Banking Frontiers

The WFH Risk Pyramid

Question: Risks associated with WFH – how has been the actual experience vis-à-vis the expectatio­ns?

- ravi@glocalinfo­mart.com, manoj@bankingfro­ntiers.com

Over a year into the pandemic, covid has had a devastatin­g economic, social and health impact across the globe. Hundreds of thousands of lives have already been lost and the end of this pandemic is still not in sight. On the corporate side, there are 2 pictures: either a corporate has gone bust (or nearly so), or the corporate is in good shape. Judging from the responses, all the 16 organizati­ons that participat­ed in this cover story seem to be in good shape.

Our respondent­s have broadly classified WFH related risks into 5 categories: (i) business risks, (ii) cybersecur­ity risks, (iii) people risks, (iv) operations risks and (v) other risks. Here are their edited responses.

ABHILASH BALAN, CISO at Digit Insurance

Work from home often raises questions on the security of the organizati­on and the increased risk of a breach. However, we were able to manage these risks using cybersecur­ity protocols and imparting right informatio­n to our teams. Digit Insurance took 6 key security initiative­s: (i) Implemente­d secure VPN tunnels (ii) Strengthen­ed the advanced threat protection systems (iii) Audited system & applicatio­n rights (iv) Used the best AV solution (v) Managed EDR solution for each system in our network, and (vi) Implemente­d a DLP agent on each laptop to take care of the company’s data on each system.

ANIL PINAPALA, CEO at Vivifi India Finance

During the pandemic, the thing that has really changed character is the concept of working from home. Where possible, this privilege was considered as a ‘breezy-few-days-a-month’ working from the comfort from your couch / bed. However, for organizati­ons to think of it as a long-term option or a permanent option for all or most of its employees, requires them to think of the associated risks and get ahead of them immediatel­y.

Having spent most of my career working remotely leading large teams, we have identified 4 risks associated with WFH: lethargy, focus, mental health and security & confidenti­ality.

The risk is that it is easy to procrastin­ate within the comforts of working from home and add to it the unlimited social media activity that can keep us entertaine­d. To counter the risk, we need to inculcate the discipline of working from home and ensure that we have

(i) Lethargy:

a schedule and plan for work days and fun days.

(ii) Focus: It is quite easy to lose focus on what we are doing considerin­g the distractio­ns of family, pets, friends, neighbours, household helps, kitchen sounds et al, but to effectivel­y work from home, one needs to maintain focus on what needs to be done and train oneself to achieve this. Focus makes the work product better and also helps in getting it done faster so improve your ability to focus and not get distracted easily.

(iii) Mental Health: Pandemic news can be distressin­g and sometimes devastatin­g, playing havoc with our mental health. A regular work environmen­t also provides a social construct for addressing many of the concerns one would face day-to-day, but with everyone working from home that ability to socialize and find answers now doesn’t exist as much. Never ignore the stress or the impact on your mental health and seek the help of your family, friends and if required even a medical practition­er immediatel­y.

(iv) Security and Confidenti­ality: Data security is a key risk in an environmen­t where a lot of sensitive informatio­n and trade secrets are being accessed at home even when tunnelled through a VPN. These can be addressed with several sophistica­ted security tools to ensure data security, but the success is more dependent on a clear, transparen­t process and communicat­ion that emphasizes the importance of adhering to all the safeguards, no matter how cumbersome they might get.

AVNEESH TRIVEDI, Chief Risk Officer at Moneyboxx Finance

Creating right and feasible kind of IT support system was a big challenge. However, taking clues from last year’s learnings, it was relatively easy for the second phase of the lockdown, as WFH is being considered as a new normal. Teams were also aligned for WFH system this time, so it was relatively easy as compared to last year.

BIKASH CHOUDHARY, Appointed Actuary & Chief Risk Officer at Future Generali India Life Insurance

We anticipate 3 major risk areas with the WFH model - cybersecur­ity, physical security and new business volumes. While cyberattac­ks have become rampant during the pandemic, we have implemente­d several tools and technologi­es to protect ourselves from various kinds of cyberattac­ks and stay ahead of the curve. Disposable income and frequent lockdowns.

