"The clause merits close scrutiny, because it is the point in the Bill where risk is supposed to be addressed beyond the individual operator and into the supply chain. In plain terms, clause 12 will allow the regulator to designate a supplier as critical where disruption to that supplier would …..." Alison Griffiths - View Speech
"Clause 7 is definition-heavy, and rightly so; these terms decide who is regulated and who is not. My only observation is that cloud models are, as the Minister knows, evolving quickly because of the AI revolution. Definitions that track architecture too closely will age fast, so the Committee should be …..." Alison Griffiths - View Speech
"Clause 4 relies heavily on capacity as the trigger for regulation. I understand why that is attractive: it is measurable. But capacity is not the same as criticality, and a high-capacity facility used for redundancy can present less systemic risk than a smaller, highly concentrated one. I simply put on …..." Alison Griffiths - View Speech
"I think my hon. Friend is about to reference the commercial impacts on MSPs. We have already referenced the fact that they are of many different sizes. One of the concerns the Committee will need to consider is whether new contracts will need to be written. The level of uncertainty …..." Alison Griffiths - View Speech
"On my hon. Friend’s point about the lack of clarity in the Bill, there is a real possibility that firms will find that an MSP has one view of an issue while their client has another. Unless there is sufficient clarity in the wording of the Bill, we will have …..." Alison Griffiths - View Speech
"Bringing MSPs into scope is the right direction of travel, and MSPs sit at points of concentrated risk, but they are not all the same and the real risk is not size alone but the level of privileged access and cross-customer dependency. Proportionality will be critical under these provisions if …..." Alison Griffiths - View Speech
"Does my hon. Friend agree that, although we support the intent behind the Bill, clause 2 does a lot of framing work but does not necessarily consider the extensive perimeter that is coming through and how proportionality will be applied in practice? I suggest that the Committee keep that in …..." Alison Griffiths - View Speech
"My hon. Friend is making a very good point, which also applies to improving board awareness and ensuring that the enforcement of the regulations incentivises boards to take the issue seriously and make sure that they are equipped to understand the commercial reality of cyber-security for their businesses. Enforcement is …..." Alison Griffiths - View Speech
"The clause is drafted broadly, which is understandable, but in practice many of the supply chains, as my hon. Friend has ably demonstrated, involve several layers of providers and sub-providers. I would welcome clarity on how regulators are expected to approach designation in these cases, so that responsibility is clear …..." Alison Griffiths - View Speech
"Q You have both mentioned the risk involved in supply chains. Do you think that, outside regulated industries, the Bill goes far enough to secure supply chains? If not, what would your recommendations be?
David Cook: The legislation talks about secondary legislation, so it allows for an agile, flexible …..." Alison Griffiths - View Speech