BBVA Colombia's General Information Security and Cybersecurity Policy
The Policy, updated on May 22, 2025, protects the information and assets of the BBVA conglomerate in Colombia. It seeks to mitigate risks, guaranteeing the integrity, onfidentiality, availability, and authenticity of data, aligning with the EBA and Colombian regulations. Its pillars include integrity, prudence in risk management, a profitable and sustainable business, and legal compliance, focusing on an organizational framework, technical and organizational controls, alignment with the Group's strategy, and fostering a security culture. The management model is based on Group guidelines, a centralized operational model, and internal control with three lines of defense. The policy is mandatory for employees, suppliers, partners, and BBVA entities in Colombia, covering the entire lifecycle of information assets. Non-compliance may result in disciplinary sanctions.
Additionally, the policy defines specific roles and responsibilities, such as those of Corporate Security (policy executor) and the local CSO (policy responsible), and emphasizes the importance of coordination between internal and external actors, as well as communication with authorities and regulatory bodies. It includes a glossary of key terms related to information security and cybersecurity.
BBVA Group has established a global information security structure for all its geographies. This structure includes a CSO at the Holding level and functional execution units for the Data CISO and corporate functions. For the geography of Colombia, a CSO Country Leader Manager has been appointed.
BBVA Group's General Operational Resilience Policy
The policy, mandatory for the entire Group, ensures the integrity and reliability of systems and networks. It is governed by principles such as integrity, prudence, transparency, sustainability, legal compliance, availability, confidentiality, authenticity, and physical security. It includes identification of Critical Processes, third-party risk management, training, incident management, testing, and continuous improvement, with an ICT Risk Management Framework that details the risk cycle and the importance of backups.
The Business Continuity Management Framework identifies critical processes to ensure their maintenance and rapid recovery after interruptions, minimizing impacts. Internal regulation will be developed to manage continuity and operational crises. The Group will also establish processes for operational incidents that affect continuity and security, including an ICT process to detect, manage, and communicate relevant incidents to clients and authorities, classifying them by criticality.
Information Security and Cybersecurity Incident Management Standard V7
BBVA Colombia's policy defines a framework for security incident management, following the NIST SP 800-61 standard, to minimize impacts, classify incidents, and ensure compliance. It applies to all personnel and third parties with access to the Bank's systems. The principles emphasize rapid and effective management of any event that compromises systems, the entity, or clients.
The management phases include: prevention (team, plan, asset identification, tools, and awareness), detection (anomaly identification and mandatory reporting), analysis/containment/eradication/recovery (verification, root cause, resolution, vulnerability correction, and restoration), and post-incident (review, improvements, reports, and lessons learned).
Cyber incidents are classified by severity (Non-Significant, Significant, Severe) with sublevels (C to A+), based on systemic impact, service interruption, reputation, data loss, and economic impact. An escalation, notification, and internal and external communication plan (clients, regulators) is detailed.
Standard for Decision-Making and Relevant Follow-up in the Field of Information Security and Cybersecurity Management BBVA Colombia
This BBVA Colombia standard seeks to manage information security and cybersecurity, addressing concerns of the Financial Superintendency about possible conflicts of interest in Corporate Security. It establishes that key decisions must be approved by a different body, the Information Security and Cybersecurity Committee, which meets quarterly and supervises the implementation and effectiveness of the standard. It includes the approval of internal regulations, fraud parameters, controlled pilots, and risk monitoring. Corporate Security is responsible for presenting information to the Committee. The standard is governed by integrity, transparency, prudence, and legal compliance.
Additionally, internal and external audits are carried out annually to evaluate the corporate security structure.
The internal audit conducted in the first half of the year evaluated cybersecurity controls, focusing on protection against cyberattacks, intrusions, unauthorized access, theft, loss or misuse of information, and deficiency management.
E&Y's external audit report from November 2024 evaluates BBVA Colombia's General IT Controls (ITGCs). It focuses on the scope, methodology (with High, Medium, Low risk levels), and evaluation results. The areas evaluated include Program and Data Access, Change Management, and Computer Operations.