Cybersecurity Policy Template
DORA Compliant Communication Policy
1. Introduction
Purpose and Scope: This Communication Policy outlines the procedures for internal and external communication during all phases of an incident, from detection to resolution and post-incident review. It ensures consistent, timely, and accurate information flow to all stakeholders, including customers, regulators, and internal teams, minimizing disruption and maintaining trust. This policy aligns with the principles of the Digital Operational Resilience Act (DORA), fostering transparency and accountability.
Relevance to DORA: This policy directly supports DORA’s requirements for incident reporting, management, and communication. It ensures compliance with obligations related to timely notification of regulators, accurate reporting of incident impacts, and transparent communication with affected parties. This policy contributes to building an organization's overall operational resilience.
2. Key Components
This Communication Policy includes the following key components:
Incident Communication Plan: Defines communication channels, roles, and responsibilities for different incident types and severity levels.
Stakeholder Communication Matrix: Identifies key stakeholders, their communication preferences, and the information they require during an incident.
Communication Templates and Protocols: Provides pre-written templates for various communication scenarios, ensuring consistent messaging.
Escalation Procedures: Outlines the process for escalating communication to senior management and external parties when necessary.
Post-Incident Communication Review: Describes the process for reviewing communication effectiveness after an incident to identify areas for improvement.
Training and Awareness: Details the training program to ensure all personnel understand their communication roles and responsibilities.
3. Detailed Content
3.1 Incident Communication Plan:
In-depth explanation: This plan details the communication channels (e.g., email, phone, SMS, internal communication platforms), frequency of updates, and responsible parties for each communication type. It should categorize incidents by severity (e.g., critical, major, minor) and specify communication actions for each level.
Best practices: Use a clear and concise communication style, avoid technical jargon, and tailor messages to the audience's understanding. Establish a central communication hub (e.g., dedicated communication platform) to manage information flow.
Example: For a critical incident impacting customer access to a core service, the plan specifies that the Incident Commander will issue updates every 30 minutes via email and the internal communication platform to affected teams and stakeholders. A public statement will be issued within 60 minutes via the company website and social media.
Common pitfalls: Inconsistency in messaging, delays in communication, lack of transparency, using inappropriate channels.
3.2 Stakeholder Communication Matrix:
In-depth explanation: This matrix lists all relevant stakeholders (customers, regulators, shareholders, employees, media) and details their communication needs (e.g., what information they need, preferred communication channels, frequency of updates).
Best practices: Segment stakeholders based on their information needs and communication preferences. Prioritize communication based on stakeholder impact and urgency.
Example: For a data breach, the matrix identifies regulators (e.g., DPA) requiring immediate notification under GDPR, customers impacted requiring personalized updates on data compromised and mitigation steps, and internal teams requiring operational and technical updates.
Common pitfalls: Missing key stakeholders, inadequate contact information, inconsistent communication across different stakeholders.
3.3 Communication Templates and Protocols:
In-depth explanation: This section provides pre-written templates for various communication scenarios (e.g., initial incident notification, progress updates, resolution announcements, post-incident reports).
Best practices: Use plain language, avoid technical jargon, and ensure consistent branding and tone of voice across all communications.
Example: A template for a customer notification about a service outage includes a clear explanation of the issue, estimated time of restoration, and contact information for support.
Common pitfalls: Using outdated or inconsistent templates, failing to personalize messages, lacking clarity and conciseness.
3.4 Escalation Procedures:
In-depth explanation: Defines the process for escalating communication to senior management, external parties (e.g., regulators), and public relations when an incident exceeds predefined thresholds.
Best practices: Clearly define escalation criteria based on incident severity and impact. Establish clear communication channels and reporting lines for escalation.
Example: If an incident causes significant financial loss or reputational damage, the Incident Commander must escalate the situation to the CEO and the PR team within one hour.
Common pitfalls: Delayed escalation, unclear escalation criteria, lack of accountability.
3.5 Post-Incident Communication Review:
In-depth explanation: Outlines the process for conducting a post-incident review of communication effectiveness, identifying areas for improvement.
Best practices: Use feedback from stakeholders, review communication logs, and analyze communication effectiveness metrics (e.g., timeliness, accuracy, clarity).
Example: After a recent incident, a review revealed that communication to impacted customers was delayed, resulting in negative feedback. The team then updated the communication plan to address these delays.
Common pitfalls: Failing to conduct a review, not analyzing lessons learned, not incorporating feedback.
3.6 Training and Awareness:
In-depth explanation: This section describes the training program to ensure all personnel understand their communication roles and responsibilities.
Best practices: Use a combination of online training modules, workshops, and tabletop exercises to enhance employee understanding.
Example: All employees receive annual training on the Communication Policy and participate in simulated incident scenarios to practice their communication roles.
Common pitfalls: Insufficient training, lack of awareness, inadequate resources.
4. Implementation Guidelines
1. Establish a Communication Team: Assign roles and responsibilities (Incident Commander, Communication Lead, Spokesperson).
2. Develop Communication Plan and Matrix: Define communication channels, stakeholders, and messaging.
3. Create Communication Templates: Develop pre-written templates for various scenarios.
4. Implement Training Program: Educate employees on the Communication Policy and their roles.
5. Test and Refine: Conduct regular simulations and drills to refine the plan.
6. Document and Update: Regularly review and update the plan based on lessons learned.
5. Monitoring and Review
The effectiveness of this policy will be monitored through:
Regular reviews: Quarterly reviews of incident reports and communication logs.
Feedback mechanisms: Gather feedback from stakeholders on communication effectiveness after each incident.
Key performance indicators (KPIs): Track metrics such as timeliness of communication, accuracy of information, and customer satisfaction.
Annual review: A comprehensive annual review to assess the policy's overall effectiveness and make necessary adjustments.
6. Related Documents
Incident Management Plan
Business Continuity Plan
Regulatory Compliance Policy
Data Breach Response Plan
7. Compliance Considerations
This Communication Policy addresses DORA requirements related to incident reporting, communication with supervisory authorities, and transparency with stakeholders. It ensures compliance with relevant regulations like GDPR (regarding data breach notifications), and national cybersecurity legislation. Specific clauses addressed depend on the jurisdiction, but generally include those pertaining to:
Timely notification of supervisory authorities: The policy defines the timeframe for notifying regulators about incidents.
Transparency with stakeholders: The policy ensures clear and consistent communication with affected parties.
Accuracy and completeness of information: The policy ensures accurate and reliable information is provided.
Management and mitigation of incidents: The policy facilitates swift and effective incident response.
This comprehensive Communication Policy provides a framework for organizations to meet DORA's communication requirements and build operational resilience. Remember to adapt this template to your specific organizational context and regulatory environment. Regular review and updates are crucial to ensure its continued effectiveness.
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