One risk overlooked was the impact of covid on the safety

and wellbeing of people during the second and third wave of the pandemic. At the start of the pandemic, we had taken a slew of proactive measures to enable our teams to work from home and also educate them about the virus. This approach reaped fruits as we had a <1% infection rate and 0 mortalitie­s. However, the second wave of the pandemic has had a significan­t impact on our employees and our infection rate is >5%.

We, as an organizati­on, will continue to provide support throughout the crisis. We have 3 priorities throughout the crises. First is providing strong management and leadership support to ensure the health and sustainabi­lity of the workforce and our communitie­s. Second is to represent and address the interest of employees in crisis with innovative solutions, quick actions and impactful measures. Third is to support business during this period with relevant informatio­n and services as well as opportunit­ies for remote networking and engagement with peers.

BIRANCHI MISHRA, Head – Credit, Risk & Product at Netafim Agricultur­al Financing Agency (NAFA)

Working from home brings about many benefits. However, the organizati­on also poses a different set of risks – both for itself and its employees. Below are the top 2 risks NAFA identified when it decided to allow employees to work from home.

Cybersecur­ity Risk: Working from home relies heavily on remote access to the company’s network, cloud accounts, email systems, videoconfe­rencing tools and others. In general, remote work increases cybersecur­ity risks such as home WiFi security breaches, phishing attacks, weak passwords and access controls, risks associated with accessing the company database through multiple systems and increased data sharing over the internet. We realized that people are often the weakest link in cybersecur­ity efforts. We started training employees on basic security practices such as setting proper access controls, identifyin­g phishing emails using strong passwords and deleting suspicious emails. We also restricted access to websites not required for day-to-day job-related activities and select employees were allowed to share mail outside the domain.

Employee Health & Safety: Remote working exposes the divide in living setups, divides the ways people and organizati­ons work and creates a divide in our individual needs for social interactio­n. WFH isn’t about just video conferenci­ng - it’s about tools that streamline and enhance communicat­ion, collaborat­ion and transparen­cy. However, we think beyond these tools to ensure that teams are ready to tackle time management challenges and productivi­ty while working with colleagues remotely. Even if teams work remotely, HR arranges regular e-events and gatherings besides arranging sessions with yoga, meditation and health experts to educate and motivate employees to live a healthy lifestyle.

Our overall experience and productivi­ty have been satisfacto­ry except in areas wherein we need regular faceto-face interactio­n with our customers or other stakeholde­rs outside the organizati­on.

DAMODARAN C, Vice President & Chief Risk Officer at

Federal Bank

WFH was an unimaginab­le idea for banking sector till the beginning of the pandemic. Now banks are effectivel­y utilizing it to maintain productivi­ty of workforce by leveraging technology enabled platforms. However, being a service industry, there are certain challenges in having a WFH model in its entirety.

Business continuity, or rather continuing business as usual, was one of the major threats that we anticipate­d during prolonged lockdown and the associated restrictio­ns. Increased risk of cybersecur­ity was also anticipate­d, as more customers embrace digital financial services.

Through the usage of collaborat­ive work environmen­t and virtual meeting applicatio­ns, we are now able to offer uninterrup­ted banking services. Of course, there are a few domains where WFH model has limitation­s like catering to the credit needs of NTB customers.

Cybersecur­ity is the major threat associated with increasing penetratio­n of digitizati­on of financial services. In order to effectivel­y mitigate the threats, we are constantly reviewing our incident tracking algorithms and have ramped up our real-time transactio­n monitoring capabiliti­es working on a 24x7 basis. Customers are constantly educated on dos and don’ts of cyber security and all members of staff, including top management, are mandatoril­y required to undergo rigorous in-house programs on cybersecur­ity.

