The Absence of CISOs in Credit Unions: A Structural Reality

Why don’t credit unions have CISOs?

  • Organizational structure and scale: Credit unions are generally smaller than banks and large corporations. With fewer resources and streamlined leadership teams, credit unions focus their executive roles on traditional operational needs, such as CEOs, CFOs and COOs. Security, though critical, often gets embedded within IT rather than elevated as a standalone executive function.
  • Perceived risk vs. responsibility: Many credit unions view information security as a subset of IT rather than a standalone strategic concern. This perspective leads to assigning security responsibilities to an ISO, who typically reports to a CIO, CTO or VP. While this approach can be effective for day-to-day operations, it lacks the strategic oversight a CISO provides.
  • Budget constraints: The financial model of credit unions prioritizes member services and community support. Allocating resources for an executive-level CISO position can be difficult to justify, especially when other IT leadership roles already exist. Instead, credit unions often opt to distribute cybersecurity responsibilities across existing positions.
  • Cultural and historical factors: Credit unions have historically focused on personalized member service and community engagement. This culture sometimes results in less emphasis on integrating security into the highest levels of decision-making, even as digital transformation and cyber threats have grown exponentially.

The role of the ISO in credit unions

The ISO in a credit union is crucial but often faces limitations:

  • Operational focus: ISOs are tasked with implementing security measures, monitoring threats and ensuring compliance. They are the boots-on-the-ground, addressing immediate cybersecurity needs.
  • Limited influence: Unlike a CISO, ISOs rarely participate in executive leadership discussions, meaning cybersecurity priorities may not always align with organizational strategy.
  • Reporting challenges: ISOs often report to the CIO or VP of IT, creating a potential conflict of interest. IT leaders may prioritize operational needs over security investments, inadvertently sidelining critical risk mitigation efforts.

Why cybersecurity needs executQive representation

The absence of a CISO in credit unions raises important questions about how cybersecurity is prioritized:

  • Strategic oversight: Cybersecurity is not just a technical issue—it’s a business risk. A CISO provides the strategic lens needed to integrate security into business decisions and long-term planning.
  • Regulatory pressures: As compliance requirements grow, regulators increasingly expect organizations to demonstrate robust security leadership. Elevating the ISO role or creating a CISO position signals a proactive approach to governance.
  • Member trust: Cybersecurity is directly tied to trust. A security breach can erode member confidence, making it critical for credit unions to visibly commit to safeguarding sensitive data.

Moving toward a more strategic approach

Credit unions should consider evolving their security leadership structures:

  • Elevate the ISO role: By giving ISOs more visibility and decision-making authority, credit unions can bridge the gap between operations and strategy.
  • Adopt a virtual CISO model: For credit unions of all sizes, hiring a part-time or fractional CISO can provide the expertise needed without the cost of a full-time executive.
  • Invest in board education: Ensuring board members understand cybersecurity risks can help create a culture where security is seen as a strategic priority, not just an operational expense.

Conclusion

Barry Lewis, CISSP is the Senior Director, Security, and Technology Consulting at Trellance. 

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