Working template

Leadership security review

A companion to What a small investment firm should expect from its security program.

Download the text file to fill it in with your own details, or print a blank copy.

Use a small number of business exposures. Describe evidence with its scope and date. Assign legal or contractual applicability questions to the appropriate advisers.

Review period / owner:  

Attendees and roles (accountable executive, technology lead, compliance, outside adviser if any):  

Frameworks or obligations the program claims to follow, and who confirmed applicability:  

Obligation crosswalk

One row per commitment the firm has made or must meet. A row with no evidence column filled is a finding.

Obligation or commitment (regulatory, contractual, investor, insurance) Policy or procedure that addresses it Control in operation Evidence and retention location Owner Last confirmed

Exposure review

Business exposure Control / practice Evidence, scope, and date Gap / uncertainty Accountable owner Decision required
Unauthorized access
Loss of important information
Unavailable critical service
Vendor dependency
Delayed detection or response
Payment or instruction fraud
Misuse of AI tools with firm or portfolio data

Measures worth seeing each period

State the measure, the value, its source, and the date. Leave unknown values blank rather than estimating.

Measure Value Source and date Trend
Accounts with phishing-resistant or multi-factor sign-in, as a share of all accounts
Privileged accounts, and date of last review of that list
Devices meeting the baseline (encryption, updates, management), as a share of all devices
Critical updates outstanding beyond the agreed window
Backup or recovery exercises run, and how many met their objective
Vendors handling sensitive data with a review completed in the last year
Security awareness or phishing exercise completion and result
Incidents and near misses, by category
Open findings from the last assessment, penetration test, or audit, by age

Changes since the previous review

Information, services, providers, or access added:  

Incidents / exercises / significant findings:  

Policy documents due for review or approval this period:  

Obligations calendar (regulatory filings, attestations, investor questionnaires, insurance renewal, contract commitments) due in the next two periods:  

Exception decision

Affected service and information:  

Consequence / compensating measures:  

Remaining exposure:  

Accepting owner / review date:  

Actions

Improvement Owner Due date Budget or resource needed Evidence of completion

Common failure modes

  • The review reads a dashboard nobody can trace to evidence.
  • Exceptions accepted in a hurry are never re-examined.
  • Vendor reviews are counted as done when the questionnaire was sent, not answered.
  • Metrics are reported without the denominator.

A dashboard status should be traceable to evidence. Mark a check as unknown or untested when that is what the record supports.

Next review date / cadence:  

This review supports leadership decisions. It does not replace a risk assessment, an independent assessment, or legal advice on which obligations apply.