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CSIA 485: Practical Applications in Cybersecurity Management & Policy
Project #1: Cybersecurity Strategy & Plan of Action
Your Task:
You have been assigned to support the Padgett-Beale Merger & Acquisition (M&A) team working under
the direct supervision of Padgett-Beale’s Chief Information Security Officer (CISO). The M&A team is in
the planning stages for how it will integrate a new acquisition, Island Banking Services, into the company
as its financial services arm (PBI-FS). Initially, PBI-FS will function as a wholly owned subsidiary which
means that it must have its own separate cybersecurity program.
Your first major task (Project #1) will be to help develop a Cybersecurity Strategy & Plan of Action for
PBI-FS. Island Banking Services never had a formal cybersecurity program so you’re starting from
scratch. You will need to research best practices as well as relying heavily upon what you learned in your
undergraduate studies in Cybersecurity Management and Policy. The CISO has provided detailed
instructions for this task. (These appear after the Background section below.)
Background
After five years of operation, Island Banking Services — a non-U.S. firm — was forced into bankruptcy
after criminal money laundering charges were filed against the company and its officers. Padgett-Beale,
Inc. purchased the digital assets and records of this financial services firm from the bankruptcy courts.
The purchased assets include licenses for office productivity software, financial transactions processing
software, database software, and operating systems for workstations and servers. Additional assets
included in the sale include the hardware, software, and licensing required to operate the company’s
internal computer networks.
Figure 1. Island Banking Services IT Infrastructure Purchased by Padgett-Beale, Inc.
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CSIA 485: Practical Applications in Cybersecurity Management & Policy
Padgett-Beale’s legal counsel successfully negotiated with the bankruptcy court and the criminal courts
for the return of copies of the company’s records so that it could restart Island Banking Service’s
operations. The courts agreed to do so after Padgett-Beale committed in writing to reopening the
customer service call center (but not the branch offices) on the island. Reopening the call center will
provide continued employment for 10 island residents including 2 call center supervisors. Padgett-Beale
intends to relocate the call center to a company owned property approximately 10 miles away from the
current location and adjacent to a newly opened Padgett-Beale resort.
Padgett-Beale’s Risk Manager has recommended that the Merger & Acquisition plan be amended such
that Island Banking Services would be operated as a wholly owned subsidiary for a period of 5 years
rather than being immediately and fully integrated as an operating element of Padgett-Beale. The
company’s attorneys agreed that this would be the best approach given the potential for additional legal
troubles related to the actions of the previous owners and employees. The Board of Directors has signed
off on this amendment to the M&A plan and stipulated that the new subsidiary will be named PBI
Financial Services (PBI-FS). The company officers and senior managers for PBI-FS will be named at a later
date. For now, the leader of the M&A Team will serve as the Chief Operating Officer. Padgett-Beale’s
Chief Information Security Officer will be loaned to PBI-FS while a search is conducted for a dedicated
CISO for the subsidiary.
CISO’s Detailed Instructions to You
The CISO has given you and your team mates a set of instructions (below) which you should follow as
you complete this task.
Task #1: Read and Analyze the Background Materials
If you have not already done so, read the Background information in this file. Next, review the PadgettBeale M&A Profile 2020 which was posted to the LEO classroom. You should also review all materials
from the classroom for Weeks 1 – 4 as these provide needed information about the Financial Services
industry and the legal and regulatory requirements which apply to this industry.
Task #2: Perform a Gap Analysis & Construct a Risk Register
Using the information available to you, determine the most likely information technology/security gaps
which existed at Island Banking Services prior to its being acquired by PBI. Next, determine which of
these, if not addressed, will likely exist in the newly formed subsidiary PBI-FS. Document your analysis
and evaluation in a Gap Analysis.
Your Gap Analysis should address operating issues relating to confidentiality, integrity, and availability
(CIA) of information, information systems, and information infrastructures owned or used by PBI-FS.
Your analysis should also consider and use the People, Process, and Technology framework.
Copyright © 2022 by University of Maryland Global Campus. All rights reserved.
