EU Cybersecurity Dashboard - A Path to a Secure European Cyberspace
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EU Cybersecurity Dashboard A Path to a Secure European Cyberspace BUSINESS SOFTWARE ALLIANCE A
EU Cybersecurity Dashboard A Path to a Secure European Cyberspace CONTENTS EXECUTIVE SUMMARY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Methodology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 KEY FINDINGS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Legal Foundations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Operational Entities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Public-Private Partnership . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Sector-Specific Cybersecurity Plans. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Education . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 EUROPEAN UNION CYBERSECURITY MATURITY DASHBOARD (2015). . . . . . . . . . . . . . . . . . . . . . . . . . 8 EUROPEAN UNION CYBERSECURITY COUNTRY SUMMARIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
EXECUTIVE SUMMARY The promise of today’s interconnected world is immeasurable. Technology has become integral to virtually every sector of the global economy, including banking, communications and the electrical grid. The benefits that stem from that promise, however, face very real threats. Attackers — in ever greater numbers and with Such policy and legal frameworks and appropriate increasing sophistication — see, in the growing implementation structures must be stable and clear, promise of our tech-connected world, opportunities but they need also to remain flexible. They must to steal or cause major disruption or destruction take into account and be able to adjust to the by exploiting vulnerabilities. Unfortunately, as evolving threat environment that is inherent in the technology’s benefits expand and evolve, so too will technology arena. the threats. Countering those threats and ensuring the resilience of our cyber-enabled systems will require The purpose of this report — the first-of-its-kind flexibility and an ability to evolve as well. BSA EU Cybersecurity Dashboard — is to provide government officials in each of the EU Member States For governments, protection from cyber-attacks — with an opportunity to evaluate their country’s policies as well as the ability to both mitigate the harms of against these metrics, as well as their European any such instances and to address all newly emerging neighbors. threats — can be found in the cybersecurity policies they adopt and execute. Three elements must be The most important takeaways of the report can be present: the proper legal and policy frameworks along summarised as follows: with the appropriate public input and the necessary Most EU Member States recognise that working infrastructure needed to implement those frameworks. toward cybersecurity and cyber resilience — Laws, rules, institutions and appropriate structure to with particular focus on the protection of critical facilitate cooperation with relevant stakeholders are infrastructure — should be an important national the key foundations that support countries, as well as priority. non-governmental actors in their effort to protect their Considerable discrepancies exist between systems and prevent, mitigate and respond to cyber- Member States’ cybersecurity policies, legal attacks. frameworks and operational capabilities, creating notable cybersecurity gaps across Europe. www.bsa.org 1
EU Cybersecurity Dashboard A Path to a Secure European Cyberspace In addition to this report, the detailed results of the research are available online — at www.bsa.org/EUcybersecurity. While 27 EU Member States have established communities, effectively sharing meaningful operational entities, such as computer emergency cybersecurity information and prioritising the response teams (CERTs), the mission and protection of critical infrastructures are key steps experience of those entities vary greatly. which will increase cybersecurity and cyber resilience of all EU Member States. One notable gap is the lack of systematic cooperation with non-governmental entities and In addition to this report, the detailed results of the public-private partnerships: a well-established research are available online — at www.bsa.org/ framework in place for such partnerships exists EUcybersecurity. in only five EU Member States. This leaves a large area untapped for effective, voluntary Just as cybersecurity is an ever-evolving field, this collaboration between governments and the report is also intended to be a living document. As private sector that owns and operates the majority national governments and decision makers update of commercial critical infrastructure services in their frameworks to address the remaining gaps, this Europe. website will be updated to show progress across the relevant areas. We invite you to review these Achieving a coherent approach and common results and contact BSA | The Software Alliance with baseline level of cybersecurity in the EU will information regarding any relevant changes. require a sustained effort. The Network and Information Security (NIS) Directive and its implementation presents an opportunity to focus on protecting Member States’ most critical METHODOLOGY services and assets. Doing so would enable the This study is based on an assessment of twenty NIS Directive to play a key role in closing Europe’s five criteria across five themes. (See results, cybersecurity gap. pages 8–9.) Each of the criteria are given a This year’s report, thus, highlights some fundamental “Yes”, “No”, “Partial”, or “Not Applicable” challenges as well as significant opportunities for status. There are no overall rankings or scores in improving cybersecurity across the EU. If EU Member this study. States can align their approach to cybersecurity and This analysis is the result of desk-based research bring their capabilities to a comparable, coherent on publicly available information, and did not baseline level, it will be a major step towards achieving involve direct interviews with national agencies. a true Digital Single Market in the EU. Where possible we have included links to further Cybersecurity and cyber resilience are often information and resources. These are available thought of as a funding challenge, but primarily on our homepage. it is a management one. Getting the right policy, The research period concluded on 1 January legal and operational frameworks in place, improving 2015 and general information in the report is collaboration with various relevant stakeholders’ correct up to that date. For detailed information on the methodology used, please visit our website www.bsa.org/ EUcybersecurity. 2 BSA | The Software Alliance
