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U.K. Social Housing Providers Set Their Sights On Cyber Risks

This report does not constitute a rating action.

In dealing with one imminent risk, U.K. social housing providers (SHPs) have exposed themselves to another. Cyber risk has increased in recent years for SHPs, particularly since the COVID-19 pandemic's outbreak, mainly because of increased digitalization efforts of internal systems and growth in online services. The sector is a target for cyberattacks because they collect confidential information from tenants in offering an important public service. SHPs are essential in providing safe and well-maintained homes for many people in the country, so a serious disruption could have significant social impacts. While no cyberattack has substantially affected our rated SHPs so far, we think the financial impacts could be considerable, especially if disruption is prolonged and existing IT infrastructure and policies cannot mitigate this. In addition, regulators could impose heavy fines. We think that a significant cyberattack would tarnish an SHP's public image and become a dealbreaker in debt issuances, given that investors are paying more attention to social responsibilities than before.

Social Housing Providers Are Likely Targets

In our view, U.K. SHPs, both large and small, have increasingly become targets of cyberattacks. Clarion Housing Group (A-/Stable/--), one of the largest SHPs in the U.K., became a victim recently. We understand that the attack targeted Clarion's IT infrastructure, causing some of its emails, IT systems, and phone lines to fail. The group has restored many of the affected services. However, while its main repository, in which personal data is stored, was not accessed, it is still investigating the extent to which data stored elsewhere might have been affected. Meanwhile, its reported operating surplus is likely to weaken via additional provisions against rent arrears linked to this incident, although we do not see the financial impact as being an immediate credit risk. Other regional and local SHPs were not immune. Red Kite Community Housing (not rated), an SHP based in Wycombe, lost almost £1 million after cyber criminals mimicked the domain and emailed details of the group's suppliers in 2019. As a result, the Regulator of Social Housing (RSH) revised its governance grade to G2 from G1. The grading system assesses whether a SHP meets the regulator's governance requirements, on a scale from G1 to G4. G1 and G2 are compliant grades.

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Similar to many private sector corporations, SHPs in the U.K. increasingly rely on IT systems to provide services to tenants. We think that the pandemic was a catalyst in making online platforms a more-dominant tool for tenant requests when face-to-face meetings were difficult. SHPs also rely on digital tools more to carry out daily operations, including rent collection and tenancy support services. Also, with the increased remote working, critical systems that monitor or control assets and processes are becoming increasingly connected to externally facing technology, streamlining business processes and enabling SHPs to provide better services. This is propelling higher efficiency across the sector. However, new technologies, especially those that deploy business intelligence based on residents' data, offer cyber criminals more targets.

Partners with the sector are not immune to the issue. For instance, Plentific, a company that runs a repairs platform for large London SHPs, such as L&Q, Notting Hill Genesis, and Peabody, experienced a cyberattack that indirectly affected SHPs' operations. Local councils, which manages housing benefits and planning, are also targets.

The Sector Is Gearing Up To Tackle The Threat

Many U.K. SHPs are working on stepping up their IT security. While we usually see relevant policies and measures such as business continuity plan, penetration testing, some have gone beyond this by setting up 24/7 monitoring systems, conducting third-party reviews or more trainings to their employees to raise the awareness. Cyber Essentials Accreditation, a government-backed scheme that certifies an organization's defense against cyberattacks, is becoming more popular in the sector. The accreditation ensures an SHP has basic technical controls, such as firewalls, secure configuration, user access controls, malware protection, and security update management. Some SHPs are further pursuing standards, including Cyber Essentials Plus Accreditation and International Organization for Standardization 27001, which covers information security management systems. We consider the sector's increasing effort to strengthen IT infrastructure credit positive that would somewhat mitigate the rising risk. While it is difficult to quantify the financial impact, some providers account for cyber security breaches in stress testing.

We understand that cyber insurance is common in the sector, but it's getting more expensive. Globally, much of the increase in price has followed a supply and demand mismatch and insurers' cautiousness in taking on new risk (for more information, see "Cyber Risk In A New Era: The Future For Insurance-Linked Securities In The Cyber Market Looks Uncertain," published Aug. 24, 2022 on RatingsDirect). This also applies to U.K. SHPs; indeed, some SHPs have seen the costs of cyber insurance increase.

