vCISO and Cyber & Information Security Guru helping businesses prevent and mitigate risk

I am a business-focused cyber security and GRC leader with extensive experience operating at Board and executive level across global managed services and technology organisations. My career spans over a decade of progressive leadership, from building security functions from the ground up to acting as Deputy CISO for a multi-entity international group.

I have defined and executed enterprise-wide security strategies, established and scaled Security Operations and GRC capabilities, and embedded integrated management systems covering ISO 27001, ISO 9001, ISO 14001, ISO 20000, and ISO 22301. I have led incident and vulnerability management across 40+ global data centres, overseen third-party due diligence programmes, and provided risk and compliance reporting to Audit & Risk Committees and Boards.

Alongside governance and compliance, I focus on building security into business value — whether integrating acquisitions, launching new client-facing services such as vCISO, or strengthening security culture through awareness programmes. My approach combines technical credibility with strategic vision, ensuring cyber security enables resilience, trust, and sustainable growth.
Objectives:
Continual self improvement.
To strive for excellence in everything I do.
Grow my business exposure and GRC expertise.

The UK Information Commissioner's Office has been signalling a tougher enforcement posture on so-called technical compliance failures. In plain English: weak access controls, poor retention practices, incomplete records, and controls that exist on paper but not in reality are now squarely in scope.

This matters because most regulatory pain doesn’t come from exotic zero-days. It comes from hygiene failures and a lack of basic good practices.

A few uncomfortable facts:
🛑 The ICO has repeatedly stated that inadequate security controls remain one of the most common causes of reportable personal data breaches.
🛑 In recent enforcement actions, organisational and technical measures under Article 32 GDPR have been central, even where there was no malicious attack.
🛑 According to the ICO’s own breach reporting trends, human error and misconfiguration consistently account for a material proportion of incidents.

The direction of travel is clear. Compliance is no longer assessed by whether a policy exists, but whether it is demonstrably implemented, monitored, and effective.

For businesses, this raises the bar:
▶️ More effort evidencing how controls operate, not just that they exist
▶️ Increased scrutiny of “low-risk” personal data processing
▶️ Greater expectation that privacy, security, and IT operations are joined up, not siloed.

This is operationally expensive, unglamorous work. Asset inventories. Access reviews. Retention enforcement. Logging. Testing. Re-testing. But it is also exactly where regulators are looking.

❓The uncomfortable question for leadership teams:❓ 
If the ICO reviewed your controls tomorrow, could you prove they work in practice, or just that someone once signed them off? Do you have good basic cyber hygiene in place?

#DataProtection #GDPR #CyberSecurity #RiskManagement #Governance

Hylton Stewart MCIIS

CISM & CRISC | vCISO and Cyber & Information Security Guru helping businesses prevent and mitigate risk

🛑 UK Cybersecurity at a Crossroads: Ambitious Action Plan, Weak Legal Teeth? 🛑

The UK government’s launch of its Government Cyber Action Plan alongside the second reading of the Cyber Security and Resilience Bill is being framed as a leap forward in national cyber defence. The plan comes with £210 million of investment to strengthen public sector defence, create a central Government Cyber Unit, and establish a Government Cyber Profession to attract talent and coordinate incident response across departments.

But here’s the strategic twist: central and local government are explicitly excluded from the scope of the Bill itself, relying instead on this Action Plan to “hold government to equivalent standards” without legal obligations.

To cybersecurity leaders and risk executives, that rings an alarm bell. The public sector has been a frequent target: the NCSC reported that about 40% of attacks it handled between 2020 and 2021 targeted the public sector — a share likely to grow in today’s threat climate. 

🔍 Why this matters to enterprise risk and compliance:
1️⃣ Regulatory certainty is central to cyber risk management. Exempting government from binding requirements while mandating them for operators of essential services (such as MSPs, data centres, and utilities) creates an inconsistent risk landscape, complicating compliance decisions for regulated industries.

2️⃣ For businesses in financial services and critical infrastructure, the CSR Bill expands reporting duties and scope well beyond the old UK NIS regime, signalling tougher enforcement ahead. But if the public sector isn’t bound by the same statutory duties, data protection and breach reporting expectations may diverge unpredictably.

3️⃣ From a data protection viewpoint, the devil is in the details: voluntary, guidance-based plans are harder to enforce, can slow incident transparency, and risk weaker accountability when it matters most.

This isn’t a blame game. A robust cybersecurity ecosystem depends on both strong regulation and strong implementation. An Action Plan without statutory force may look proactive on paper, but leaves a gap when the threat actors don’t care whether your standards are voluntary.

❓ Question for leaders: Are UK organisations prepared to navigate a post-NIS world where government cybersecurity isn’t legislated but expected, and enterprise reporting duties are tightening? What’s your view on aligning legislative force with strategic cybersecurity outcomes?

#cyberresilience #NIS #CyberSecurityandResilienceBill

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