats, and how to get your board engaged without sending them running for the exits.

Until then, I will leave you with this: Build with purpose. Not because the examiner said so. Not because a vendor scared you. Build because you care about doing it right. That is where real security starts.

Let me know what you think. If you have stories to share-or traps you have run into along the way-I would love to hear them. We are all figuring this out together.

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