Cybersecurity Policy Template

Crisis Management Policy: DORA Compliant

1. Introduction

Purpose and Scope: This Crisis Management Policy outlines the procedures and responsibilities for managing and mitigating crises that significantly impact the organization's operations, reputation, and compliance with the Digital Operational Resilience Act (DORA). This policy covers a broad range of incidents, including but not limited to: major ICT failures (e.g., widespread system outage impacting core services), data breaches (e.g., unauthorized access to sensitive customer data), cybersecurity attacks (e.g., ransomware attack), significant third-party service disruptions, natural disasters affecting operational continuity, and reputational crises (e.g., negative media coverage related to service failures).

Relevance to DORA: This policy directly addresses DORA's requirements for digital operational resilience. Specifically, it contributes to fulfilling obligations related to incident management, ICT risk management, recovery planning, and reporting requirements to supervisory authorities. This policy ensures the organization's ability to maintain essential ICT services and promptly recover from disruptive incidents, thereby protecting customers, maintaining market stability, and complying with regulatory obligations.

2. Key Components

This Crisis Management Policy includes the following key components:

  • Crisis Definition and Escalation: Defining what constitutes a crisis and establishing clear escalation paths.

  • Crisis Management Team (CMT): Defining the composition, roles, and responsibilities of the CMT.

  • Incident Response Plan: Detailed procedures for identifying, assessing, responding to, and recovering from incidents.

  • Communication Plan: Procedures for communicating internally and externally during a crisis.

  • Recovery and Restoration Plan: Procedures for restoring services and operations after an incident.

  • Post-Incident Review: Procedures for analyzing incidents, identifying lessons learned, and improving resilience.

  • Documentation and Reporting: Procedures for documenting all aspects of crisis management and reporting to relevant stakeholders, including supervisory authorities.

3. Detailed Content

3.1 Crisis Definition and Escalation:

  • In-depth explanation: Defines different severity levels of incidents (e.g., minor, major, critical) based on impact on business operations, reputation, and legal/regulatory compliance. Clearly outlines criteria for escalating an incident to a full-blown crisis requiring activation of the CMT.

  • Best practices: Use a clear and concise matrix defining severity levels based on factors like impact on availability, confidentiality, integrity, and compliance. Establish clear escalation thresholds and communication channels.

  • Example: An incident resulting in a complete outage of the core banking system for over 4 hours would be classified as a critical crisis, automatically triggering the activation of the CMT. A minor system glitch affecting a non-critical service for less than an hour would not require CMT activation.

  • Common pitfalls: Failing to define clear escalation criteria; unclear communication channels leading to delays in escalation; lack of a documented escalation procedure.

3.2 Crisis Management Team (CMT):

  • In-depth explanation: Defines the composition of the CMT (e.g., CEO, CIO, Head of Security, Legal Counsel, Communications Director), their roles and responsibilities during a crisis, and their contact information. Outlines the chain of command and decision-making processes.

  • Best practices: Ensure the CMT has diverse expertise and clear lines of authority. Conduct regular training and drills to ensure team members are prepared.

  • Example: The CMT for a data breach would include the CIO (responsible for technical aspects), the Head of Legal (responsible for regulatory compliance), and the Communications Director (responsible for external and internal communications).

  • Common pitfalls: Lack of clearly defined roles and responsibilities; insufficient training for CMT members; inadequate communication among team members.

3.3 Incident Response Plan:

  • In-depth explanation: Provides step-by-step procedures for handling incidents, including initial assessment, containment, eradication, recovery, and post-incident activity. This includes details on technical procedures, communication protocols, and resource allocation.

  • Best practices: Regularly test and update the plan based on lessons learned from past incidents and evolving threats. Use a structured methodology like NIST Cybersecurity Framework.

  • Example: The plan for a ransomware attack would include steps for isolating affected systems, identifying the source of the attack, restoring data from backups, and engaging with law enforcement.

  • Common pitfalls: Outdated plans; lack of realistic testing; inadequate resource allocation; unclear roles and responsibilities.

3.4 Communication Plan:

  • In-depth explanation: Outlines procedures for communicating with internal stakeholders (employees, management) and external stakeholders (customers, regulators, media) during a crisis. Includes pre-approved communication templates and contact lists.

