1. Executive Summary
UBBfh Bank prioritises the confidentiality, integrity and availability of sensitive data and systems. In an era of increasing cyber threats, our commitment is to mitigate risks, ensure regulatory compliance and maintain stakeholder trust. Aligned with ISO/IEC 27001:2022, our Information Security Management System (ISMS) provides a systematic framework to identify, manage and mitigate information security risks. This document outlines the strategic implementation of our ISMS, associated controls and our adherence to global best practices in cybersecurity.
2. Scope of the ISMS
The ISMS encompasses all UBBfh Bank activities involving, but not limited to:
Customer Data: Personal, financial and transactional information. Core Banking Systems: Payment processing, loan management, digital platforms and related services. Third-Party Services: Cloud providers, fintech partners and other critical vendors. Physical and Logical Security: Data centres, employee workstations, mobile devices and access controls. Supporting Infrastructure: Network security, communication systems and backup environments. The ISMS is governed by the Chief Information Security Officer (CISO) and is tightly integrated with our IT governance, risk management and business continuity frameworks.
3. Leadership and Governance
3.1 Leadership Commitment
The Board of Directors and Senior Management have underscored their commitment by:
Establishing a comprehensive Information Security Policy that defines clear accountability. Allocating dedicated resources for ISMS implementation, regular audits and continuous staff training. Ensuring the ISMS aligns with [Central Bank Name]’s Cybersecurity Guidelines and all relevant local regulations [reference local regulations]. Maintaining oversight through regular performance reviews and executive reporting. 3.2 Roles and Responsibilities
Key roles within the ISMS include:
Chief Information Security Officer (CISO): Responsible for overall ISMS management, risk assessments and incident response. IT Security Team: Implements and monitors technical security controls such as firewalls, encryption and intrusion detection systems. Data Protection Officer (DPO): Ensures compliance with data privacy regulations, such as GDPR and local data protection laws. Department Heads: Enforce security policies and facilitate staff training and awareness. Third-Party Risk Manager: Coordinates with external vendors to ensure alignment with UBBfh Bank’s ISMS requirements. 4. Risk Assessment and Treatment
4.1 Risk Identification
UBBfh Bank conducts biannual risk assessments to:
Identify emerging threats such as ransomware, phishing, insider risks and other cyber threats. Evaluate vulnerabilities in systems, processes and third-party relationships. Assess the impact on the confidentiality, integrity and availability (CIA triad) of critical assets. Utilise quantitative and qualitative measures to prioritise risk. 4.2 Risk Treatment
Risk mitigation is achieved through the application of controls outlined in ISO 27001 Annex A, including:
Role-based access management, multi-factor authentication (MFA) and ongoing monitoring of privileged accounts. A.12 – Operations Security: Implementation of secure coding practices, regular patch management and continuous monitoring via SIEM (Security Information and Event Monitoring). A.16 – Incident Management: Comprehensive cyber incident response plans, 24/7 Security Operations Centre (SOC) oversight and regular incident simulations. Frequent internal audits to ensure adherence to GDPR, PCI-DSS and central bank cybersecurity directives. 4.3 Statement of Applicability (SoA)
A documented Statement of Applicability details all implemented controls, provides justification for any exclusions and demonstrates alignment with ISO 27001 requirements. This serves as a living document that is updated regularly as risks and organisational needs evolve.
5. ISMS Implementation and Support
5.1 Resource Allocation
UBBfh Bank ensures robust support for the ISMS through:
Investment in advanced security tools, including intrusion detection systems, endpoint protection and encryption solutions. Annual third-party penetration testing and vulnerability assessments. Continuous staff training programmes and awareness initiatives tailored to cybersecurity. 5.2 Awareness and Training
To foster a culture of security, the following measures are implemented:
Mandatory, comprehensive cybersecurity training for all staff, refreshed quarterly. Regular phishing simulation exercises to enhance vigilance. Specialized training programmes for IT and security teams, including industry certifications such as CISSP and CISM. 5.3 Documentation
Key ISMS documentation maintained includes:
Information Security Policy. Detailed Risk Treatment Plan. Incident Response Procedures and Data Breach Notification Protocols. Change management and audit logs to support ongoing compliance. 6. Operational Security Controls
6.1 Asset Management
Maintain an up-to-date inventory of hardware, software and data assets, categorised by sensitivity (e.g. public, confidential). Implement secure disposal and data sanitisation protocols for decommissioned assets. 6.2 Cryptography
Use of robust encryption (e.g. AES-256 for data at rest and TLS 1.3 for data in transit). Secure key management processes utilising Hardware Security Modules (HSMs). 6.3 Supplier Security
Rigorous security assessments for third-party vendors. Contractual obligations that include security service level agreements (SLAs) and incident reporting protocols. Regular reviews to ensure vendors comply with UBBfh Bank’s ISMS standards. 6.4 Incident Management
Detection: 24/7 monitoring through a dedicated Security Operations Centre (SOC) with real-time alerting. Response: Immediate escalation via an established Crisis Management Team (CMT) for severe incidents. Recovery: Data restoration processes from encrypted backups and business continuity measures. Reporting: Mandatory notification to regulators within [X hours] following a confirmed breach. 7. Performance Evaluation
7.1 Internal Audits
Annual audits performed by an independent internal audit team. Comprehensive reporting of audit outcomes to the Board’s Risk Committee for oversight and action. 7.2 Management Review
Quarterly review meetings by Senior Management to evaluate ISMS performance. Discussion of emerging threats (including AI-driven attacks) and policy updates in response to new regulatory guidelines. 7.3 Continual Improvement
UBBfh Bank adopts the PDCA (Plan-Do-Check-Act) cycle to:
Implement corrective actions following audit findings and incident reviews. Continuously benchmark against the NIST Cybersecurity Framework and industry best practices. Ensure that the ISMS remains agile and responsive to the evolving threat landscape. 8. Regulatory Compliance
UBBfh Bank’s ISMS aligns with multiple regulatory frameworks:
Adherence to Bank of Ghana’s Cybersecurity Directive and any specific clauses therein. Compliance with data privacy legislation (e.g. GDPR, [Local Data Protection Act]) and other relevant standards. Integration of anti-money laundering (AML) controls through secure transaction monitoring and continuous risk assessments. Regular dialogue with regulatory bodies to maintain transparency and incorporate evolving regulatory requirements. 9. Conclusion
UBBfh Bank’s ISO/IEC 27001-certified ISMS is a testament to our commitment to robust information security. By deploying comprehensive controls, continuous monitoring and regular training, we ensure the protection of sensitive data and sustain trust across all stakeholder segments. We invite further engagement with regulators to demonstrate our controls and discuss our proactive cybersecurity measures.
Attachments
The following annexes provide detailed supporting documentation for our ISMS implementation:
Annex A: Statement of Applicability (SoA) Template Annex B: Risk Assessment and Treatment Reports Template Annex C: Incident Response Plan Summary Template 
