Compliance & Cyber Intelligence for Insurance
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CYB-27 · Cyber security

Cyber awareness training — all staff complete annual training; new staff trained at onboarding

Human error and social engineering are implicated in over 80% of successful cyber attacks. All staff must complete cyber security awareness training at onboarding and annually thereafter. Training must cover: phishing recognition, BEC, password hygiene, safe data handling, and incident reporting. Completion must be tracked per individual.

High priority

Trigger

When this rule fires

No cyber awareness training programme; staff training records absent; training not completed within last 12 months; new staff not trained within 30 days of joining

Applicability gate

Confirm the entity's role before treating this as a duty

This is a readiness rule mapped to JS2 themes. Its presence in the library does not establish that JS2 applies directly to the firm.

  • Insurance Broker: Most independent non-life Category I brokers are not directly in JS2's defined scope. A broker may be directly in scope if it separately meets a listed category, and may face contract or oversight requirements from an in-scope institution. Third-party provisions impose duties on the in-scope financial institution. They do not themselves make every supplier or intermediary directly subject to JS2.
  • Uma Binder Holder: UMA or binder-holder status is not itself listed in JS2's definition. Direct scope depends on another listed capacity; insurer contracts and oversight may create evidence requirements. JS2 paragraph 3.3 concerns juristic persons structured under an insurer or designated insurance group; it is not a blanket rule for every independent UMA or intermediary.
  • Insurer: An insurer as defined in the Insurance Act is directly in scope of JS2 from 1 June 2025. Apply proportionality and distinguish the insurer's own duty from requirements it places on third parties.

Citation

Mapped source

This control maps to the public instruments below. The mapping does not establish entity applicability.

Section
Joint Standard 2 of 2024 — paragraph 7.2.7 (cybersecurity awareness and training) / FICA s.43
Legislation
  • Joint Standard 2 of 2024
  • FICA s.43

Remediation

How to close the gap

Implement a cyber awareness training programme (KnowBe4, Proofpoint Security Awareness, or similar). Track completion per staff member. Include assessment with minimum pass score. Integrate into new staff onboarding checklist.

Evidence required

Evidence to prepare if this control applies

  • Training programme and content
  • Completion records per staff member (last 12 months)
  • Assessment scores
  • New staff onboarding training record
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