Cybersecurity Policy Template

Continuous Monitoring Policy (DORA Compliant)

1. Introduction

Purpose and Scope: This policy establishes a framework for the continuous monitoring of all Information and Communication Technology (ICT) systems within [Organization Name]. The goal is to proactively detect and respond to unusual activity, security incidents, and performance issues, thereby ensuring the availability, integrity, and confidentiality of our systems and data, aligning with the principles of the Digital Operational Resilience Act (DORA). This policy covers all ICT systems critical to the organization’s operations, including but not limited to servers, networks, applications, databases, and cloud services.

Relevance to DORA: This policy directly addresses DORA's requirements for ICT risk management, incident reporting, and resilience testing. Continuous monitoring is crucial for identifying and mitigating disruptions, fulfilling DORA's mandate for robust operational resilience. Specific DORA articles addressed are detailed in section 7.

2. Key Components

This Continuous Monitoring Policy encompasses the following key components:

  • Monitoring Objectives and Scope: Defines what needs to be monitored and why.

  • Monitoring Tools and Technologies: Specifies the technologies used for monitoring.

  • Metrics and Thresholds: Details the key performance indicators (KPIs) and alert thresholds.

  • Alerting and Escalation Procedures: Outlines the process for handling alerts and escalations.

  • Incident Response Plan: Integrates with the organization's incident response plan.

  • Data Retention and Archiving: Defines data retention policies for monitoring logs and data.

  • Security Monitoring: Focuses specifically on security threats and vulnerabilities.

  • Reporting and Auditing: Details reporting requirements and audit trails.

3. Detailed Content

3.1 Monitoring Objectives and Scope:

  • In-depth explanation: This section clearly defines the specific ICT systems and processes that fall under the scope of continuous monitoring. It should explicitly list critical systems, applications, and data that, if compromised or unavailable, would significantly impact the organization's operations. It should also outline the specific operational risks to be monitored (e.g., denial-of-service attacks, data breaches, performance degradation).

  • Best practices: Categorize systems by criticality (high, medium, low) to prioritize monitoring efforts. Use a comprehensive asset inventory to ensure nothing is overlooked.

  • Example: High-criticality systems include our core banking platform, payment processing system, and customer relationship management (CRM) system. Medium-criticality systems include internal communication platforms and email servers. Low-criticality systems encompass non-critical internal applications and development servers.

  • Common pitfalls: Failing to identify all critical systems, neglecting to define clear monitoring objectives, and not regularly reviewing and updating the scope.

3.2 Monitoring Tools and Technologies:

  • In-depth explanation: This section details the specific monitoring tools and technologies employed, including system monitoring tools (e.g., Nagios, Zabbix), security information and event management (SIEM) systems (e.g., Splunk, QRadar), network monitoring tools (e.g., SolarWinds), and cloud-based monitoring services (e.g., AWS CloudWatch, Azure Monitor).

  • Best practices: Utilize a combination of tools to achieve comprehensive coverage. Ensure tools are properly configured and integrated. Regularly update tools and software to address vulnerabilities.

  • Example: We use Splunk as our SIEM, Nagios for system monitoring, and AWS CloudWatch for monitoring our cloud infrastructure. These systems are integrated to provide a unified view of our ICT environment.

  • Common pitfalls: Relying on a single monitoring tool, neglecting proper configuration, and failing to integrate tools effectively.

3.3 Metrics and Thresholds:

  • In-depth explanation: Defines the key performance indicators (KPIs) and their corresponding thresholds that trigger alerts. Examples include CPU utilization, memory usage, network latency, transaction processing time, error rates, and security event counts.

  • Best practices: Establish baseline metrics and dynamically adjust thresholds based on historical data and system behavior. Use a combination of quantitative and qualitative metrics.

  • Example: If CPU utilization on our core banking platform exceeds 90% for more than 15 minutes, an alert is generated. If the number of failed login attempts exceeds 10 within an hour, a security alert is triggered.

  • Common pitfalls: Setting thresholds too high or too low, failing to establish baselines, and not adjusting thresholds over time.

3.4 Alerting and Escalation Procedures:

  • In-depth explanation: This section outlines the process for handling alerts and escalations, including the individuals or teams responsible for responding to different types of alerts, the communication channels used, and escalation paths for critical incidents.

  • Best practices: Use automated alerts via email, SMS, and/or paging systems. Establish clear escalation paths to ensure timely response. Maintain an on-call rotation schedule.

