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CEO & CISO: Start with Security Due Diligence

CEO & CISO: Start with Security Due Diligence

CEO & CISO: Start with Security Due Diligence

Enki White Hat

Enki White Hat

Content

Content

Content

When a security incident breaks out, people first ask.

“Who will take responsibility.”

And that arrow usually points to the CEO and Chief Information Security Officer (CISO) currently in office. Because the person leading the company when the incident happened is seen as the one responsible. On the surface, that seems natural. But if you trace the roots of the actual incident, the story becomes far more complex.

Accidents strike suddenly, but problems have grown over time

Looking at the major security incidents that have emerged at leading domestic companies recently, the problem was not something that suddenly appeared on the day the incident broke out. In many cases, old vulnerabilities, the absence of basic safeguards, neglected systems, lax authentication management, and weak governance had accumulated over a long time and then exploded all at once.

The government and the Personal Information Protection Commission pointed to shortcomings in basic safeguards such as passwords, operation of legacy systems, delayed notification, and governance issues in the 2025 SK Telecom incident. In the KT case as well, the government investigation confirmed vulnerabilities in certificate management that enabled unauthorized femtocell access, along with long-standing structural management failures. In other words, incidents happen in an instant, but the causes are usually built up over time.

In this kind of structure, the CEO or CISO in office when the incident occurs may not be the one who created all the causes. Even so, real responsibility is often concentrated on the management in place at that time. In the end, some leaders inherit the same company and finish their term without an incident by luck, while others encounter problems that have existed for years during their own tenure and are judged as symbols of incompetence. It is clear that security responsibility is extremely important, but if the starting point of responsibility is vague, it becomes difficult to make a fair assessment.

A new leader’s first need is to grasp the current situation

Isn't there a practical way to resolve this structural irrationality?
When a CEO or CISO is newly appointed, how about conducting an 'Initial Independent Security Posture Review' through an independent body early in their tenure to assess the organization’s overall security? 

This is a process in which a newly appointed CEO or CISO objectively reviews the organization’s security posture through an external independent body early in their tenure and leaves the results as an official record. 

Looking at overseas practices, this direction is quite practical and persuasive. EY explains that in a new CISO's first-year strategy, the company's current security posture should be reviewed first, and that as a starting point, an independent assessment of cybersecurity posture is important. The key is to look not only at vulnerability scans but also at policies, procedures, technology, and overall organizational operations.

Why is such a process necessary?
The reason is simple. When people go to a new hospital, they get a basic checkup first. Companies are no different. When a new leader takes charge of an organization, it is only natural to first confirm the current security posture. 

Yet in reality, things often move in the opposite direction. That is because the moment a problem is officially identified, both accountability for explanation and responsibility for improvement arise. So in some organizations, “not looking too closely” can seem like the easier choice. But pretending not to know does not make the risk disappear. It simply goes unrecorded.

This issue becomes even sharper in the CISO role. According to surveys, the average CISO tenure is about 18 to 26 months, much shorter than the 4.9-year average for general C-level roles. Another Heidrick & Struggles survey found that the biggest personal risks cited by CISOs were stress at 71% and burnout at 54%, and 29% feared they could lose their jobs after a breach. What these figures clearly show is that a CISO is not simply someone skilled in technology, but a role that bears both uncertain risk and responsibility at once. If so, even more reason is needed for a formal mechanism to confirm exactly what state was inherited.

Recent changes in overseas regulations also support this awareness.
The U.S. Securities and Exchange Commission (SEC) adopted its final 2023 cybersecurity disclosure rule. Listed companies must disclose cyber incidents within four business days after determining them to be material. Annual reports must explain the cyber risk management, strategy, and governance framework. This means a structure has been created in which management must explain to investors and the market how security is being managed. Security is no longer solely the job of an internal operations team; it has become a matter of management accountability.

Europe has gone a step further. The Network and Information Systems Directive 2 (NIS2) explicitly requires management and governing bodies to approve cybersecurity risk management measures and oversee their implementation. It also establishes a significant administrative penalty regime for violations. The Digital Operational Resilience Act (DORA) likewise makes the full and ultimate responsibility of the governing body for ICT risk management in finance explicit. 

In other words, the notion that “security is something the IT team handles” no longer holds institutionally, and the trend is that management accountability is being strengthened.

How should security due diligence be done on taking office to be effective?

So how should inauguration security due diligence be designed?
First, it must have independence. Internal reviews alone have limits to objectivity. An outside specialist should perform it, and the results should be formally reviewed at the management and board level.
Second, the scope must be broad and deep. Vulnerability scans or penetration tests of only some systems are not enough. To reveal the organization’s true state, you need to look at policy, asset management, authentication systems, backup and recovery, security operations, partner and supply chain risk, and security governance as well. 

Third, it must be left as an official record. This report should not be just a simple diagnosis; it should become a baseline. What vulnerabilities existed at the time of inauguration, what was set as the first priority to address, and how much improvement was made must all remain on record so the next assessment is possible. Only then can accountability be separated and investment priorities be set.

Above all, what matters is not viewing this procedure only as a defensive rationale. Inauguration security due diligence is not a document that says, “I will avoid responsibility.” Quite the opposite. 

It is a leadership declaration that says, “I will know the organization’s security state accurately and begin from there.” If there are problems, it is a promise to reveal them rather than hide them, and to improve by setting priorities. 

The same applies from the board’s perspective. Requiring a new CEO or CISO to undergo an external independent security review within a set period is not distrust; it is closer to a healthy management handover process.

A baseline is needed for accountability, investment, and improvement.

When onboarding security due diligence takes hold, three things change.
First, the starting point of accountability becomes clear. You can distinguish between issues accumulated since the predecessor’s tenure and those neglected under the current administration.
Second, discussions about security investment become far more realistic. That is because you can persuade the board and the CFO based on actual assessment results, not vague fear.
Third, security shifts from a one-time response to a continuous management system. The diagnostic results at the time of taking office become the baseline, and a virtuous cycle is created in which ongoing reviews measure whether improvements have been made.

Security is not something you look at after an incident occurs. What truly matters is making the state visible before an incident happens.

The first question needed for a new CEO and CISO may not be a flashy vision. Rather, this one sentence should come first.

“Do we really know the security status of our organization right now?”

Enki White Hat

Enki White Hat

Start-up College Adjunct Professor at Gachon University
Start-up College Adjunct Professor at Gachon University

Former desk member of the Electronic Newspaper ICT Convergence Department, active as a cyber security journalist and communication expert for 20 years.

Former desk member of the Electronic Newspaper ICT Convergence Department, active as a cyber security journalist and communication expert for 20 years.

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Copyright © 2025. ENKI WhiteHat Co., Ltd. All rights reserved.

Copyright © 2025. ENKI WhiteHat Co., Ltd. All rights reserved.

Copyright © 2025. ENKI WhiteHat Co., Ltd. All rights reserved.