THE BUILDING BLOCKS OF A STRONG LEGAL CYBERSECURITY FRAMEWORK Construct Solid Legal Foundations Establish Operational Entities with Key Governments should enact and keep up-to-date a Responsibilities for Security comprehensive legal and policy framework, based on Governments should set up operational entities to a solid national cybersecurity strategy. This framework support the prevention of cybersecurity incidents and should be built upon the following key principles. to ensure response to them. A core component of this is the establishment of operational computer security, Risk-based and prioritised: Cyber-threats come in emergency and incident response teams. many shapes and magnitudes with varying degrees of severity. Establishing a hierarchy of priorities — based on an objective assessment of risk — with Engender Trust and Work in Partnership critical assets and/or critical sectors at the top is No country or government can address cybersecurity an effective starting point from which to ensure risk in isolation. Collaboration with non-governmental that cyber protections are focused on those areas entities as well as with international partners and allies where the potential for harm is greatest. is a crucial component of an effective approach to cybersecurity. Technology-neutral: A technology-neutral approach to cybersecurity protection is vital to Partnering with the private sector: Most ensure access to the most secure and effective infrastructure is owned by the private sector, solutions in the marketplace. Specific requirements making effective public-private cooperation or policies that mandate the use of certain essential. Cooperation also improves the technology only undermine security by restricting effectiveness of risk management by improving the evolving security controls and best practices and sharing of information, experience and perspective potentially creating single points of failure. of multiple sources. Particular efforts are needed to foster trust and avoid legal obstacles that may Practicable: Any strategy is only as effective as it is hinder it. adoptable by the largest possible group of critical assets and implementable across the broadest Global rather than isolated: Given that cyber range of critical actors. Overly burdensome threats are global, effective cybersecurity policies government supervision of private operators, or and strategies need to maintain an international disproportionately intrusive regulatory intervention outlook, building on joint efforts with partners and in their operational management of cybersecurity allies. They should also leverage international, risk would most often prove counterproductive, voluntary and market-driven standards in order diverting resources from effective and scalable to maximise pan-regional and global information protection to fragmented administrative sharing and protection. compliance. Flexible: Managing cyber risk is a cross-disciplinary Foster Education and Awareness About function and no one-size-fits-all approach exists. Cybersecurity Risk Each industry, system and business faces distinct challenges, and the range of actors must have People, process and technology are equally important flexibility to address their unique needs. to ensuring cybersecurity. Even the best technology will be ineffective if not used appropriately. Awareness Respectful of privacy and civil liberties: Security raising, education and training about clearly requirements should be duly balanced with the articulated cybersecurity priorities, principles, policies, need for protection of privacy and civil liberties. processes and programs are essential components of Ensuring that requirements and obligations are any cybersecurity strategy. proportionate, do not represent more intrusion in fundamental rights than what is strictly necessary, follow due process and are supported by adequate judicial oversight are all important considerations to address in any cybersecurity framework. www.bsa.org 3
EU Cybersecurity Dashboard A Path to a Secure European Cyberspace KEY FINDINGS Recent high-profile cybersecurity incidents have underlined the crucial importance of strengthening cyber resilience in general, as well as the protection of critical infrastructure from cyber threats, both in Europe and around the world. In order to achieve these goals, public and private stakeholders need to be equipped with the capacity to effectively prevent, mitigate and respond to cyber-attacks and incidents. With an increasing focus on improving cyber resilience A key component, and in many ways the in both the Member States and at the EU level, this foundation, of this framework is a national report — the first-of-its kind BSA EU Cybersecurity cybersecurity strategy, which is critical for managing Dashboard — provides a comprehensive overview of national level cyber risks and developing appropriate the state of the current cybersecurity frameworks and legislation to support those efforts. A strong capabilities. cybersecurity strategy should be a “living document,” developed and implemented in partnership with key As detailed below, the report examines five key areas public and private stakeholders. It should contain of each EU Member State’s cybersecurity policy clearly articulated principles and priorities that reflect environment: societal values, traditions and legal principles. Legal foundations for cybersecurity; In this regard, there is a need for further improvement Operational capabilities; within the EU. Only 19 of the 28 Member States have Public-private partnerships; more or less detailed and comprehensive cybersecurity Sector-specific cybersecurity plans; and strategies in place, while eight have not declared any such framework at all. Even in the case of those Education. countries with adopted cybersecurity strategies, the quality of these is variable, many remaining vague and high-level, lacking a clear implementation plan. LEGAL FOUNDATIONS Furthermore, most of these documents seem static. Policymakers have a key role to play in ensuring that Only a small number of countries have already revised both public and private entities are well equipped and improved their initial strategies and published an to face the cybersecurity challenges of an ever more updated one. Finally, only a minority of the Member connected world. They can achieve this not only by States have reinforced their cybersecurity strategy establishing appropriate legal and policy frameworks, with relevant legislative and policy instruments that but also through promoting cybersecurity awareness address security, information classification obligations and cooperation with the different actors involved in and critical information infrastructure protection working towards cyber resilience. requirements. 4 BSA | The Software Alliance
