July 22, 2023
1. Pre-Deal: Due Diligence
1.1 Cybersecurity Policies and Procedures
- Assess the maturity and comprehensiveness of the target’s cybersecurity policies and procedures.
- Determine if they are implemented consistently and if employees are aware and trained.
- Check if they have a dedicated team or individual responsible for cybersecurity.
1.2 Incident Response and History
- Review the target’s history of cybersecurity incidents and breaches.
- Evaluate their incident response plan, its effectiveness, and how it was applied in past incidents.
1.3 Regulatory Compliance and Litigation
- Confirm the target’s compliance with relevant cybersecurity regulations (e.g., GDPR, CCPA, HIPAA).
- Check for any past or ongoing litigation or fines related to cybersecurity.
1.4 Risk Assessment
- Review the target’s process for identifying and managing cybersecurity risks.
- Look for third-party or internal audits of the target’s cybersecurity posture.
1.5 Technology and Controls
- Evaluate the target’s IT infrastructure, including network architecture, use of cloud services, and security controls.
- Look for the use of encryption, firewalls, intrusion detection systems, and other security technologies.
1.6 Vendor Management
- Assess how the target manages cybersecurity with its vendors.
- Confirm if vendors comply with the target’s cybersecurity policies.
1.7 Cybersecurity Culture
- Gauge the organization’s culture towards cybersecurity.
- Is cybersecurity considered a priority? Is there a culture of awareness and training?
2. Post-Deal: Integration and Segregation
2.1 Integration Planning
- Develop a plan for integrating the target’s systems and data.
- Consider how to manage user accounts and access controls during the integration.
2.2 Security Architecture
- Assess how the combined security architecture will look post-deal.
- Consider whether the target’s systems require upgrades or enhancements to meet your security standards.
2.3 Data Migration
- Plan for secure migration of sensitive data.
- Use encryption and secure protocols during data transfer.
2.4 Access Management
- Review and revise access controls and privileges for both existing and new users.
- Implement the principle of least privilege and maintain an audit trail of access logs.
2.5 Continued Compliance
- Ensure continued compliance with all relevant regulations after the integration.
- Update privacy policies and notify users as necessary.
2.6 Segregation Planning
- If necessary, develop a plan for segregating certain systems or data.
- Ensure that segregation does not introduce vulnerabilities or compliance issues.
2.7 Ongoing Monitoring
- Set up ongoing monitoring of the combined systems for any security incidents.
- Regularly review and update the cybersecurity strategy and response plan.