CSIA 485: Practical Applications in Cybersecurity Management & Policy
Step 1: Identify 10 or more significant cybersecurity issues/challenges/risks which the background
information and M&A profile indicate currently exist at PBI-FS / Island Banking Services. You are allowed
to “read between the lines” but must be able to map your analysis and findings to specific statements
from these documents. These items will become your “Gaps” for the Gap Analysis. Use one or more
cybersecurity frameworks or standards (e.g. NIST CSF; People, Processes, and Technologies;
Confidentiality, integrity, availability) to organize your analysis.
Note: there was significant criminal behavior found at Island Banking Services. Your analysis
must address internal weaknesses which allowed this to occur without being discovered by the
employees who were not involved in the crimes.
Step 2: Using your Gap Analysis (step 1) create a Risk Register (see Table 1 at the end of this file) in
which you list 10 or more specific and separate risks. For each risk, assign a category (confidentiality,
integrity, availability, people, process, technology) and a severity (impact level using a 1 – 5 scale with 5
being the highest potential impact).
Step 3: Review the laws and regulatory guidance which apply to the Financial Services industry and
companies like Island Banking Services. For each entry in your risk register, identify and record the laws,
regulations, or standards which provide guidance as to how the identified risks must be addressed or
mitigated. Record this in your risk register.
Step 4: Review laws and regulations which apply to all companies, i.e. Sarbanes Oxley, IRS regulations
for Business Records, SEC regulations and reporting requirements, etc. Review your Risk Register and
either map these requirements to existing entries in your risk register or insert new entries for
significant legal or regulatory requirements which you were not able to map to your previously
identified risks. (Include risk related to non-compliance.)
Step 5: Review section 1.2 Risk Management and the Cybersecurity Framework in the NIST
Cybersecurity Framework v1.1 (https://nvlpubs.nist.gov/nistpubs/CSWP/NIST. CSWP. 04162018.pdf)
Using this information, determine the best strategy for addressing (“treating”) each of your identified
risks. Remember the four types of risk mitigation strategies (accept, avoid, control, transfer).
Consider the business impact for each of your mitigation strategies (e.g. if you applied an
“avoid” strategy across the board, the company would not be able to operate in the financial
services industry because it would need to shut down all operations).
Record your risk mitigation strategy for each risk in your risk register. For each of your “control” entries,
include the corresponding control category and subcategory (if applicable) from the NIST Cybersecurity
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CSIA 485: Practical Applications in Cybersecurity Management & Policy
Framework (see Tables 1 and 2 in version 1.1). Examples: ID.AM Asset Management or PR.AC Identity
Management and Access Control. Remember to cite your sources.
Step 6: Develop a Cybersecurity Strategy that presents five or more specific actions (strategies) that the
company should take to implement your recommended risk mitigations. Include information from your
gap analysis, legal and regulatory analysis, risk analysis and proposed risk mitigations. Under each
strategy include information about how the strategy will affect or leverage people, policies, processes,
and technologies (hardware, software, infrastructure). Include examples and other pertinent
information about Island Banking Services and Padgett-Beale. You should have at least one technology
related strategy which includes an updated Network Diagram. This diagram must show the to-be state
of the IT infrastructure including recommended mitigating or “control” technologies, e.g. intrusion
detection, firewalls, DMZ’s, etc. (start with the diagram provided in this assignment file).
Note: Your strategy will be presented to the Board of Directors by the executive who is leading
the Merger & Acquisition Team so make sure that you write in appropriate language and include
sufficient detail to explain your recommended strategy.
Step 7: Develop and document a proposed plan of action and implementation timeline that addresses
each element of the cybersecurity strategy that you identified previously (in step 6). Provide time,
effort, and cost estimates for implementing your recommended actions (include appropriate
explanations of your reasoning). Include the resources (people, money, etc.) necessary for completing
each task in the timeline.
Step 8: Develop a set of 5 or more high-level summary of recommendations regarding the next steps to
take in mitigating the risks that you identified in steps 1-7. These recommendations should logically flow
from your analysis and be supported by your Cybersecurity Strategy and Plan of Action.