Policymakers have a key role to play in ensuring that both public and private entities are well equipped to face the cybersecurity challenges of an ever more connected world. Governments also should assess and establish Sharing cybersecurity relevant information is no clear priorities among the critical services and doubt an important aspect of an effective approach infrastructures that most need protection. Not to cyber resilience, as it serves the interest of both all assets, systems, networks, data and services are public and private stakeholders. This is because it equally essential. Accordingly, it is important that increases collective awareness and, thereby, enables decision makers assess the national infrastructure, every stakeholder to adapt their security posture to the based on objective criteria and subject to public evolution of the threat landscape. comment, and determine those that are providing critical services and functions, whose compromise, Effective information sharing, however, requires damage or destruction through a cybersecurity information protection, appropriate information incident could have national significance. classification requirements are therefore crucial. This is recognised by almost all EU Member States as most of The results of this study show that more than half of them have such classification requirements in place. the EU Member States have not yet gone through this evaluation process in order to pursue a strategy or Governments also should facilitate information plan to protect their most important assets. sharing by supporting the creation of public-private partnerships and sector-specific collaboration (see Once these critical infrastructures are identified, below), as well as by providing the necessary human their cyber resilience needs to be evaluated in order and technical resources, operational entities and the to identify and address vulnerabilities and gaps. appropriate legal protections against anti-trust claims, undue disclosure requirements or liabilities, and Best practices developed in the private sector often identify and address any other policy and legal barriers include systematic internal and third party audits that may inhibit information sharing. to test the cyber resilience of critical systems. This approach is equally valuable for the public sector, yet the study has shown that most EU Member States and public bodies do not follow such best practices. OPERATIONAL ENTITIES Incident-response capabilities should be established Finally, as discussions around mandatory cyber to manage the most critical and significant events that incident reporting intensify, it is important to note that threaten the confidentiality, integrity or availability most European countries seem to remain reluctant of nationally significant information networks and to introduce such schemes, many of them favoring systems. Computer emergency response teams formal or informal cooperation with the private (CERTs) and computer security incident response sector. Many fear that a mandatory requirement teams (CSIRTs) can play a crucial role in improving to notify incidents may be less effective than the cyber resilience. exchange of information based on mutual trust and ongoing collaboration. These bodies can provide incident response services to victims of attacks; share information concerning Indeed, if a notification regime should be introduced, vulnerabilities and threats with key stakeholders in the most Member States recognise the importance that government, private sector and in some instances with only incidents having a significant impact or causing the broader public; and offer other ways of helping to a serious risk of harm should be captured by the improve computer and network security. obligation. www.bsa.org 5
EU Cybersecurity Dashboard A Path to a Secure European Cyberspace Effective partnership between public and private sectors is all the more important because non-government entities manage and operate many critical infrastructures that we rely on every day, including those that control transportation, health, banking and energy. Given this important role, it is a positive development guidance that is tailored to the business needs of that most EU Member States have operational CERTs, particular entities or provides methods to address with only Cyprus and Ireland yet to make their CERTs unique risks or specific operations in certain sectors. fully operational. Moreover, while there is a growing interest in Most of the countries also have established establishing sector-specific responses to cybersecurity, competent national authorities for network and practical implementation is still fairly limited in the information security. Member States. The same countries that are leading the way in public-private partnerships also are the leaders in this field, often establishing sector-specific PUBLIC-PRIVATE PARTNERSHIP dialogues and information exchanges with the private sector. Such steps can help promote the most suitable The culture of cybersecurity requires collaborative and effective guidance throughout individual sectors. efforts and coordination among all national stakeholders. Effective partnership between public and private sectors is all the more important because EDUCATION non-government entities manage and operate many critical infrastructures that we rely on every day, No single entity or group of stakeholders can including those that control transportation, health, secure cyberspace alone — and no individual or banking and energy. group is without responsibility for playing a part in cybersecurity. As not only governments, but While the importance of cooperation is recognised organisations of all sizes, as well as consumers, need to in Europe, there is a wide diversity in national take steps to secure their own systems, education and approaches and maturity levels on this issue. Five awareness raising play a crucial role. countries — Austria, Germany, the Netherlands, Spain and the United Kingdom — are leading the way by This requires educational and awareness-raising having established formal public-private partnerships campaigns as well as support for the development and for cybersecurity. generalisation of cybersecurity training in universities and in earlier curricula. On the other hand, public-private partnerships for cybersecurity are either non-existent, very restricted, The European Union has expressed a strong or still at a very early stage of development in the commitment to cybersecurity education and majority of the Member States. awareness raising and is acting upon this commitment. For instance, the European Cyber Security Month takes place every October all over SECTOR-SPECIFIC CYBERSECURITY Europe, with most EU countries participating. PLANS On the other hand, a small number of countries, including Greece, Malta, Portugal and Slovenia While certain elements of cybersecurity protection have yet to implement national education strategies apply across all areas, and a wide variety of in this field. recommendations are available from national and international organisations, there is also a need for 6 BSA | The Software Alliance
