Who Acts as the Responsible Agency for Cybersecurity Inside a Company?

Table of Contents

• What Is the “Responsible Agency” in Cybersecurity?
• Why Clear Responsibility Matters
• The CISO: The Captain of the Ship
• The CEO and Board: The Ultimate Owners
• The IT Team: The Engine Room
• HR and Employees: The First Line of Defense
• Legal and Compliance Teams: The Rule Keepers
• Third-Party Vendors and MSSPs: The External Allies
• Who Takes Charge in Small Organizations?
• Indian Laws and Who They Hold Accountable
• How to Build Your Internal Cybersecurity Agency
• RACI Matrix: Who Does What?
• Real Indian Case Studies
• Common Mistakes in Assigning Responsibility
• Future-Ready Cybersecurity Leadership
• Conclusion
• FAQs

What Is the “Responsible Agency” in Cybersecurity?

The “responsible agency” is not one person. It’s a network of roles with clear duties, authority, and accountability for protecting the company from cyber threats.

• It includes strategy, execution, training, and response.
• It aligns with laws like DPDP Act, IT Rules, and RBI guidelines.
• It scales: a 5-person startup may have one owner. A bank has a full CISO team.

Think of it as a cricket team: the captain (CISO) leads, but every player has a role.

Why Clear Responsibility Matters

Without clarity, chaos wins.

• Delayed response: Average breach detection in India: 280 days (IBM, 2025).
• Blame game: “I thought IT handled backups.”
• Legal risk: DPDP Act holds “data fiduciaries” liable. Who is that?
• Cost explosion: Uncoordinated recovery costs 3x more.

A defined agency cuts response time by 70% (Gartner).

The CISO: The Captain of the Ship

CISO = Chief Information Security Officer. The central figure in large firms.

• Reports to CEO or board (not CIO, to avoid conflict).
• Creates strategy, manages tools, leads incident response.
• Trains staff, liaises with CERT-In, runs drills.
• Needs budget, authority, and board access.

In India, RBI mandates CISOs for banks. SEBI requires them for listed firms.

The CEO and Board: The Ultimate Owners

Cybersecurity is a business risk, not just IT.

• CEO approves budget and strategy.
• Board oversees risk via audit committee.
• Must understand cyber in simple terms: “What keeps us up at night?”
• Signs off on incident communication.

Global trend: 40% of boards now have a cyber expert (Deloitte, 2025).

The IT Team: The Engine Room

IT executes the CISO’s plan.

• Patches systems, manages firewalls, monitors logs.
• Sets up MFA, encryption, backups.
• Supports employees with secure tools.
• Reports to CISO, not the other way around.

In small firms, the IT head wears the CISO hat.

HR and Employees: The First Line of Defense

90% of breaches start with a click.

• HR creates security policies in onboarding.
• Employees follow rules: strong passwords, no USBs, report phishing.
• Run monthly phishing simulations.
• Reward vigilance: “Employee of the Month” for spotting fakes.

A trained receptionist once stopped a ₹10 crore fraud by questioning a fake invoice.

Legal and Compliance Teams: The Rule Keepers

They translate laws into action.

• Ensure DPDP, GDPR, RBI compliance.
• Draft DPAs with vendors.
• Handle breach notifications (72 hours to users).
• Manage cyber insurance claims.

Third-Party Vendors and MSSPs: The External Allies

You’re only as strong as your weakest vendor.

• MSSPs (Managed Security Service Providers) act as virtual CISOs.
• Seqrite, Paladion, or Quick Heal offer 24/7 monitoring.
• Cloud providers (AWS, Azure) share responsibility.
• All must sign SLAs with clear cyber duties.

Who Takes Charge in Small Organizations?

No CISO? No problem.

• Owner/CEO: Owns risk. Sets tone.
• IT Lead or Freelancer: Handles tools and patches.
• MSSP: Acts as external CISO (₹50k–2 lakh/month).
• All Employees: Trained via free CERT-In modules.

Even a 3-person team can have a 5-page responsibility chart.

