Embed cyber accountability within your SMCR framework
Cybersecurity Governance Model Design.
Align cybersecurity oversight with your SMCR responsibilities—clarifying roles, strengthening accountability, and ensuring board-level visibility of cyber risk. We help your firm build a governance structure that meets regulatory expectations, reduces exposure, and supports informed, risk-aware decision-making.
What is cybersecurity governance model design?
Cybersecurity Governance Model Design is a top-down, enterprise-wide framework that ensures cyber risk is managed with the same rigor as financial, legal, or operational risk. It clarifies accountability—from the board to operational teams—ensures decision-making structures, and integrates policies, technical controls, risk monitoring, and incident readiness into everyday business operations.
A well-designed model defines roles and responsibilities, sets risk appetite, and aligns cybersecurity strategy with business objectives.
Why it matters for your firm.
Clarifies Accountability Under SMCR
Helps clearly define who is responsible for cyber risk at the senior management level—supporting compliance with SMF functions and reducing personal liability exposure.
Supports Regulatory Expectations for Oversight
Establishes governance structures that demonstrate effective board and executive oversight of cyber risk, aligning with FCA expectations for operational resilience and risk management.
Improves Decision-Making Through Risk Visibility
Creates clear reporting lines and escalation paths, enabling timely, risk- informed decisions by senior leaders—essential for demonstrating a “reasonable steps” defence under SMCR.
Financial Materiality & Investor Scrutiny
Cyber incidents can result in multimillion-pound losses, reputational harm, and shareholder consequences. Investors and pension funds are demanding evidence of board engagement and accountability in cyber oversight.
Key features of our service.
Board-Level Accountability & Oversight
Define clear ownership—from board, CEO, COO, CTO, to internal audit. Embed regular reporting and engagement in board agendas. Foster cybersecurity expertise at the senior level.
Alignment to Business Strategy & Risk Appetite
Tie cybersecurity objectives to your firm’s strategic goals such as client trust, operational resilience, and innovation. Establish a risk appetite framework that reflects investment-management priorities.
Policies, Standards & Technical Controls
Implement comprehensive policies (access control, data protection, third-party risk), underpinned by standards like ISO 27001, COBIT, NIST CSF. Enforce technical controls and document them to match declared risk appetite.
Risk Management & Supply Chain Oversight
Conduct continuous risk assessment—especially across thirdparty vendors and service providers. Include supply chain risk as part of core monitoring and incident planning.
Incident Preparedness & Response
Prepare and exercise incident response playbooks at all organizational levels—from ops to board crisis management. Use red teams, tabletop exercises, and conduct post-incident analysis to drive improvement.
Continuous Monitoring & Independent Assurance
Regular audits, penetration tests, vulnerability assessments and board reporting combine to deliver ongoing assurance on posture integrity.
Outcome for your firm.
A clear, fit-for-purpose cybersecurity governance model aligned to your firm’s risk appetite, regulatory obligations, and operational structure. With a Governance Model in place, your firm not only meets regulatory demands, but also demonstrates robust strategic security, strengthens investor confidence, and protects against the reputational and financial consequences of cyber breaches.
Ready to align cybersecurity governance with SMCR requirements?
Get in touch to learn how our Cybersecurity Governance Model Design service helps investment firms meet FCA expectations, demonstrate clear cyber risk ownership, and evidence SMCR compliance.
Why our clients trust us.
See what makes us differentDeep Sector Expertise
We align cybersecurity with your operational reality, delivering practical solutions that enhance efficiency and build lasting resilience
Trusted Partnerships
We act in your best interests, building trust through clarity, consistency and results that align with your business.
GRC-FIRST APPROACH
We align cybersecurity with governance, risk and compliance, delivering solutions that safeguard your operations and reinforce business resilience.
VALUE DRIVEN APPROACH
We embed cybersecurity that’s proportionate, business-aligned and always focused on the outcomes that matter most to you.