STUMBLING BLOCKS IN THE PATH TO TRUE SECURITY Some governments today are invoking cybersecurity Avoid Data Localization Rules as a justification for a variety of policies that go With the rise of global cloud computing services, beyond what is needed to address legitimate security companies of all sizes around the world can leverage concerns. In fact, such policies often undermine powerful resources that were once available only to the cybersecurity rather than improve it. They also impose largest firms. The cloud model, though, is based on unfair market access barriers on global producers and networks that allow the storage and processing of data service providers, whether intended or not. in multiple locations and even in multiple countries. By allowing data to flow freely among multiple markets, Avoid Unnecessary or Unreasonable cloud providers can deliver numerous advantages, Requirements including reliability, resiliency, and 24-hour service support. A proper cybersecurity policy enables organisations to develop and adopt the widest possible choice of Based on the mistaken assumption that data is safer in cutting-edge cybersecurity solutions. It also allows a specific location, some countries are imposing rules entities to implement the security measures that are that prohibit or significantly impede data transfers most effective at mitigating the specific risks they face. across borders. Policies that unnecessarily restrict the free flow of data undermine the very benefits of cloud Some governments instead impose various computing by increasing costs and threatening to requirements that restrict choice, increase costs prevent access to emerging cloud-enabled services. and reduce the ability of their own firms to use the most appropriate cybersecurity tools available. These include, but are not limited to, country unique Avoid Preferences for Indigenous Technologies certification conditions or local testing requirements; Cutting-edge products and services are developed mandates for local content; requirements to disclose through global collaboration in research and design sensitive information, such as source codes and centers in many different countries. Countries should encryption keys; and, restrictions on foreign ownership create incentives for cross-border collaboration to of intellectual property. facilitate voluntary technology transfer and the rapid development and deployment of enhanced products Refrain from Manipulating Standards and services. Technology standards play a vital role in enabling and However, some countries take the opposite approach, enhancing cybersecurity. By supporting internationally assuming that by preventing foreign competition recognised technical standards that are developed they can protect domestic champions, develop with industry participation and accepted across an indigenous technology industry, and enhance markets, companies can more quickly develop and cybersecurity. By definition, indigenous technologies distribute newer and more secure products. are a subset of global innovation. Preventing foreign competition reduces cybersecurity by denying firms Even so, some governments have imposed and agencies from buying world-class products country-specific standards with the argument that and services. Furthermore, such policies deprive requiring market-specific rules will lead to improved domestic technology firms of valuable opportunities cybersecurity. The real effect, however, is the opposite. to collaborate with global leaders and make them less Government-imposed standards, rather than competitive internationally, harming global innovation. bolstering security, tend to freeze innovation and force consumers and businesses into using products that might not suit their needs. www.bsa.org 7
EU Cybersecurity Dashboard A Path to a Secure European Cyberspace EUROPEAN UNION CYBERSECURITY MATURITY DASHBOARD (2015) Czech Republic 4 Yes 6 No Partial Denmark Bulgaria Belgium Estonia Finland Croatia Austria Cyprus France # QUESTION LEGAL FOUNDATIONS 1. Is there a national cybersecurity strategy in place? 4 4 6 6 4 4 6 4 4 4 2. What year was the national cybersecurity strategy adopted? 2013 2012 – – 2013 2011 – 2014 2013 2011 3. Is there a critical infrastructure protection (CIP) strategy or plan in place? 4 6 6 4 6 4 4 6 4. Is there legislation/policy that requires the establishment of a written information security plan? 6 6 6 6 6 4 4 6 5. Is there legislation/policy that requires an inventory of “systems” and the classification of data? 4 4 4 4 4 4 4 4 4 6. Is there legislation/policy that requires security practices/ requirements to be mapped to risk levels? 4 4 4 4 6 4 4 4 4 4 7. Is there legislation/policy that requires (at least) an annual cybersecurity audit? 4 6 6 6 6 6 4 4 6 8. Is there legislation/policy that requires a public report on cybersecurity capacity for the government? 6 6 6 4 6 4 4 6 9. Is there legislation/policy that requires each agency to have a chief information officer (CIO) or chief security officer (CSO)? 6 6 6 6 6 6 6 6 6 4 10. Is there legislation/policy that requires mandatory reporting of cybersecurity incidents? 6 6 6 4 4 6 4 6 6 11. Does legislation/policy include an appropriate definition for "critical infrastructure protection" (CIP)? 4 4 4 6 6 4 4 4 4 6 12. Are requirements for public and private procurement of cybersecurity solutions based on international accreditation or 4 N/A N/A N/A 4 4 4 certification schemes, without additional local requirements? OPERATIONAL ENTITIES 1. Is there a national computer emergency response team (CERT) or computer security incident response team (CSIRT)? 4 4 4 4 6 4 4 4 4 4 2. What year was the computer emergency response team (CERT) 2008 2008 2008 2009 – 2011 2009 2008 2014 2008 established? 3. Is there a national competent authority for network and information security (NIS)? 4 4 4 4 4 4 4 4 4. Is there an incident reporting platform for collecting cybersecurity incident data? 4 4 4 4 6 4 4 4 4 4 5. Are national cybersecurity exercises conducted? 4 4 4 4 4 4 4 6. Is there a national incident management structure (NIMS) for responding to cybersecurity incidents? 4 6 6 6 4 6 6 PUBLIC PRIVATE PARTNERSHIPS 1. Is there a defined public private partnership (PPP) for cybersecurity? 4 6 6 6 2. Is industry organised (i.e. business or industry cybersecurity councils)? 4 4 6 6 6 4 4 6 3. Are new public private partnerships in planning or underway (if so, which focus area)? 4 – 6 6 6 6 6 6 SECTOR SPECIFIC CYBERSECURITY PLANS 1. Is there a joint public private sector plan that addresses cybersecurity? 4 6 6 6 6 6 4 2. Have sector specific security priorities been defined? 6 6 6 6 6 6 6 6 6 6 3. Have any sector cybersecurity risk assessments been conducted? 6 6 6 6 6 4 6 6 6 6 EDUCATION 1. Is there an education strategy to enhance cybersecurity knowledge and increase cybersecurity awareness of the public 4 6 6 4 6 4 4 4 from a young age? 8 BSA | The Software Alliance