Indian Laws and Who They Hold Accountable

Laws name specific roles.

• DPDP Act: “Data Fiduciary” (usually CEO) is liable.
• IT Rules: “Significant Data Fiduciary” must appoint India-based officer.
• RBI: Banks need CISO, reporting to MD.
• CERT-In: Mandates 6-hour breach reporting by “point of contact.”

How to Build Your Internal Cybersecurity Agency

Follow this 7-step plan:

• Step 1: Appoint a cyber lead (CISO, IT head, or MSSP).
• Step 2: Define roles in a RACI matrix.
• Step 3: Get board/CEO sign-off.
• Step 4: Allocate budget (1–3% of IT spend).
• Step 5: Train everyone (use Cyber Swachhta Kendra).
• Step 6: Test with drills quarterly.
• Step 7: Review roles annually.

RACI Matrix: Who Does What?

R = Responsible, A = Accountable, C = Consulted, I = Informed

Real Indian Case Studies

Case 1: Fintech with CISO (Saved)

• CISO detected phishing in 11 minutes.
• IT isolated segment. HR sent alert. Legal notified users.
• Zero data loss. Trust intact.

Case 2: Retail Chain without Clarity (Failed)

• IT thought vendor managed backups. Vendor thought IT did.
• Ransomware hit. No recovery. ₹7 crore loss.

Common Mistakes in Assigning Responsibility

• Making IT the scapegoat: “It’s their fault.”
• No board oversight: Cyber never discussed in meetings.
• CISO reports to CIO: Conflict of interest.
• Employees not trained: “We sent one email.”

Future-Ready Cybersecurity Leadership

By 2030:

• CISOs will report directly to boards in 80% of firms.
• AI will flag risks, but humans decide.
• DPDP Board (DPBI) will audit personal accountability.
• MSSPs will be standard for SMEs.

Conclusion

Cybersecurity is a team sport. The “responsible agency” is not one hero. It’s a chain of command: from the CEO who owns the risk, to the CISO who leads the charge, to the IT team that executes, to the employee who spots the phishing email. In India, laws like DPDP and RBI are clear: someone must answer. Use the RACI matrix. Start small. Train everyone. The edtech startup in Pune? After collapse, the founder rebuilt with a virtual CISO and clear roles. Now they train 50,000 students securely. Your company can do the same. The next breach is coming. The question is: Who will lead your defense? Assign it today.

FAQs

Who is ultimately responsible for cybersecurity?The CEO and board. They own the risk and budget.

Do small companies need a CISO?

No. The owner or IT lead can act as one. MSSPs help.

Can the CIO be the CISO?

Not ideal. It creates conflict. CISO should be independent.

Does DPDP Act name a specific role?

It holds the “data fiduciary” (usually CEO) accountable.

Who reports breaches to CERT-In?

The designated point of contact, usually CISO or IT head.

Should HR be involved in cyber?

Yes. They train, enforce policies, and manage access.

What if we use an MSSP?

They execute, but you remain accountable.

Does the board need cyber training?

Yes. At least annually. Use NASSCOM modules.

Who approves the cyber budget?

CEO and board, based on CISO’s proposal.

Can employees be held liable?

Rarely, unless gross negligence (e.g., sharing passwords).

Who runs phishing drills?

CISO or HR, with IT support.

Does RBI mandate a CISO?

Yes, for all banks and NBFCs.

Who signs vendor DPAs?

Legal team, reviewed by CISO.

Can a freelancer be the cyber lead?

Yes, for small firms. Define scope in contract.

Who communicates during a breach?

CISO drafts, CEO approves, PR sends.

Should receptionists know cyber?

Yes. They spot social engineering (fake delivery guys).

Who tests backups?

IT team, overseen by CISO.

Does SEBI require cyber roles?

Yes, listed firms need cyber risk reporting to board.

Who updates the strategy?

CISO, with input from all teams, approved by CEO.

Where can I find a RACI template?

NIST, MeitY, or NASSCOM websites.