Putting It All Together
1. Format your work for Steps 1-7 as a Cybersecurity Strategy and Plan of Action. The six major
elements listed below should appear in this order in a single file. Your MS Word format
document file must include:
• Introduction (what is in this document and to what organization does it apply)
• Gap Analysis (Step 1)
• Legal & Regulatory Requirements Analysis (Steps 3, 4)
• Risk Analysis & Risk Register (Steps 2, 3, 4, 5)
• Cybersecurity Strategy (Step 6)
• Plan of Action and Implementation Timeline (Step 7)
Copyright © 2022 by University of Maryland Global Campus. All rights reserved.
CSIA 485: Practical Applications in Cybersecurity Management & Policy
The Cybersecurity Strategy and Plan of Action is a comprehensive MS Word document that
includes a separate title page followed by the six major elements (see list under step 7) and
ending with a reference list. Your document must include a reference list and appropriate
citations throughout. You will need 10 – 12 pages to fully document your strategy and plan.
Use section headings and sub headings to organize your work. You may use internal title pages
(section titles) to make it clear where each of the major elements begins and ends. Title pages
and reference pages are not included in the recommended length.
2. Format your recommendations from Step 8 as a Cover Letter / Recommendations Memo to
accompany your Security Strategy document.
The Recommendation Memo is a 2 page, professionally formatted memorandum
addressed to the Merger & Acquisition Team. This cover letter / memo should
summarize why this package is being forwarded to the M&A team for “review and
action.” The memo should introduce and provide a brief summary of the purpose and
contents of the Cybersecurity Strategy and Plan of Action (name and describe each of
the major sections). Use a professional format for your memo (consider using one of the
MS Word templates). The memo does not include citations or references but, you may
need to name laws or regulations.
Notes on Constructing Your Network Diagram (for step 6):
Your diagram must be based upon the provided network diagram with additions or deletions that are
clearly your own work. You may use MS Word’s drawing tools, Power Point, or other drawing program.
When you have completed your diagram, you may find it helpful to take a screen snapshot and then
pasted that into your deliverable file(s).
You may use commercial or “free” clip-art to represent individual end point devices or network
appliances such as routers, firewalls, IDPS, etc.) Clip art does not need to be cited provided that it is clip
art (not screen captures from another author’s work).
Additional Information
1. Consult the grading rubric for specific content and formatting requirements for this assignment.
2. Your paper should be professional in appearance with consistent use of fonts, font sizes,
margins, etc. You should use headings and page breaks to organize your paper.
3. Your paper should use standard terms and definitions for cybersecurity.
4. The CSIA program recommends that you follow standard APA formatting since this will give you
a document that meets the “professional appearance” requirements. APA formatting guidelines
and examples are found under Course Resources. An APA template file (MS Word format) has
also been provided for your use CSIA_Paper_Template(TOC+TOF,2021).docx.
Copyright © 2022 by University of Maryland Global Campus. All rights reserved.
CSIA 485: Practical Applications in Cybersecurity Management & Policy
5. All submission files must begin with a cover page with the assignment title, your name, and the
due date. Your reference list must be on a separate page at the end of your file.
6. You are expected to write grammatically correct English in every assignment that you submit for
grading. Do not turn in any work without (a) using spell check, (b) using grammar check, (c)
verifying that your punctuation is correct and (d) reviewing your work for correct word usage
and correctly structured sentences and paragraphs.
7. You are expected to credit your sources using in-text citations and reference list entries. Both
your citations and your reference list entries must follow a consistent citation style (APA, MLA,
etc.).
Copyright © 2022 by University of Maryland Global Campus. All rights reserved.
CSIA 485: Practical Applications in Cybersecurity Management & Policy
Table 1. Risk Profile Table (example)
Risk ID
Risk
001
Theft of
customer
information
from online
transactions
Category
Severity
Applicable
Laws,
Regulations,
Standards
Risk Mitigation
Strategy
(description)
Implementation:
Required
Technologies,
Products, or
Services
Encrypt all
communications
between
customers and
the company’s
online ordering
system.
Implement
Transport Layer
Security; purchase
and deploy digital
certificates to use
to encrypt
communications.
002
003
004
005
006
007
008
009
010
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NIST
Cybersecurity
Framework
Category and
Sub Category
Identifier (e.g.
ID.AM-1)
PR.DS-2
Sub-Category
Description
Data-in-transit
is protected.
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