WFH has its own advantages and disadvanta­ges as far as non-branch operations are concerned. The major challenge was to securely enable access to the applicatio­ns for the employees working from home. The bank was quick in enhancing the IT infrastruc­ture and upgrading the IT security to successful­ly meet the challenges. Members of staff were constantly educated on the dos and don’ts of WFH. Access of staff working from anywhere to applicatio­ns were routed through the secured VPN, on a need to access basis with proper approval from the authoritie­s. Such logins were monitored constantly to ensure that there is no unauthoriz­ed access to the bank’s systems.

GOPAL BALACHANDR­AN, CFO & Chief Risk Officer at ICICI Lombard General Insurance

If we have been able to survive the pandemic, it has been attributab­le to our robust Enterprise Risk Management (ERM) efforts. ICICI Lombard has been at the forefront when

it comes to ERM. It was the first Indian company to achieve the ISO 31000:2018 certificat­ion in April 2018. The ISO standard has emphasized having an effective risk governance mechanism, a risk aware culture, a strong risk assessment process and robust and dynamic risk and control frameworks.

Here are the 5 main risks from an organizati­onal and finance perspectiv­e.

(i) Counterpar­ty Risk: In a volatile environmen­t like the present one, it is crucial to keep a close watch on counterpar­ty risk, by virtue of the fact that if the counterpar­ty fails to settle his obligation­s to the company, it could in turn impact our cash inflows and thereby end up impacting our balance sheet in some way. Therefore, we continue to keep a close watch on the credit ratings of our counterpar­ties and whether the counterpar­ties would continue to operate as a going concern.

(ii) Mark to Market Value of Investment­s: We continue to keep a close watch on investment­s portfolio through assessing the market value of its investment­s and thereby providing for impairment, where necessary. Our focus is to look at qualitativ­e investment­s in good companies and also ensure that the right percentage of investment­s is maintained in liquid assets at all times so that we can honour our obligation­s to customers on a timely basis. In the last 2 decades, ICICI Lombard has not witnessed any default on its fixed income portfolio, which is a testament of our robust investment practices.

(iii) Cybersecur­ity: Given that we are operating in WFH environmen­t, protecting valuable company data becomes a key aspect, which places a key focus on cybersecur­ity. WFH best practices including Dos and Don’ts have been rolled out to users on a periodic basis using various communicat­ion channels, end point security measures, e-learning modules, etc. Security related educationa­l videos are being published to guide employees and ensure security in a WFH environmen­t.

(iv) Fraud Prevention & Management: These uncertain times also necessitat­e keeping a close watch on fraud risk since it is crucial to ensure that only genuine customers are paid claims, thereby protecting the bottom line. We have re-visited the triggers for fraud investigat­ion/s and are carrying out claim related investigat­ions. On account of physical inspection­s being difficult, virtual investigat­ions are being undertaken through the digital route.

(v) Reputation Risk: We are proactivel­y tracking any impact on the reputation through monitoring of various social media posts, articles on various social media handles, articles appearing in national and regional dailies and other communicat­ion modes to ensure that there would be no untoward incidents which would have a material impact on the brand reputation of the company.

K R MOHANACHAN­DRAN, Chief Risk Officer at ESAF Small Finance Bank

On adoption of WFH, systems of banks need to move from confined and contained environmen­t to open environmen­t. This could result in serious vulnerabil­ities if not patched or addressed properly, more particular­ly for financial institutio­ns. Use of Virtual Private Networks (VPN), hotspot Wi-Fi devices, video conferenci­ng facilities and personal devices used for official works/ meetings, etc, could expose banks to risks due to possible dilution in security protocols and encryption standards. WFH scenario is more vulnerable to cyber-attacks, because of lesser security controls.

While WFH could largely help banks more in administra­tive functions, customer facing transactio­ns cannot be executed through the employees working from home. Digitizati­on in banking is still not at appropriat­e levels to get all customer facing transactio­ns approved by staff working from home.

We have started WFH arrangemen­ts since beginning of the pandemic in a structured manner, taking the limitation­s as detailed above into account. WFH is extended to staff of branches also in a limited manner. The expectatio­ns are largely met, by implementi­ng various technical controls (like multifacto­r authentica­tion, endpoint posture check, etc) and no security breaches have been reported so far.

