Building a Cyber Risk Management Framework That Drives Resilience

Most organizations have cyber certifications. Fewer can confidently answer the board’s real questions:

• What are our top cyber risks right now?

• Are they prioritized consistently across the enterprise?

• Do we have credible plans to treat them and recover if they materialize?

According to PwC’s 2024 Global Digital Trust Insights:

• 39% of executives admit their organizations lack enterprise-wide visibility into cyber risks.

• 44% say compliance is still managed in silos, creating duplication across frameworks.

• Only 27% report having resilience or risk metrics available at the board level.

The reality: many firms are technically compliant but still unable to demonstrate their ability to withstand or recover from disruption.

This gap between certification and resilience is where most organizations struggle — and where cyber risk management frameworks must evolve.

Rising Global Expectations

Around the world, regulators and stakeholders are moving beyond certifications and demanding proof of risk-informed resilience.

In Europe, the Digital Operational Resilience Act (DORA) requires financial institutions to conduct risk-based ICT assessments and demonstrate continuity through resilience testing.

In the United States, the SEC now mandates disclosure of material cyber incidents within four business days, alongside expanded governance disclosures on risk oversight.

Across the Middle East, regulators are embedding resilience into national strategies, requiring organizations to prove business continuity, incident response readiness, and third-party oversight.

In Asia, Singapore’s MAS guidelines, Japan’s ISMAP framework, and Hong Kong’s HKMA Cyber Resilience Assessment all require organizations to show they can sustain critical services during disruption.

The trend is unmistakable: compliance is now table stakes — resilience, proven through credible risk assessments, continuity testing, and structured treatment plans, is the true differentiator.

Where Organizations Struggle

1. Siloed Cyber Risk

• Risks are tracked inconsistently across IT, compliance, and business units.

• Scoring methods vary, creating conflicting priorities.

• Boards receive technical updates, not business-aligned risk insights.

Result: Leadership lacks a clear, enterprise-wide view of cyber exposure.

Pros:

• Simple to establish within individual teams.

• Allows departments to track risks close to day-to-day operations.

Cons:

• Creates duplication and blind spots.

• Prevents consistent prioritization across the enterprise.

• Leaves boards with fragmented or misleading insights.

2. Integrated Risk Management

• Cyber risks are embedded within the Enterprise Risk Management (ERM) framework.

• Risk appetite and tolerance are defined at the board level.

• KRIs and KPIs track resilience across people, processes, and vendors.

Result: Cyber risks are prioritized consistently and treated alongside financial and operational risks.

Pros:

• Provides a unified view of risk for decision-making.

• Aligns cyber with enterprise strategy and board oversight.

• Enables consistent prioritization and smarter resource allocation.

Cons:

• Requires significant investment in governance, processes, and tooling.

• Can be complex to implement across global, multi-entity enterprises.

• Needs a strong risk-aware culture to avoid becoming bureaucratic.

3. Transitional (Hybrid) Model

• Risk registers exist but remain fragmented.

• Steering committees begin to engage, but metrics remain technical.

• Evidence is collected, but action plans are ad hoc.

Result: Progress is visible, but resilience remains unproven until cyber risk is fully integrated.

Pros:

• A realistic step for organizations moving from compliance-driven models.

• Encourages governance evolution through committees and early board engagement.

• Demonstrates initial maturity to regulators and investors.

Cons:

• Still leaves visibility gaps across the enterprise.

• Risk treatment is inconsistent, creating uneven resilience.

• Boards may still lack confidence in the organization’s ability to recover from disruption.

Case Study: Building Risk-Informed Resilience

A SaaS solution provider engaged Seen Group after recognizing that while it was compliant on paper, its risk management practices were fragmented and siloed. Each business unit tracked risks separately, using different scoring methods and criteria. As a result, leadership received inconsistent reports and had no consolidated view of cyber exposure.

Challenges Identified

• Fragmented risk registers: Each unit maintained its own register, with no central repository.

• Inconsistent prioritization: Similar risks were scored differently across units, creating confusion.

• No enterprise risk appetite: Cyber risks were not aligned with organizational risk tolerance.

• Limited board visibility: Reporting emphasized control completion, not actual exposure or resilience.

