Cybersecurity Policy Template

Configuration Management Policy (DORA Compliant)

1. Introduction

1.1 Purpose and Scope: This Configuration Management Policy (CMP) establishes a comprehensive framework for managing and controlling all ICT configurations across the organization. It aims to ensure the security, stability, availability, and integrity of all systems and applications, aligning with the principles of the Digital Operational Resilience Act (DORA). This policy applies to all ICT systems, applications, networks, and infrastructure, regardless of location or ownership, within the organization's scope as defined by the DORA regulations.

1.2 Relevance to DORA: This CMP directly addresses DORA's requirements for robust ICT risk management, incident reporting, and resilience. Specifically, it contributes to meeting obligations related to:

  • Incident management: By establishing baselines and configuration controls, the policy facilitates faster incident detection, analysis, and response.

  • Risk management: Proactive configuration management mitigates risks related to vulnerabilities, unauthorized changes, and system instability.

  • Resilience: Maintaining secure and stable configurations enhances the overall resilience of the ICT infrastructure against disruptions.

  • Third-party risk management: The policy clarifies requirements for managing configurations of systems provided by third-party vendors.

  • Data protection: Secure configurations contribute to the protection of personal and sensitive data.

2. Key Components

The main sections of this CMP include:

  • Configuration Identification and Baselining: Defining and documenting the authorized configuration of all ICT assets.

  • Configuration Change Management: Establishing a process for requesting, authorizing, implementing, and verifying changes to configurations.

  • Configuration Auditing and Monitoring: Regularly verifying the accuracy and integrity of configurations.

  • Configuration Control: Establishing processes to prevent unauthorized configuration changes.

  • Vulnerability Management: Integrating vulnerability management practices into the configuration management process.

  • Incident Response: Procedures for handling incidents related to configuration issues.

  • Recovery and Restoration: Processes for recovering and restoring ICT systems to their authorized configurations.

  • Roles and Responsibilities: Clearly defining roles and responsibilities for configuration management activities.

3. Detailed Content

3.1 Configuration Identification and Baselining:

  • In-depth explanation: This involves creating a comprehensive inventory of all ICT assets, including hardware, software, and network devices. For each asset, a baseline configuration is established, documenting its approved settings, software versions, and security parameters. This baseline serves as the reference point for all future configuration changes.

  • Best practices: Utilize automated tools for discovery and configuration scanning. Maintain a central repository for configuration baselines. Regularly update baselines to reflect approved changes.

  • Example: A baseline for a web server might include: OS version (Ubuntu 22.04), web server software (Apache 2.4.52), security patches (all applied up to date X), firewall rules (specific ports open/closed), and user accounts (with clearly defined permissions).

  • Common pitfalls: Inconsistent naming conventions, incomplete asset inventory, outdated baselines.

3.2 Configuration Change Management:

  • In-depth explanation: This defines a formal process for managing all changes to ICT configurations. This includes change requests, approvals, implementation, testing, and documentation.

  • Best practices: Implement a change management system (e.g., ServiceNow, Jira). Establish clear approval workflows based on risk levels. Thoroughly test all changes before deployment.

  • Example: A change request to upgrade the database server software requires approval from the database administrator, security officer, and IT manager. The change must be tested in a non-production environment before deployment to production. Rollback plan must be included.

  • Common pitfalls: Lack of formal approval process, inadequate testing, insufficient documentation.

3.3 Configuration Auditing and Monitoring:

  • In-depth explanation: Regularly auditing and monitoring configurations to ensure they conform to established baselines and security policies. This includes automated scans, manual checks, and log analysis.

  • Best practices: Utilize automated configuration management tools. Establish regular audit schedules. Analyze audit logs for anomalies.

  • Example: Regular automated scans using tools like Ansible or Chef to compare the current configuration of servers against their baselines. Manual checks of critical configurations at least monthly.

  • Common pitfalls: Infrequent audits, lack of automated tools, inadequate log analysis.

3.4 Configuration Control:

  • In-depth explanation: Implementing mechanisms to prevent unauthorized changes to configurations. This might involve access controls, change control processes, and security hardening techniques.

  • Best practices: Implement role-based access control (RBAC). Use configuration management tools to enforce configuration settings. Regularly review and update access controls.

  • Example: Only authorized personnel have access to modify server configurations. Changes are logged and tracked. Automated tools ensure that configurations remain within defined parameters.

  • Common pitfalls: Weak access controls, lack of monitoring, insufficient logging.

3.5 Vulnerability Management:

  • In-depth explanation: Integrate vulnerability management into the configuration management process. This involves regularly scanning for vulnerabilities, prioritizing remediation efforts, and tracking the status of fixes.

  • Best practices: Use vulnerability scanners (Nessus, Qualys). Prioritize vulnerabilities based on risk. Establish clear remediation timelines.

  • Example: Regular vulnerability scans identify a critical vulnerability in a web server. A patch is applied, and the configuration is audited to ensure the fix was successful.

  • Common pitfalls: Infrequent vulnerability scans, ignoring low-risk vulnerabilities, lack of prioritization.

3.6 Incident Response, Recovery & Restoration: (Covered under separate DORA compliant Incident Response Plan)

3.7 Roles and Responsibilities: (Detailed in a separate document outlining roles and responsibilities across the organization)

4. Implementation Guidelines

1. Inventory and Assessment: Create a comprehensive inventory of all ICT assets and assess their current configurations.

2. Baseline Development: Develop configuration baselines for all critical assets.

3. Change Management Process Implementation: Implement a robust change management process.

4. Tool Selection and Deployment: Select and deploy automated configuration management tools.

5. Training: Provide training to all relevant personnel on the new CMP.

6. Testing and Validation: Test and validate the implemented CMP.

7. Documentation: Maintain comprehensive documentation of the CMP, including procedures and baselines.

Roles and Responsibilities: This will be outlined in a separate document detailing specific responsibilities for each role (e.g., System Administrator, Security Officer, IT Manager).

5. Monitoring and Review

The effectiveness of this CMP will be monitored through:

  • Regular audits: Frequency defined by risk assessment (e.g., monthly, quarterly).

  • Incident analysis: Identifying configuration-related incidents and their root causes.

  • Compliance reports: Regularly assessing compliance with the policy.

  • Security assessments: Incorporating configuration compliance checks into broader security assessments.

The CMP will be reviewed and updated at least annually or as needed to reflect changes in technology, threats, and regulatory requirements.

6. Related Documents

  • Incident Response Plan

  • Security Policy

  • Risk Management Policy

  • Disaster Recovery Plan

  • Third-Party Risk Management Policy

7. Compliance Considerations

This CMP directly addresses DORA's requirements for robust ICT risk management and incident handling. Specific clauses addressed include those related to:

  • ICT risk management (Article 4)

  • Incident reporting and resolution (Article 8)

  • Business continuity and recovery (Article 9)

  • Third-party risk management (Article 10)

This policy will be reviewed for compliance with all relevant legal and regulatory requirements including GDPR, NIS2 and other applicable national regulations.

This detailed template provides a comprehensive framework for a DORA-compliant Configuration Management Policy. Remember to tailor it to your organization's specific needs and context. Regular updates and reviews are crucial to maintain its effectiveness and compliance.

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