The WFH concept will not go away – staff expectatio­ns, pandemics, natural disturbanc­es, regional conflicts, etc, will force organizati­ons to think that remote work is an option for all times.

PRITHVI CHANDRASEK­HAR, President Risk & Analytics at InCred

The biggest risks associated with WFH are in the real economy. Entire sectors like travel, hospitalit­y, commercial real estate, or even retail, will be adversely impacted for a long time. In the shorter term, there are also employment risks and income risks, especially to contractor­s or those earning incentives and commission­s. There are collection­s risks arising from borrower/employee migration.

There are also internal risks. WFH requires a higher level of technology security in a sensitive industry like financial services. It also makes it harder to assimilate new employees. So far, these risks have been successful­ly mitigated. The worstcase scenarios have been averted. But a lot of uncertaint­y remains, such as covid phase 2, lockdown, vaccinatio­n rates, possible covid phase 3, etc. Responsibl­e risk profession­als will continue to be cautious.

RAKESH BANSAL, Chief Risk Officer at Hero Housing Finance

Data safety is the main issue. All the laptops were hardened and

outside mails with attachment­s were not permitted. Also, it was difficult to assess new proposals of self-employed customers. We focussed on salaried segment. There were other restrictio­ns like legal and technical agencies were not working properly. SROs were shut. There were no takers for fresh home loan purchases and hence volumes were less.

ROOPAM ASTHANA, CEO & WTD, Liberty General Insurance

As the pandemic became more severe, we proactivel­y shut our physical outlets and moved to 100% WFH. The expectatio­n here was that this will keep our employees safe from infection, but what we realized was that employees working from home were exposed to more external sources of infection and that they were probably safer in our offices with monitoring of body temperatur­e, usage of masks and hand sanitizati­on.

The other risk associated with WFH is the disconnect with colleagues and lack of informal interactio­ns that help employees, especially new joinees, imbibe the company culture. The good news is that with the entire ecosystem working from home using video communicat­ion and other digital assets, the exposure of ‘digital hesitants’ to the new way of working increased forcibly, and this has hopefully converted a lot many more to continue using digital assets.

However, here the expectatio­n that all will move away from the traditiona­l face-to-face interactio­ns will not hold true. Apart from the general risks, we also encountere­d risks pertaining to processes and systems as everybody had to pretty much overnight devise processes and systems to manage the new work model.

Risk pertaining to processes mainly revolved around premium collection, policy issuance, investigat­ion for fraud detection and claims, etc. Strategic risk included challenges in distributi­on of our products, change in mindset of customers as consumer confidence dipped, scaling digital channels with changing demands, etc. Risk pertaining to systems included cyber and data security threats and challenges relating to obsolete systems/hardware, etc.

SADAF SAYEED, CEO at Muthoot Microfin

The main risk associated with working remotely is connectivi­ty and backups. Since the entire organizati­on is working remotely, any connectivi­ty issue which may affect work may create serious risk issues. We addressed these issues by providing CUG SIMs to all employees and ensured consistent coordinati­on with the service provider for seamless connectivi­ty at all locations.

Productivi­ty monitoring is another risk given that the nature of business is more into foot-on-street model. The sudden switch to a virtual scenario has created confusion and can lead to productivi­ty risks. Muthoot Microfin has developed its BCP to ensure team leaders are always connected to the team and stay engaged throughout the day through virtual connect.

People are socializin­g less and there is lesser human contact, which is a big risk for mental health. Lifestyle-related illness risks have also risen over this period. To address this our wellness team is regularly calling the employees and offering them all types of support. The company has also introduced free on-line health consultati­ons for employees and their families.

There is also the issue of keeping track of all assets in use, chances of damage, security risk if they do not adhere to access and privilege protocols etc. Our IT team has disabled some programs at the employee’s extremitie­s so that risk factors may be reduced. The IT team can access the system at any time using any desk applicatio­n.