We understand that most SHPs use their own resources to fund IT infrastructure and other cyber-related investment, with limited help from government grants. The U.K. government is increasing its IT-related investment, such as with this year's National Cyber Security Strategy 2022 that includes £2.6 billion in cyber and legacy IT over the next three years. This exceeds £1.9 billion over five years committed to the previous strategy from 2016. Although whether the funding will benefit SHPs is unclear, we see it is a positive sign of the government's financial commitment to overall cyber security.

Incorporating Cyber Risk In U.K. Social Housing Ratings

We embed issuers' cyber risk preparedness in our assessment of U.K. SHPs' management and governance assessment. In our view, SHPs should have a comprehensive cyber strategy to mitigate risks with sufficient monitoring and IT infrastructure. Lack of a strategy could imply weak risk management. We also consider the financial impacts of cyber risk in our financial risk profile assessment.

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Cyberattacks Could Be Costly

Cyberattacks could weaken financial performance, the risks of which we assess in the financial risk profile under our rating methodology. Incidents can result in extended service disruptions for SHPs. At the same time, the activation of the emergency actions might face hiccups, prolonging disruption to operations--which we have seen in some recent incidents. On top of that, key treasury functions, such as rent collection and payment to suppliers, might not resume in a timely manner.

The U.K. regulator has the power to fine SHPs due to data breaches. The related regulatory bodies in England include the Information Commissioner's Office (ICO) and RSH. ICO could place a huge fine of up to £17.5 million, or 4% of an SHP's revenue if it finds breaches are significant. Also, if an organization fails to notify the ICO of notifiable breaches, a fine of up to £8.7 million, or 2% of revenue, could follow. The ICO has other corrective powers. Large SHPs would have more financial capacity to pay any fines but are more exposed to cyber risks, given their large database are more attractive to hackers. Conversely, small SHPs could be less likely to be a target but would be more susceptible to any fines. Moreover, SHPs already under financial stress might find themselves hard-pressed to improve IT systems and would become more vulnerable to cyber incidents, unable to absorb the resulting potential losses.

Although we have not seen a cyberattack cause a data breach in the sector in recent years, breaches due to SHPs' human errors are a good proxy for the potential repercussions on financial performance. Watford Community Housing mistakenly sent out an email that contained personal information about customers in 2020. This led to a review from the ICO, which provided recommendations to prevent a similar incident. Also, the group made provisions to cover costs including cyber security coverage being provided to all affected customers, investigatory or remedial costs, and other associated regulatory and legal costs.

Reputations Are At Risk

We think that major cyber incidents could cause serious reputational damage to SHPs. Regaining tenant trust will take a long time following their personal information becoming compromised. We believe this could result in a potential loss of investor trust in SHPs' operations. Also, the U.K. social housing sector has a strong element of social responsibility that has attracted sustainability-linked investments in recent years. Cyberattacks could damage a SHP's reputation and cast doubt on its social role, which would put off investors looking at new issuances.

In our view, cyber security has become a growing concern to social housing regulators. In England, RSH has stressed that cyber is a key sector risk. Its introduction of tenant satisfaction measures from April 2023 could further stress providers in handling customer satisfaction if there are any disrupting security incidents.

Although we understand that the sector is increasing efforts in IT infrastructure, cyberattacks are becoming more sophisticated, constantly seeking ways to exploit system or human vulnerabilities. As we expect that financial and reputational consequences could be more significant for cyberattacks, we think that cyber security will be increasingly important in SHPs' risk management. Those that do not manage the risk well, via strong planning and management, could see significant negative credit implications.

Related Research

Primary Credit Analyst:Tim Chow, London +44 2071760684;
tim.chow@spglobal.com
Secondary Contacts:Felix Ejgel, London + 44 20 7176 6780;
felix.ejgel@spglobal.com
Eileen X Zhang, CFA, London + 44 20 7176 7105;
eileen.zhang@spglobal.com
Michelle Keferstein, Frankfurt (49) 69-33-999-104;
michelle.keferstein@spglobal.com

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