  • Example: System alerts are initially routed to the Level 1 support team. If the issue cannot be resolved within 30 minutes, it's escalated to the Level 2 team. Critical security alerts are immediately escalated to the Security Operations Center (SOC).

  • Common pitfalls: Slow response times, unclear escalation paths, and lack of communication.

3.5 Incident Response Plan:

  • In-depth explanation: This section details how security incidents and performance issues will be managed, including incident identification, containment, eradication, recovery, and post-incident activities.

  • Best practices: Integrate with existing incident management processes. Establish clear roles and responsibilities. Regularly test the plan.

  • Example: The incident response plan includes detailed procedures for handling DDoS attacks, data breaches, and system failures.

  • Common pitfalls: Lack of a documented plan, unclear roles and responsibilities, inadequate testing.

3.6 Data Retention and Archiving:

  • In-depth explanation: This section defines how long monitoring data will be retained, where it will be stored, and how it will be archived. Compliance with data protection regulations must be addressed.

  • Best practices: Implement a data retention policy that meets legal and regulatory requirements while minimizing storage costs. Securely archive data.

  • Example: Monitoring logs will be retained for 90 days. Security incident logs will be retained for at least one year.

  • Common pitfalls: Insufficient data retention, insecure storage, lack of compliance with data protection regulations.

3.7 Security Monitoring:

  • In-depth explanation: Focuses on security-specific aspects, including intrusion detection, malware analysis, vulnerability scanning, and user activity monitoring.

  • Best practices: Use SIEM systems to aggregate and analyze security logs. Implement security information and event management (SIEM) and threat intelligence platforms. Conduct regular vulnerability scans.

  • Example: We use Splunk to monitor security logs for suspicious activities, such as unauthorized access attempts or malware infections.

  • Common pitfalls: Lack of proactive security monitoring, neglecting vulnerability management, insufficient threat intelligence.

3.8 Reporting and Auditing:

  • In-depth explanation: Outlines regular reporting requirements, including management reports on system performance, security incidents, and monitoring effectiveness. Includes audit trail requirements for all changes to monitoring systems.

  • Best practices: Generate regular reports summarizing key metrics and incidents. Conduct regular audits of the monitoring system itself.

  • Example: Weekly reports are generated on system performance. Monthly reports summarize security incidents. Quarterly audits of the monitoring infrastructure are performed.

  • Common pitfalls: Insufficient reporting, lack of audit trails, infrequent audits.

4. Implementation Guidelines

1. Assessment: Conduct a thorough assessment of current ICT systems and identify critical assets.

2. Tool Selection: Select appropriate monitoring tools and technologies.

3. Configuration: Configure monitoring tools and establish baseline metrics.

4. Testing: Thoroughly test the monitoring system and alert mechanisms.

5. Training: Train personnel on the use of monitoring tools and response procedures.

6. Deployment: Deploy the monitoring system and integrate it with existing systems.

Roles and Responsibilities:

  • IT Operations: Responsible for day-to-day monitoring and response.

  • Security Team: Responsible for security monitoring and incident response.

  • Management: Responsible for oversight and resource allocation.

5. Monitoring and Review

The effectiveness of this policy will be monitored through regular reviews of:

  • Alert frequency and resolution time: Track the number of alerts generated and the time it takes to resolve them.

  • Incident response effectiveness: Analyze incident response times and outcomes.

  • System uptime and performance: Monitor system availability and performance metrics.

  • Security event analysis: Review security logs for trends and patterns.

The policy will be reviewed and updated at least annually or more frequently as needed, following significant changes in the ICT environment or in response to identified weaknesses.

6. Related Documents

  • Incident Response Plan

  • ICT Security Policy

  • Business Continuity Plan

  • Disaster Recovery Plan

7. Compliance Considerations

This Continuous Monitoring Policy directly addresses several key aspects of DORA, including:

  • Article 3: Identification and assessment of ICT risks.

  • Article 4: Implementation of ICT risk management measures.

  • Article 5: Incident reporting obligations.

  • Article 6: Requirements for ICT resilience.

  • Article 7: Supervision of ICT service providers.

This policy also considers relevant data protection regulations, such as GDPR and local equivalents. The data retention policy aligns with these regulations to ensure compliance. Regular legal reviews will ensure ongoing compliance with evolving legislation.

This template provides a comprehensive framework. Specific details should be tailored to the unique characteristics of the organization and its ICT environment. Regular updates and revisions are crucial to maintain effectiveness and alignment with DORA and evolving best practices.

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