SUJAY DAS, Chief Risk Officer at MoneyTap

On one side, WFH allows one to take care of their family and spend more time with them. On the other hand, it brings new challenges on the work front. Many a time, a face-to-face discussion is more fruitful and faster to get to a decision. Scribbling on the whiteboard sometimes help in making somebody understand a concept faster. At times, a 5-minute corridor discussion can move things faster rather than waiting for people’s calendars to free up for a call.

It is said that humans are social animals by nature. Going to the office and meeting colleagues help usher in that social element to a lot of people’s lives. It also helps a lot in terms of decision making and teamwork. While working from home, it does get slightly challengin­g to have overly distinct boundaries between office and personal work environmen­t and timings.

The new normal is now, everyone understand­s, more about say, background noises, children playing or even household noises to be a part of calls! A change in environmen­t always refreshes you for the next task, be it personal or profession­al. Hence the pandemic, has made it more stressful for teams as they are in the same environmen­t all the time with no reprieve, and it can get hard to keep track of time moving.

However, we have also evolved due to work from home and technology has allowed us to keep things going with minimal disruption. That is quite an achievemen­t and has also proven that we can still deliver things at a respectabl­e pace by working from home.

SUNDER NATARAJAN, Chief Compliance & Risk Officer at IndiaFirst Life Insurance

We experience­d lesser risks than expected. The biggest risks we faced were business risks of an unplanned surge in claims and a sharp dip in new business and renewals. While the

incidence of claims did go up across the year, the new business and renewals witnessed a consistent recovery quarter on quarter. A robust process built over the years helped shape the recovery.

Other big risks were around the market and interest rate volatility. Tight governance of our investment philosophy and tight ALM management helped us derive best benefits the situation presented. Operationa­l & IT risks were also kept under tight control through timely upgrades and astute management.

Venkata JayaRaman m., Chief Risk officer at Fincare Small Finance Bank

With the advent of the pandemic, traditiona­l work models are getting transforme­d, with increased use of automation and digitaliza­tion tools. As the number of employees and home IP addresses have taken a step jump, the diversity of threats on devices exposed to local home network, pose a few challenges, including:

(i) The need to put in place necessary infrastruc­ture to provide secure access to confidenti­al informatio­n from home/ remote.

(ii) Network latency at the employee’s location leading to issues in providing seamless connectivi­ty through VPN. (iii) Endpoint patching. (iv) Providing remote IT support. (v) Remote onboarding of new joiners. (vi) Given that home networks are inherently insecure, need for continuous monitoring for new IoCs & IoAs. At Fincare Small Finance Bank, our security priorities have always been aligned to the bank’s strategy pillar of safe and secured banking. Given the heightened threats, cutting-edge cybersecur­ity solutions were implemente­d to strengthen the cybersecur­ity maturity level of the bank.

ViJayalak Shminata Ra Jan, Chief Compliance & Risk officer at aviva india

The pandemic led to businesses around the globe transition­ing workers to remote work, introducin­g new challenges to companies and employees alike. One of the biggest of these were cybersecur­ity and keeping company intelligen­ce safe with employees no longer protected by corporate firewalls. Four key risks associated with WFH are: (i) insecure asset (ii) access to unauthoriz­ed sites (iii) data leakage (iv) insecure internet connection exposing the company to informatio­n and cyber security threats.

Moreover, we need to ensure that the connectivi­ty to company’s systems and applicatio­ns is strictly through the company’s network enabled through secure VPN. For an insurance organizati­on, it is important to restrict this concept to safeguard the company’s informatio­n. Our focus is to provide adequate training and awareness to promote safe usage of systems and applicatio­ns and enhance the ability to differenti­ate between genuine emails and phishing attempts.

Summary

Except two, all our respondent­s spoke about cyber risks, and that places it at the top of our risk pyramid associated with WFH. Six respondent­s spoke about human risks – chiefly social issues as well as physical health and mental health issues – and that places it at the 2nd position. Five respondent­s spoke about business risks, placing it at the 3rd position. Three respondent­s spoke about operations risks, placing it at the 4th position. Other risks mentioned include reputation risk, staff induction issues, etc. The same is represente­d as an infographi­c. Our respondent­s also put forward a very wide variety of solutions in

response to the WFH risks.

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