In our last blog, we gave a rundown of what the Telecommunications (Security) Act (TSA) is, why it’s been introduced, who it affects, when it starts, and how firms can prepare. Here, we take a closer look into the themes introduced by the Act, explore how the telecoms industry can explore zero trust to further improve its security posture, and outline the benefits that can be gained when complying.
When the Telecoms Security Act (TSA) was introduced, it was labelled as ‘one of the strongest telecoms security regimes in the world, a rise in standards across the board, set by the government rather than the industry’ by Matt Warman, former Minister of State at the Department for Digital, Culture, Media, and Sport. The industry is certainly feeling the impending impact of the act – with one industry pundit at an event we ran recently describing it as a ‘multi-generational change’ for the sector.
One of the headline grabbers stemming from the Act are the associated fines. With the new powers granted to it by the Act, Ofcom now has the responsibility to oversee operators’ security policies and impose fines of up to 10 percent of turnover or £100,000 a day in case operators don’t comply or the blanket ban of telecoms vendors such as Huawei. Sounds like the typical ‘stick’-based costly compliance messaging that no-one particularly wants to hear, right? But what if the TSA had some ‘carrot’-based business benefits that are much less discussed?
The TSA introduces a new security framework for the UK telecoms sector to ensure that public telecommunications providers operate secure and resilient networks and services and manage their supply chains appropriately. ny of the themes introduced in the code of practice can be aligned with the themes in a zero trust security model, which are also a focus for CISOs.
Zero trust security is a concept (also known as ‘never trust, always verify’) which establishes trust in users and devices through authentication and continuous monitoring of each access attempt, with custom security policies that protect every application. At Duo, our approach to zero trust is:
A crucial point to note here: much like a solution that claims to help with all aspects of the TSA, telecom providers should be wary of any vendor who claims to have a zero-trust product. Both are far much bigger than any ‘silver bullet’ solution purports to offer. But there is a good reason a zero-trust framework has been mandated by the US White House for all federal agencies, and recommended by the Australian Cyber Security Centre (ACSC) and the UK’s National Cyber Security Centre (NCSC).
As well as helping to mitigate the significant cyber risks presented to the telecoms industry, a zero-trust strategy provides many business benefits. Our recent Guide to Zero Trust Maturity shows that:
A robust zero-trust security program includes phishing-resistant multi factor authentication (MFA), access controls for devices and applications, risk-signalling, dynamic authentication, firewalls, analytics, web monitoring and more. As I said previously there is no one answer to zero trust, or indeed the TSA, but getting the basics right like strong MFA, single sign on (SSO) and device trust are an easy and effective way to get started.
The TSA will be a huge undertaking for industry, but it is important to focus on the benefits such a wide-reaching set of regulatory rules will inevitably result in. As another guest from our recent event put it: ‘the TSA is full of the latest and modern best practice around security, so the aim really is to raise the tide and all ships, which can only be a good thing.’
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In November 2020, the Telecommunications (Security) Bill was formally introduced to the UK’s House of Commons by the department for Digital, Culture, Media & Sport. Now, after several readings, debates, committee hearings, and periods of consultation, the Telecommunications (Security) Act is quickly becoming reality for providers of public telecoms networks and services in the UK, going live on 1 October 2022. Here, we outline what exactly the requirements mean for these firms, and what they can do to prepare.
The Act outlines new legal duties on telecoms firms to increase the security of the entire UK network and introduces new regulatory powers to the UK Telecoms regulator OFCOM to regulate Public Telecommunications Providers in the area of cyber security. It place obligations on operators to put in place more measures around the security of their supply chains, which includes the security of the products they procure. The Act grants powers to the Secretary of State to introduce a so-called Code of Practice. It is this Code of Practice which contains the bulk of the technical requirements that operators must comply with. Those not in compliance face large fines (up to 10% of company turnover for one year).
Following the UK Telecoms Supply Chain review in 2018, the government identified three areas of concern that needed addressing:
Following the review, little did we know a major resilience test for the telecoms industry was about to face significant challenges brought on by the Covid-19 pandemic. Data released by Openreach – the UK’s largest broadband network, used by customers of BT, Plusnet, Sky, TalkTalk, Vodafone and Zen – showed that broadband usage more than doubled in 2020 with 50,000 Petabytes (PB) of data being consumed across the country, compared to around 22,000 in 2019.
There is no question the security resilience of the UK telecoms sector is becoming ever more crucial — especially as the government intends to bring gigabit capable broadband to every home and business across the UK by 2025. As outlined in the National Cyber Security Centre’s Security analysis for the UK telecoms sector, ‘As technologies grow and evolve, we must have a security framework that is fit for purpose and ensures the UK’s Critical National Telecoms Infrastructure remains online and secure both now and in the future’.
The legislation will apply to public telecoms providers (including large companies such as BT and Vodafone and smaller companies that offer telecoms networks or services to the public). More specifically to quote the Act itself:
As the requirements are long and varied and so the timelines to comply have been broken down to help organisations comply. The current Code of Practice expects Tier 1 providers to implement ‘the most straightforward and least resource intensive measures’ by 31 March 2024, and the more complex and resource intensive measures by 31 March 2025.
Tier 2 firms have been given an extra two years on top of the dates outlined above to reflect the relative sizes of providers. Tier 3 providers aren’t in scope of the regulatory changes currently but are strongly encouraged to use the Code of Practice as best practice. The Code of Practice also expects that these firms ‘must continue to take appropriate and proportionate measures to comply with their new duties under the Act and the regulations’.
The TSA introduces a range of new requirements for those in the telecoms industry to understand and follow. These will require a multi-year programme for affected organisations. An area of high focus for example will be on Third Party controls and managing the relationship with them.
However there are more common security requirements as well. From our work with many companies across many different industries, we know that establishing that users accessing corporate systems, data and applications are who they say they are is a key aspect of reducing risk by limiting the possibility of attacks coming in through the front door. This is a very real risk highlighted in Verizon’s 2022 Data Breaches Investigations Report, which states that around 82% of data breaches involved a human element, including incidents in which employees expose information directly or making a mistake that enables cyber criminals to access the organisation’s systems.
Therefore, one area to start to try and protect the organisation and take a step on the way to compliance is to build up authentication and secure access to systems, data and applications. However even this can take time to implement over large complex environments. It means gaining an understanding of all devices and ensuring there is a solid profile around them, so they can be reported on, attacks can be blocked and prevented, and access to applications can be controlled as needed.
We will be creating more information around the Act as we move closer to the deadlines, including part two of this blog where we will take a deeper dive into themes introduced by the bill, how it compare with other industries’ and jurisdictions’ cyber security initiatives, and explore what else the telecoms industry can do to improve its security posture.
We are also running an event in London on 13 October: ‘Are you ready for TSA?’ which will include peer discussions where participation is welcome on the TSA. If you are interested in attending, please register here.
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