Complying with The Protection of Critical Infrastructures Bill

How Thales Helps with the Protection of Critical Infrastructures (Computer Systems) Bill Compliance in Hong Kong

What is the Protection of Critical Infrastructures (Computer Systems) Bill in Hong Kong?

On December 6th, 2024, the Hong Kong Government published the Protection of Critical Infrastructures (Computer Systems) Bill ("Bill") in gazette to enhance cybersecurity standards for essential services and critical societal or economic activities in Hong Kong. The Bill aims to protect the security of the critical computer systems (CCS) of critical infrastructures (CIs), to regulate CIs’ operators (i.e., critical infrastructure operators (CIO) and to provide for the investigation into, and response to, computer-system security threats and incidents.

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    • To ensure the computer system security of critical infrastructure that are necessary for the normal functioning of the Hong Kong society.
    • To strengthen the security of the computer systems of critical infrastructure and minimize the chance of essential services being disrupted or compromised due to cyberattacks.

    The regulation covers two major categories of critical infrastructure (CI):

    Infrastructures for delivering essential services in Hong Kong covering eight sectors:

    • Energy
    • Information Technology
    • Banking and Financial Services
    • Land Transport
    • Air Transport
    • Maritime
    • Healthcare Services
    • Communications and Broadcasting

    Other infrastructures for maintaining important societal and economic activities:

    Examples:

    • Major sports
    • Performance venues
    • Research and development parks

    Critical Computer Systems (CCS) 
    CCSs refer to computer systems that are relevant to the provision of essential service of the core functions of computer systems, and those systems which, if interrupted or damaged, will seriously impact the normal functioning of the critical infrastructure.

    Critical Infrastructure Operators (CIO) 
    Designated operators which operate a Specified CI.

    CIO will need to fulfill three types of obligations below:

    Organizational

    • Maintain an address and office in Hong Kong
    • Report changes in the ownership and operatorship of CI
    • Set up a computer system security management unit with professional knowledge supervised by a dedicated supervisor of the CIO

    Preventive

    • Inform the Commissioner’s Office of material changes to their CCS
    • Formulate and implement a computer system security management plan
    • Conduct a computer system security risk assessment and audit (at least once every year and two years respectively)
    • Adopt measures to ensure that their 3rd-party services providers are in compliance with the relevant statutory obligations

    Incident Reporting and Response

    • Participate in a computer system security drill (at least once every two years)
    • Formulate an emergency response plan
    • Notify the Commissioner’s Office of the occurrence of computer system security incidents in respect of CCS

    The codes of practice (CoPs) are issued in respect of CIO obligations to set out recommended standards and provide practical guidance to CIOs to fulfil the obligations.

    Regulatory authorities 
    The Chief Executive of Hong Kong will appoint a new Commissioner of Critical Infrastructure (Computer-system Security), who, along with the designated authorities in Schedule 2 of the CI Bill for specific sectors (currently the Monetary Authority and the Communications Authority), (“Designated Authorities”), will serve as the regulating authorities.

    Concerning the relevant legislation of the UK and EU, the penalties under the Bill will only include fines, with maximum level ranging from HK$500,000 to HK$5 million, and additional daily fines for persistent non-compliance for certain continuing offences, the maximum of which range from HK$50,000 to HK$100,000.

    The obligations and requirements under the Bill which will result in offences and penalties for non-compliance will be imposed on CIOs at the organizational level only, and are not designed to target at their staff at individual level.

    Jun 25, 2024
    Protection of Critical Infrastructures (Computer Systems) Bill was proposed.

    July 2, 2024
    Tabled legislative proposal to the Legislative Concul Panel on Security for consultation.

    Aug 1, 2024
    Consultation period ends.

    Oct 8, 2024
    Published consultation report.

    Dec 6, 2024
    The Bill was gazetted.

    2025
    Commissioner's office to be setup within one year after legislation.

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    Complying with The Protection of Critical Infrastructures Bill in Hong Kong

    Explore solutions for The Protection of Critical Infrastructures (Computer Systems) Bill (CI Bill) by simplifying compliance and automating security reducing the burden on security and compliance teams.

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    How Thales Helps with the Protection of Critical Infrastructures (Computer Systems) Bill Compliance

    The Protection of Critical Infrastructures (Computer Systems) Bill (CI Bill) strengthens the cybersecurity of critical infrastructure and minimize disruption of essential services in Hong Kong; Thales’ solutions can help CIOs address the requirements in Bill by simplifying compliance and automating security reducing the burden on security and compliance teams.

    Protection of Critical Infrastructures (Computer Systems) Bill Compliance

    Protection of Critical Infrastructures Bill Compliance Solutions

      Application Security

      Protect applications and APIs at scale in the cloud, on-premises, or in a hybrid model. Our market leading product suite includes Web Application Firewall (WAF), protection against Distributed Denial of Service (DDoS) and malicious BOT attacks, security for APIs, a secure Content Delivery Network (CDN), and Runtime Application Self-Protection (RASP).

      Data Security

      Discover and classify sensitive data across hybrid IT and automatically protect it anywhere, whether at rest, in motion, or in use, using encryption tokenization and key management. Thales solutions also identify, evaluate, and prioritize potential risks for accurate risk assessment as well as identify anomalous behavior, and monitor activity to verify compliance, allowing organizations to prioritize where to spend their efforts.