On paper, the company had achieved it's initial ISO certifications. In practice, it could not demonstrate resilience to either regulators or customers.

Our Approach

1. Consolidating Risk Registers

   1. We worked with business unit leaders to consolidate all siloed registers into a single enterprise-wide repository.

   2. Result: Reduced duplication, created a consistent scoring methodology, and provided a single source of truth for executives.

   3. Example: More than 200 fragmented risks were rationalized into 65 enterprise-level risks.

      
      

2. Enterprise Risk Assessment

   1. From the consolidated register, we conducted an enterprise-wide cyber risk assessment.

   2. Result: identified five top risks — ransomware, third-party outage, insider threat, cloud misconfiguration, and regulatory non-compliance.

   3. Quantification: Using the FAIR method, ransomware exposure alone was estimated at $12M annually, largely due to downtime and churn risk.

      
      

3. Defining Risk Appetite and Tolerance

   1. We facilitated executive workshops to define risk appetite statements (e.g., maximum acceptable downtime, tolerance for unmitigated third-party risk).

   2. Result: established board-approved thresholds that tied cyber directly to business strategy.

   3. Example: The board approved a tolerance of no more than 8 hours of downtime for customer-facing services — forcing targeted investment in recovery capabilities.

      
      

4. Developing Risk Treatment Plans

   1. For each top risk, we created structured treatment options and action plans with accountable owners:

      1. Ransomware: Automated backup recovery reduced recovery time objectives from 16 hours to 4 hours.

      2. Third-party outage: Introduced tiered vendor oversight and quarterly resilience attestations; risk exposure reduced by 30%.

      3. Cloud misconfiguration: Implemented CSPM (Cloud Security Posture Management), reducing misconfigurations by 45% within three months.

      4. Insider threat: Rolled out DLP (Data Loss Prevention) controls and monitoring playbooks; high-risk data movements dropped by 60%.

      5. Regulatory risk: Created a proactive compliance watchlist and regulator engagement process, reducing likelihood of late responses by 70%.

         
         

5. Embedding Metrics into Reporting

   1. We introduced board-level dashboards with KRIs and KPIs:

      1. Incident detection and recovery times (MTTD/MTTR).

      2. % of high-risk vendors reviewed and remediated.

      3. % of top risks with treatment plans tied to budget allocation.

      4. Residual risk trends across the enterprise.

Outcomes

Within six months, the SaaS provider:

• Consolidated 200+ siloed risks into a single enterprise register with unified scoring.

• Defined and approved cyber risk appetite and tolerances at the board level.

• Reduced high-priority exposures by over 40% through targeted treatments.

• Shortened ransomware recovery objectives from 16 hours to 4 hours, reducing financial exposure by millions.

• Embedded dashboards into board reporting, shifting the narrative from compliance status to resilience trends.

Most importantly: risk management became measurable and board-visible, transforming cyber from a checklist exercise into a business-aligned capability.

Key Insights for Leaders

• Compliance ≠ risk management — certifications don’t prove resilience.

• Boards need clarity, not checklists — risk appetite and tolerances must be explicit.

• Resilience requires action plans — identification without structured treatments leaves exposure unaddressed.

• Third-party risk is systemic risk — vendor outages can cascade into enterprise-level disruptions.

• Metrics build trust — regulators and boards rely on organizations that track and report risk trends over time.

Looking Ahead

The next frontier in cyber risk management will be defined by:

• Regulatory stress testing — organizations will be asked to prove continuity under simulated disruption.

• Cross-border harmonization — global supply chains will require cyber risk frameworks that meet multiple regulatory regimes.

• Real-time risk dashboards — boards will expect always-current KRIs, not static annual reviews.

• Resilience-by-design — forward-looking organizations will move from after-the-fact recovery to proactive resilience engineering.

Closing Thoughts

Every organization’s journey to cyber risk maturity is different, but the core principles remain the same:

• Clear governance and risk appetite.

• Integrated risk assessments and treatment planning.

• Continuous metrics and board visibility.

Seen Group helps organizations turn fragmented risk data into actionable, board-ready insights — building cyber risk management frameworks that drive measurable resilience.

Let’s start the conversation.