  • Best practices: Develop a communication strategy that is consistent, transparent, and timely. Designate a single spokesperson to avoid conflicting messages.

  • Example: A pre-approved press release template would be used for communicating about a data breach to the public, while internal communication channels would be used to update employees on the situation.

  • Common pitfalls: Delayed or inconsistent communication; inaccurate information; failure to address stakeholder concerns.

3.5 Recovery and Restoration Plan:

  • In-depth explanation: Outlines procedures for restoring normal operations after an incident, including system recovery, data restoration, and business continuity measures.

  • Best practices: Regularly test and update the plan, ensuring it covers all essential services. Prioritize critical systems and data for recovery.

  • Example: The recovery plan for a major ICT failure might include steps for restoring system functionality from backups, rerouting traffic to alternative data centers, and implementing temporary workarounds.

  • Common pitfalls: Insufficient backup and recovery capabilities; lack of redundancy; inadequate testing of recovery procedures.

3.6 Post-Incident Review:

  • In-depth explanation: Outlines the process for conducting a thorough post-incident review to identify root causes, assess the effectiveness of the response, and identify areas for improvement.

  • Best practices: Use a structured methodology for conducting the review, involving relevant stakeholders. Document findings and recommendations clearly.

  • Example: A post-incident review of a data breach would involve analyzing the attack vectors, identifying vulnerabilities in security controls, and recommending improvements to security policies and procedures.

  • Common pitfalls: Insufficient investigation; failure to identify root causes; lack of follow-up on recommendations.

3.7 Documentation and Reporting:

  • In-depth explanation: Specifies requirements for documenting all aspects of crisis management, including incident reports, communication logs, and recovery records. Outlines reporting requirements to internal stakeholders, supervisory authorities (as per DORA), and potentially law enforcement.

  • Best practices: Use a centralized system for managing crisis-related documentation. Ensure records are accurate, complete, and readily accessible.

  • Example: A detailed incident report would be filed for each crisis, including a timeline of events, actions taken, and outcomes. This report would be submitted to the relevant supervisory authority as required by DORA.

  • Common pitfalls: Lack of proper documentation; inadequate record-keeping; failure to meet regulatory reporting requirements.

4. Implementation Guidelines

  • Step-by-step process:

1. Establish the CMT and define roles and responsibilities.

2. Develop and document the Incident Response Plan, Communication Plan, and Recovery and Restoration Plan.

3. Conduct regular training and exercises for the CMT and relevant personnel.

4. Establish a system for monitoring and reporting incidents.

5. Regularly review and update the Crisis Management Policy and related plans.

  • Roles and Responsibilities: Clearly defined in Section 3.2 (CMT) and within each plan (Incident Response, Communication, Recovery).

5. Monitoring and Review

  • Monitoring effectiveness: Track the number and severity of incidents, the time taken to resolve incidents, and the effectiveness of communication and recovery efforts. Regularly assess the effectiveness of the CMT and its response to incidents. Conduct regular tabletop exercises and simulations.

  • Frequency and process: The Crisis Management Policy and associated plans should be reviewed and updated at least annually, or more frequently if significant changes occur (e.g., new technologies, regulatory updates, major incidents). The review process should involve the CMT and other relevant stakeholders.

6. Related Documents

  • ICT Risk Management Policy

  • Business Continuity Plan

  • Data Breach Response Plan

  • Cybersecurity Policy

  • Incident Reporting Policy

7. Compliance Considerations

  • Specific DORA clauses/controls: This policy directly addresses DORA's requirements regarding incident management, ICT risk management, recovery planning, and reporting to supervisory authorities. Specifically, it contributes to fulfilling Articles 3, 4, 5, 6, 7 and 8 of the DORA regulation.

  • Legal/regulatory requirements: Compliance with GDPR, NIS2 Directive (where applicable), and other relevant national and international laws and regulations related to data protection, cybersecurity, and financial stability must be considered when developing and implementing this policy. This policy ensures compliance with the obligation to report significant incidents to supervisory authorities as per DORA timelines and requirements.

This template provides a robust framework. It needs to be adapted and tailored to the specific risks and circumstances of the organization. Remember that regular testing and updates are crucial for maintaining the effectiveness of this policy and ensuring ongoing compliance with DORA.

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