      Identity & Access Management

      Provide seamless, secure and trusted access to applications and digital services for customers, employees and partners. Our solutions limit the access of internal and external users based on their roles and context with granular access policies and Multi-Factor Authentication that help ensure that the right user is granted access to the right resource at the right time.

      Address the requirements in CI Bill – The codes of practice (CoPs)

        How Thales helps:

        • Monitor I/O and block suspicious activity before ransomware can take hold.
        • Prevent malicious software and users from accessing sensitive data.
        • Use signature, behavioral and reputational analysis to block all malware injection attacks.
        • Detect and prevent cyber threats with web application firewall.
        • Safeguard critical network assets from DDoS attacks and Bad Bots.

        How Thales helps:

        • Protect application data and eliminate the need for Developers (Devs) to manage security and update data protection.
        • Deploy data protection solutions into environments through orchestration.
        • Perform updates and keep up with compliance requirements by Data Security Admins without taking Devs off of other projects.
        • Adopt “Shift left” – Security measurement in the early stage of development.

        Solutions:

        Data Security

        DevSecOps

        How Thales helps:

        • Discover and classify potential risks for all public, private, and shadow APIs.
        • Identify structured and unstructured sensitive data at risk on-premises and in the cloud.
        • Enable privileged user access control for sensitive data and restrict access from unauthorized access with the least privileged design.
        • Identify the current state of compliance, documenting gaps, and providing a path to full compliance.
        • Gain full sensitive data activity visibility, track who has access, audit what they are doing and document.

        How Thales helps:

        • Limit the access of internal and external users to systems and data based on roles and context with policies.
        • Apply contextual security measures based on risk scoring.
        • Prevent password fatigue with Smart Single Sign-On with conditional access.
        • Centralize access policies and enforcement to multiple hybrid environments in a single pane of glass.
        • Prevent hardcoded credentials or token keys in source code or CI/CD environments.

        How Thales helps:

        • Provide flexible authentication options for automated workflows to mitigate the reliance on passwords.
        • Extend single-sign-on authentication to cloud applications, enabling centralized, secure access with a protected identity.
        • Apply privileged access control to sensitive data.

        Solutions:

        Identity & Access Management

        Workforce Access Management

        Data Security

        Transparent Encryption

        How Thales helps:

        • Protect cryptographic keys in a FIPS 140-3 Level 3 environment.
        • Streamline key management in cloud and on-premises environments with key lifecycle management.
        • Manage and protect all secrets and sensitive credentials.
        • Store encrypted data and its encryption key stored in different places for separation of duties principal.
        • Adopt Post-Quantum Agility to deal with the threats from quantum computing.

        How Thales helps:

        • Leverage smart cards for implementing physical access to sensitive facilities of critical infrastructure.
        • Protect the root-of-trust of a cryptographic system within a highly secure environment.

        Solutions:

        Identity & Access Management

        Smart cards

        Workforce Access Management

        Data Security

        Hardware Security Modules

        How Thales helps:

        • Detect and prevent cyber threats with web application firewall, ensuring seamless operations and peace of mind.
        • Safeguard critical network assets from DDoS attacks and Bad Bots while continuing to allow legitimate traffic.
        • Secure data-in-transit with future-proof encryption technologies to avoid “Harvest now, decrypt later”.

        How Thales helps:

        • Protect apps from runtime exploitation, while integrating with tools in the CI/CD pipeline.
        • Detect and prevent cyber threats with web application firewall.
        • Safeguard critical network assets from DDoS attacks and Bad Bots while continuing to allow legitimate traffic.
        • Encrypt sensitive data once it is created and make sure cleartext data will not be processed or stored by unauthorized applications and personnel.
        • Protect and automate access to secrets across DevOps tools.
        • Easily access data security solutions through online marketplaces.
        • Monitor data traffic to spot data leakage risk.

        How Thales helps:

        • Reduce third-party risk by maintaining on-premises control over encryption keys protecting data hosted in the cloud.
        • Ensure complete separation of roles between cloud provider admins and your organization, restrict access to sensitive data.
        • Monitor and alert anomalies to detect and prevent unwanted activities from disrupting supply chain activities.
        • Enable relationship management with suppliers, partners or any third-party user; with clear delegation of access rights.
        • Minimize privileges by using relationship-based fine-grained authorization.
        • Enable MFA for third-party users to thwart phishing attacks.
        • Apply sufficient secure measurement with the sensitivity of data.
        • Protect network tunnel between cloud and on-premises environment to ensure data is encrypted.

        Other key data protection and security regulations

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        The PCI HSM specification defines a set of logical and physical security compliance standards for HSMs specifically for the payments industry. PCI HSM Compliance certification depends on meeting those standards.

        DORA

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        REGULATION | ACTIVE NOW

        DORA aims to strengthen the IT security of financial entities to make sure the financial sector in Europe is resilient in the face of the growing volume and severity of cyber-attacks.

        Data Breach Notification Laws

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        REGULATION | ACTIVE NOW

        Data breach notification requirements following loss of personal information have been enacted by nations around the globe. They vary by jurisdiction but almost universally include a “safe harbor” clause.

        GLBA

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        The Gramm-Leach-Bliley Act (GLBA)--also known as the Financial Services Modernization Act of 1999--requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data.

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