United Kingdom Luxembourg Netherlands Germany Lithuania Romania Portugal Hungary Slovenia Slovakia Sweden Greece Ireland Poland Latvia Malta Spain Italy 4 6 4 6 4 4 4 4 6 4 4 Draft 4 4 6 4 6 4 2011 – 2013 – 2014 2014 2011 2013 – 2013 2013 – 2013 2008 – 2013 – 2011 4 4 6 4 6 6 4 4 6 4 4 4 4 4 4 6 4 6 6 6 6 6 6 6 6 6 6 4 4 4 4 6 4 4 4 4 4 4 4 4 4 4 4 4 4 6 4 6 4 4 4 6 6 4 4 4 4 4 4 4 4 4 Draft 6 6 6 6 4 6 6 6 6 6 Draft 6 4 6 4 6 6 6 4 6 6 6 6 6 6 6 6 6 6 4 6 6 6 6 6 6 6 6 6 6 4 6 4 6 6 6 6 4 4 6 4 6 4 6 6 4 6 6 6 4 4 4 6 4 4 4 4 4 4 4 6 4 4 4 4 4 4 4 4 4 N/A 4 N/A 4 N/A 6 N/A 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 2012 2009 2013 – 2014 2006 2006 2011 2002 2012 2008 2008 2011 2009 2010 2008 2003 2014 4 4 4 6 4 4 4 4 4 4 4 4 4 4 4 4 4 4 6 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 4 6 6 4 6 4 4 6 4 4 6 6 4 4 4 6 6 6 6 6 4 6 6 6 6 4 4 4 6 4 6 6 6 4 6 4 4 4 6 6 6 6 – 6 6 4 6 6 – 6 – 6 6 6 6 6 6 6 6 4 6 6 6 6 6 4 6 4 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 6 4 4 4 4 4 6 4 4 6 4 4 6 4 6 4 www.bsa.org 9
EU Cybersecurity Dashboard A Path to a Secure European Cyberspace ESTABLISHING AN APPROPRIATE FRAMEWORK FOR MEANINGFUL INFORMATION SHARING Cybersecurity incidents or breaches can have a Ensure a high level of confidentiality: Given major impact on governments, private entities, the sensitive nature of the information shared as well as individuals. Some high-profile breaches about an incident or cyber threat affecting any have encouraged governments around the world to critical infrastructure, it is crucial to ensure that consider how to best prevent, detect and react to confidentiality and security of the communications these incidents. between the infrastructure operator and any supervisory authorities are respected and The exchange and sharing of the appropriate maintained, subject to transparent reporting by information at the right time — and the coordinated the authority, as appropriate. effort among relevant actors it enables — is considered the best way to reduce and mitigate Nevertheless, in some cases, informing the public risks and respond to cyber incidents. of an incident may be necessary. In these instances all care should be taken to ensure an in-depth Accordingly, the key question is how to best achieve dialogue between the entities suffering a breach meaningful and effective information sharing among and the authorities before any disclosure in order relevant stakeholders. While some countries have to avoid increasing the attack surface, multiplying considered mandatory incident notification systems, the impact of the incident, creating panic, or these alone would not suffice to address the issue leading to undue public shaming. of collective awareness and preparedness. When it comes to that, voluntary information exchanges based Ensure reciprocity: While the private sector on trust have proved to be the most efficient way to owns and operates much of the countries’ critical achieve successful information sharing. infrastructure, information sharing should not be seen as a one-way provision of relevant data from Such meaningful information sharing is not an easy private to public entities. It should be regarded as undertaking. It can only be achieved if the necessary a real and mutual exchange of information, based environment facilitating such exchanges is in place. on trust and mutual benefits. Some of the fundamentals of such an environment are the following: Make requirements clear and consistent across jurisdictions: As mandatory notification Create an environment of trust: Information requirements cover an ever-increasing number of sharing, as well as incident reporting, require areas and geographies, the likelihood of facing safeguards and incentives for their effective conflicting legal obligations increases. As various functioning. These elements help ensure the trust organisations operate in multiple sectors across necessary for the operation of such a system. They different countries and regions, the questions of include guarantees that the sharing of information what to report when and to whom already pose will not subject the organisation providing these important compliance challenges. Therefore, to to undue liabilities, public humiliation, litigation or the extent a mandatory notification system should sanctions. be introduced, it is imperative to strive for as much consistency as possible not only among the different notification obligations, but also among the various national and regional requirements. 10 BSA | The Software Alliance
EUROPEAN UNION CYBERSECURITY COUNTRY SUMMARIES The following summaries give an overview of the cybersecurity landscape, based on the set of criteria outlined above, highlighting key cybersecurity legislation and policy, as well as the main entities currently operating within each jurisdiction. For more detailed information on each country surveyed, please refer to the detailed Member State summaries available at www.bsa.org/EUcybersecurity. Finland Finland Sweden Estonia Latvia Ireland United Denmark Lithuania AUSTRIA Sweden EstoniaBELGIUM Kingdom Latvia Netherlands Denmark The Austrian Cyber Security Belgium’s Cyber Security Poland Lithuania Germany Ireland United Belgium Kingdom Luxembourg Czech Strategy was adopted in Strategy was adopted by the Republic Netherlands Slovakia Poland Germany France Hungary 2013. It is part of a broader government in 2012. The legal Luxembourg Czech Slovenia Romania Republic Slovakia Croatia Austria ICT security initiative of the framework for cybersecurity France Hungary Monaco Bulgaria ortugal Slovenia Romania Italy Spain Croatia Austrian government, asGreece Portugal in Belgium, however, remains Monaco Italy Bulgaria set out in the National ICT somewhat unclear, and the Spain Cyprus Security Strategy 2012. The Strategy is an extensive information available on the implementation of the Malta Greece Cyprus plan that maps targeted cybersecurity objectives into strategy is limited. Malta organised fields of action. On the other hand, Belgium does have an established Austria has an established computer emergency computer emergency response team, CERT.be, and response team, CERT.at, with a broad and well- a well-developed cybersecurity incident-reporting defined scope. There are also several public-private structure. Belgium also recently announced the launch partnerships related to cybersecurity operating in the of a new Cybersecurity Centre. There is active support country, such as the Centre for Secure Information in the country for public-private partnerships, through Finland Technology Austria (A-SIT) and Kuratorium Sicheres BeINIS, a government body that liaises closely with Österreich. private and semi-private entities. Sweden Estonia Latvia Denmark Lithuania The Austrian Trust Circles provide formal structures for Ireland United Kingdom BULGARIA Netherlands sector-specific information exchanges related to the Poland Belgium Germany Luxembourg Czech critical information infrastructure of various sectors. Republic Slovakia France Austria Hungary The legal framework for These platforms are tasked with developing sector- Slovenia Romania cybersecurity in Bulgaria Croatia specific risk management plans. The Austrian Trust Monaco is limited, and there is Portugal Italy Spain Circles are an initiative of CERT.at and the Austrian Greece no national cybersecurity Federal Chancellery. Cyprus Malta strategy in place. There are also no formalised public- www.bsa.org 11
EU Cybersecurity Dashboard A Path to a Secure European Cyberspace private partnerships, although a significant number includes comprehensive provisions on most aspects of cybersecurity events and academic discussions of cybersecurity and is complemented by several are focused on cybersecurity and critical information important regulations. infrastructure protection. The country has also established a national CERT, CERT Bulgaria is the country’s most significant CSIRT.CZ, as well as a CERT dedicated to government cybersecurity entity and the focus of recent efforts agencies: GOVCERT.CZ. from the government to strengthen cybersecurity. Sweden Estonia The National Cyber Security Centre was launched on 1 January 2015 to promote public-private partnerships. Latvia Denmark Lithuania Ireland United Kingdom Netherlands CROATIA Furthermore, the Czech Republic is conducting a Poland Belgium Luxembourg Germany Czech sector-based security risk assessment in cooperation Croatia has yet to establish a Republic with the academic and private sectors. The project is Slovakia Austria France Hungary Slovenia Romania comprehensive cybersecurity the first such assessment that addresses cybersecurity. al Spain Monaco Italy Bulgaria strategy or a well-developed system of public-private Greece partnerships. Cyprus Finland DENMARK Malta Croatia has two established Denmark does not have a Sweden Estonia national cybersecurity strategy Latvia computer emergency response teams (CERTs). The Ireland United Lithuania National CERT, established in 2009 is responsible for Kingdom or a law dedicated to the Netherlands Poland coordinating security and incident response measures Belgium Luxembourg subject. Denmark recently Germany Czech Republic passed a law that establishes Slovakia for parties that use a Croatian IP address or .hr France Austria Hungary domain. The Information Systems Security Bureau’s the Centre for Cyber Security, Slovenia Croatia Romania which both takes control of and supersedes its current Finland Monaco Bulgaria ZSIS CERT has jurisdiction over Croatian government Portugal Italy Spain institutions. Sweden Estonia government CERT. The scope and powers of the new Greece Denmark Latvia centre are still to be confirmed. Cyprus Lithuania Malta United ngdom Netherlands Germany Poland CYPRUS The Danish private sector has established a formal Belgium Luxembourg Czech Republic Slovakia framework for cooperation on cybersecurity issues France Austria Hungary Cyprus adopted a national Romania through the Council for Digital Security. Slovenia Monaco Croatia cybersecurity strategy in 2013. Bulgaria Italy It includes a commitment to update key elements Greece ESTONIA Malta of the legal framework for Finland Estonia was one of the first cybersecurity. Cyprus also is Sweden countries to develop a national working toward the establishment of a national CERT, cybersecurity strategy in 2008, Latvia Denmark which is expected to be operational in 2015. The Ireland United Kingdom Lithuania followed by the release of country has also taken an interest in sector-specific Netherlands Belgium Germany Poland an updated strategy in 2014. approaches to the management of cybersecurity, with Luxembourg Czech The country also has a wide Republic Slovakia Austria a potential focus on the energy and financial services France Hungary range of legislation that covers information security Slovenia Romania Croatia sectors. and cybersecurity. Estonia has a well-established CERT, Monaco Bulgaria Finland Portugal Italy Spain CERT Estonia, under the control of the Information Greece Sweden Estonia CZECH REPUBLIC System Authority. Further to national bodies, also Cyprus Latvia notable is the fact that NATO’s Cyber Security Centre Malta Denmark Lithuania Ireland The Cyber Security Strategy United Kingdom Netherlands Poland of Excellence is based in Estonia. Belgium Luxembourg of the Czech Republic for Germany the period 2011-2015 was Austria Slovakia While no formalised public-private partnerships exist, France public entities do work closely with relevant private- Hungary published in 2011. The Slovenia Croatia Romania ugal Monaco strategy provides general Italy Bulgaria sector organisations. Spain cybersecurity principles Greece and clearly stated goals. On 1 January 2015, the Cyprus Malta Act on Cyber Security came into force. This law 12 BSA | The Software Alliance
FINLAND Furthermore, the country has well-developed public- private partnerships, such as the Alliance for Cyber- Finland published a Security and the UP KRITIS partnership, and its Finland comprehensive cybersecurity national policies and legal framework reflect this focus strategy. It is complemented Sweden on cooperation. Estonia Sweden by a strong overall legal Estonia Latvia Denmark Latvia Lithuania Ireland framework encompassing Denmark United Lithuania Kingdom eland United Netherlands Kingdom Netherlands a range of important Poland Belgium Germany Poland GREECE Germany Luxembourg Czech Belgium Republic cybersecurity issues. The national authority responsible Luxembourg Czech Slovakia Greece does not have a Republic Austria Slovakia France Hungary France for cybersecurity in Finland is in transition, involving Austria Hungary Slovenia Croatia Romania Slovenia Romania cybersecurity strategy or the amalgamation of two government CERTs and the Croatia Monaco Bulgaria Portugal dedicated cybersecurity Italy Monaco Spain Bulgaria Spain creation of the Cyber Security Centre. Italy Finland Greece legislation. The legal and Cyprus Sweden Cyprus Estonia Malta institutional framework that FRANCE supports cybersecurity is also Malta Latvia Denmark Lithuania Ireland limited. The national computer emergency response United Kingdom France has had a national Netherlands Poland Belgium Germany team, NCERT-GR, is limited to government institutions cybersecurity strategy in Luxembourg Czech Republic Austria Slovakia and operators of critical infrastructure. place since 2011, although Hungary Slovenia Romania Croatia Portugal it has a strong focus on Monaco Bulgaria There are no significant public-private partnerships in Italy Greece, and the government is not actively pursuing Spain defence and national security their establishment or closer cooperation with the Greece issues. The National Agency Cyprus Finland for the Security of Information Systems (ANSSI) is a Malta private sector. well-established authority dedicated to information Sweden Estonia security and is integrated with the country’s Latvia HUNGARY Denmark Lithuania Ireland United computer emergency response team, CERT-FR. The Kingdom Netherlands Poland cybersecurity strategy contains recommendations for Belgium Luxembourg Germany The National Cyber Security Czech Republic closer cooperation with the private sector, but this has Slovakia France Strategy of Hungary was Austria not been significantly developed. ANSSI has published Slovenia Romania adopted in 2013. The strategy Croatia sector-specific security measures, making France one Monaco covers key principles of Bulgaria Portugal Italy Spain of the few EU countries to adopt such a targeted cybersecurity, an overview Greece approach to managing cybersecurity. of Hungary’s current Cyprus Finland Malta cybersecurity situation, and its future cybersecurity Sweden goals. Hungary has a limited legislative framework GERMANY Estonia dedicated to cybersecurity. Latvia Denmark Lithuania Ireland United Kingdom Germany has a comprehensive Several public authorities play a role in cybersecurity, Netherlands Poland cybersecurity strategy, Belgium including the National Security Authority, which Luxembourg Czech Republic adopted in 2011 and Slovakia Austria deals with information security, and the Cyber France Hungary complemented by a strong Slovenia Romania Croatia Security Centre, part of the intelligence services, cybersecurity legal framework. Monaco Bulgaria Portugal Italy which deals with cybersecurity. Hungary also has a Spain The existence of the Federal computer emergency response team, CERT-Hungary, Greece Office for Information Security (BSI), in charge of Cyprus Malta but its remit is limited to government institutions. managing computer and communication security for Furthermore, while the National Cyber Security Centre the German government, is a clear demonstration that is tasked with liaising with the private sector, there are cybersecurity is elevated to a high government level. no formalised public-private partnerships. Germany also has a network of CERTs, with the national CERT, CERT-BUND, working closely with both state-level and non-governmental CERTs. www.bsa.org 13
EU Cybersecurity Dashboard A Path to a Secure European Cyberspace IRELAND Finland While the cybersecurity strategy provides for Sweden Estonia the establishment of formalised public-private Ireland’s national legal and Latvia partnerships for cybersecurity, no such platforms policy framework is very Denmark Lithuania United Kingdom yet exist. limited when it comes to Netherlands Germany Poland Belgium cybersecurity. A cybersecurity Luxembourg Czech Republic Slovakia strategy is being developed, France Austria Hungary Romania Finland LITHUANIA Slovenia but there is no clear timeframe Croatia Portugal Monaco Bulgaria Sweden Lithuania published a for its release or adoption. Ireland is also one of Italy Estonia Spain comprehensive cybersecurity Latvia the few countries in the European Union without an Greece Denmark strategy in 2011, however Ireland United Cyprus Kingdom operational CERT, although it is in the process of Netherlands information on its Malta Poland Belgium Germany establishing one. Luxembourg Czech Austria implementation remains Republic Slovakia France Hungary While there is no formalised public-private partnership Slovenia limited. The Lithuanian Croatia Romania set up for cybersecurity, Irish private sector entities, Portugal computer emergency response team, CERT-LT, covers Monaco Italy Bulgaria Spain including Infosecurity Ireland, appear to be quite all national networks, not exclusively government ones, Greece active in this field. In addition, Ireland organised and the State Information Resources Management Cyprus a number of successful individual cybersecurity Council acts as a powerful policy formation and Malta education campaigns, such as the “Make IT Secure”, Finland management body. which included releasing online resources alongside a The cybersecurity strategy recognises the value and television advertising campaign. Sweden Estonia Denmark Latvia need for public-private partnerships, but no formalised Lithuania Ireland United Kingdom or systematic cooperation yet exist. ITALY Netherlands Poland Finland Belgium Germany Luxembourg Czech Republic Slovakia LUXEMBOURG Sweden Estonia Italy updated its security Austria France Hungary Slovenia Romania Latvia Croatia laws in 2007 and adopted Denmark Lithuania Luxembourg has a fairly Ireland United Monaco Bulgaria Kingdom Portugal Spain cybersecurity plans in 2013 Netherlands limited cybersecurity strategy, Poland Belgium Germany and 2014, resulting in a Greece Czech published in 2013, which Republic Slovakia Cyprus strong legal framework Malta France Austria Hungary contains some key guiding Slovenia Romania supporting cybersecurity. The Croatia principles but has little detail Monaco Bulgaria Italian cybersecurity strategy also calls out public- Portugal Italy Spain on their implementation. The private partnerships as the intended direction for Greece country’s legal framework Cyprus cybersecurity, but no formalised cooperation yet exists. for supporting cybersecurity is also yet to be Malta CERT-PA was established in 2014. It is responsible for fully developed. The need to encourage public- cybersecurity warning systems and the coordination private cooperation is a principle mentioned in the of incident response measures for Italian government cybersecurity strategy, but no formal cooperation is institutions. known. Luxembourg has two CERTs. CIRCL is a response LATVIA coordinating body that covers all organisations Finland operating in Luxembourg, while GOVCERT.LU is The Latvian cybersecurity dedicated to public authorities. CASES, a government strategy, published in 2014, Sweden Estonia information security agency, engages in awareness Ireland United Denmark contains a clear set of Lithuania raising activities and the promotion of best practices. Kingdom Netherlands concrete objectives matched Poland Germany with specific implementation Belgium Luxembourg Czech Republic Slovakia France Austria dates. It also has a strong legal Hungary Slovenia Romania framework for supporting cybersecurity, an important Monaco Croatia Bulgaria Spain pillar of which is the Law on Security of Information Italy Technology adopted in 2010. This law sets out the Greece roles and responsibilities of the country’s national Cyprus Malta computer emergency response team, CERT.LV. 14 BSA | The Software Alliance
Finland Finland Sweden Sweden Estonia Estonia Latvia Latvia Denmark Denmark Lithuania Lithuania Ireland Ireland United United Kingdom Kingdom Netherlands Netherlands MALTA PORTUGAL Poland Poland Germany Belgium Germany Belgium Luxembourg Czech Luxembourg Czech Republic Republic Slovakia Slovakia Austria Austria France Malta has yet to develop Slovenia Hungary Romania Portugal has not developed France Slovenia Hungary Romania Croatia Croatia Monacoa comprehensive legal Bulgaria a comprehensive legal Monaco Bulgaria Portugal Italy Italy Spain and policy framework for and policy framework Spain supporting cybersecurity, Greece Cyprus for cybersecurity, and its Greece Cyprus although its Digital Malta cybersecurity strategy has not Malta Strategy and e-government been elaborated. There is no plan promise the elaboration of a cybersecurity formalised public-private cooperation in place. strategy. The country does have a national CERT, CERT-PT, The Malta Information Technology Agency (MITA) and the National Centre for Cybersecurity. The latter appears to be active in cybersecurity. The national was established by the National Security Authority CERT is CSIRT Malta, which is responsible for and is tasked with liaising with the private sector on Finland coordinating incident response measures for entities cybersecurity incidents. Sweden Estonia engaged with Maltese critical infrastructure. Denmark Latvia Lithuania ROMANIA Ireland United Kingdom Finland Netherlands Poland NETHERLANDS Belgium Germany Sweden Estonia Luxembourg Czech Republic Romania has a somewhat Slovakia Austria The Netherlands has a Denmark Latvia France Slovenia vague cybersecurity strategy, Hungary Lithuania Croatia adopted in 2013. Its legal Ireland United sophisticated and mature Kingdom Monaco Bulgaria Portugal Italy framework is limited, although Poland Spain legal and policy framework Belgium Germany Luxembourg Czech for cybersecurity, which Republic Austria Slovakia relevant legislative proposals Greece Cyprus France Hungary includes the National Cyber Slovenia Croatia Romania Malta have been submitted to the Portugal Spain Monaco Security Strategy 2. Adopted Italy Bulgaria parliament for adoption. CERT-RO is the national in 2013, it is the second such strategy, as the country’s Greece computer emergency response team. It covers all users cybersecurity framework is renewed every two years. Cyprus of Romanian networks. Furthermore, the cybersecurity strategy proposes the establishment of two other Malta The Netherlands also has a National Cyber cybersecurity agencies. Finland Security Centre, an expanded CERT dealing with Sweden Estonia all cybersecurity related procedures and practices Latvia Denmark SLOVAKIA in a centralised manner. The centre also actively Lithuania Ireland United Kingdom participates in the work of the Information Sharing Netherlands Slovakia adopted its first, five- Poland Belgium Germany and Analysis Centres (ISACs) for sectors involved with Luxembourg Czech year cybersecurity strategy Republic Austria critical infrastructure. France Hungary in 2009. Details on the new Slovenia Croatia Romania Finland Portugal Spain Monaco strategy for 2014 to 2020 Italy Bulgaria POLAND remain limited. Slovakia has a Greece CERT, CSIRT.SK, that focuses Sweden Estonia Cyprus Latvia Poland has a comprehensive on government agencies and critical infrastructure Malta Denmark Lithuania Ireland United Kingdom Netherlands cybersecurity strategy with operators. There are no defined public-private Germany clear goals. It was adopted partnerships for cybersecurity. Belgium Luxembourg Czech Republic Slovakia France in 2013, thus most of the Austria Hungary Slovenia Romania Monaco recommendations are still Croatia Bulgaria Spain being implemented. The legal Italy framework for cybersecurity is still not fully developed. Greece Cyprus Malta Poland has several CERTs, including CERT.GOV.PL, which covers government and critical infrastructure entities. It also acts as the cybersecurity authority. CERT Polska is an academic CERT covering the entire .pl network in a semi-official capacity. www.bsa.org 15
EU Cybersecurity Dashboard A Path to a Secure European Cyberspace Finland Sweden Estonia Latvia Denmark Lithuania Ireland United SLOVENIA SWEDEN Kingdom Netherlands Poland Belgium Germany Luxembourg Czech Slovenia has yet to develop Sweden does not have a Republic Slovakia Austria France Hungary Finland a comprehensive legal Croatia Romania national cybersecurity strategy, ortugal Spain Monaco and policy framework for Italy Bulgaria Estonia but one is being developed. cybersecurity. As such, it also Greece Denmark Latvia Lithuania There are no laws in Sweden Ireland has yet to adopt a national that specifically deal with United Cyprus Kingdom Netherlands Poland cybersecurity strategy. SI-CERT cybersecurity. Malta Belgium Germany Luxembourg Czech is the national computer emergency response team, Republic Slovakia Austria and it deals with all Slovenian networks. There are no Finland Sweden does, however, have a functioning France Slovenia Hungary Romania Croatia defined public-private partnerships for cybersecurity in CERT, CERT-SE, which has jurisdiction over all Monaco Bulgaria Sweden Portugal Italy Swedish networks. Furthermore, the Swedish Civil Estonia Spain Slovenia. Latvia Contingencies Agency (MSB), which is the national Denmark Greece Lithuania Ireland United Cyprus Kingdom Netherlands Poland authority in charge of information security, has helped Malta SPAIN Belgium Germany Luxembourg Czech Republic Slovakia Sweden establish a good reputation on cybersecurity. France Austria Hungary MSG is the centralised information security entity and Spain adopted the National Slovenia Romania Croatia has a prominent public presence. Portugal Cyber Security Strategy in Monaco Italy Bulgaria 2013. It is a comprehensive Greece document, which sets Cyprus UNITED KINGDOM Finland objectives and targeted lines Malta Sweden of actions. It is compatible The United Kingdom has a Estonia Latvia with, and references, both the National Security Plan Ireland comprehensive cybersecurity Denmark Lithuania and existing security laws; and these plans and laws strategy, which was released Netherlands Poland Germany in 2011. It is complemented Belgium work together as a package. Luxembourg Czech Republic Slovakia by a strong cybersecurity France Austria Hungary Romania Slovenia Spain has established two CERTs, INTECO-CERT legal framework and two Monaco Croatia Bulgaria and CCN-CERT, and the National Centre for Critical CERTs: CERT-UK mainly supports operators of critical Portugal Spain Italy Infrastructure Protection (CNPIC). The latter appears infrastructure while GovCertUK supports government Greece to be the premier agency for information security and agencies. Other relevant bodies include the National Cyprus Malta cybersecurity, while the role of the CERTs is limited Security Council and the Office of Cyber Security and to dealing with cybersecurity incidents. CNPIC is Information Assurance. responsible for ensuring coordination and cooperation between the public and private sector. It also runs The United Kingdom also has a well-developed system sectoral working groups and is working toward the of public-private partnerships in which the private development of sector-specific cybersecurity plans. sector actively participates. This collaborative approach also is strongly supported by its cybersecurity strategy. Additionally, cooperation with the private sector is The Centre for the Protection of National Infrastructure formalised through the National Advisory Council on (CPNI), for example, organises sector-specific Cybersecurity, established in 2009, whose members information exchanges, covering 14 sectors. are private sector representatives. The council is tasked with providing policy advice to the government, although its current status is somewhat unclear. Private sector associations are also active, with two prominent bodies dedicated specifically to cybersecurity and information security, as opposed to general IT matters. 16 BSA | The Software Alliance
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