Cybersecurity Policy Template

DORA Compliant Cybersecurity Policy Template

1. Introduction

1.1 Purpose and Scope:

This Cybersecurity Policy establishes a comprehensive framework for identifying, assessing, mitigating, and monitoring cybersecurity risks within [Organization Name]. It aims to protect the confidentiality, integrity, and availability (CIA triad) of all organizational data, systems, and applications, aligning with the Digital Operational Resilience Act (DORA) requirements. This policy applies to all employees, contractors, third-party vendors, and any individual with access to [Organization Name]'s information systems and data.

1.2 Relevance to DORA:

This policy directly addresses DORA's mandates regarding ICT risk management, incident reporting, and recovery. Specifically, it covers aspects related to:

  • ICT risk management (Article 4): By establishing a robust framework for identifying, assessing, and mitigating cybersecurity risks.

  • Incident reporting (Article 10 & 11): Defining procedures for reporting, managing, and recovering from cybersecurity incidents.

  • Recovery (Article 12): Outlining plans and procedures for restoring systems and data following a cybersecurity incident.

  • Third-party risk management (Article 13): Addressing the cybersecurity risks associated with third-party vendors and service providers.

2. Key Components

This Cybersecurity Policy encompasses the following key components:

  • Risk Assessment and Management: Identifying and prioritizing cybersecurity risks.

  • Access Control and Authentication: Restricting access to sensitive data and systems.

  • Data Security: Protecting the confidentiality, integrity, and availability of data.

  • Network Security: Securing the organization's network infrastructure.

  • Incident Response: Handling and recovering from security incidents.

  • Security Awareness Training: Educating employees on cybersecurity best practices.

  • Vulnerability Management: Identifying and addressing security vulnerabilities.

  • Third-Party Risk Management: Managing cybersecurity risks associated with third-party vendors.

  • Business Continuity and Disaster Recovery: Ensuring business continuity in the event of a major incident.

3. Detailed Content

3.1 Risk Assessment and Management:

  • In-depth explanation: This involves identifying potential threats, vulnerabilities, and impacts on business operations. A risk register should be maintained, documenting identified risks, their likelihood, impact, and mitigation strategies. Regular risk assessments should be conducted (at least annually, or more frequently as needed).

  • Best practices: Use a standardized risk assessment methodology (e.g., NIST Cybersecurity Framework), conduct both quantitative and qualitative assessments, involve relevant stakeholders, and prioritize risks based on their likelihood and impact.

  • Example: A risk assessment identifies the vulnerability of the organization's web application to SQL injection attacks. The likelihood is rated as "medium" and the impact as "high" due to potential data breaches. The mitigation strategy involves implementing a web application firewall (WAF) and conducting regular penetration testing.

  • Common pitfalls: Failing to consider all potential threats, using outdated risk assessment methodologies, insufficient stakeholder involvement, and neglecting to update the risk register regularly.

3.2 Access Control and Authentication:

*(Continue this pattern for each Key Component – Data Security, Network Security, Incident Response, etc. Each section should include in-depth explanations, best practices, detailed examples, and common pitfalls as shown above. Here's a brief outline of what each section could contain)*

3.2 Access Control and Authentication: Implementing strong passwords, multi-factor authentication (MFA), role-based access control (RBAC), and regular access reviews. Example: Implementing MFA for all employees accessing sensitive systems. Pitfalls: Weak password policies, lack of MFA, excessive privileges granted to users.

3.3 Data Security: Data encryption both in transit and at rest, data loss prevention (DLP) measures, data backups and recovery plans. Example: Encrypting all customer data stored in databases using AES-256 encryption. Pitfalls: Insufficient data encryption, lack of data backup and recovery plans.

3.4 Network Security: Firewalls, intrusion detection/prevention systems (IDS/IPS), virtual private networks (VPNs), network segmentation. Example: Implementing a next-generation firewall with intrusion prevention capabilities. Pitfalls: Outdated network security devices, lack of network segmentation.

3.5 Incident Response: Defining procedures for detecting, responding to, and recovering from security incidents. Example: A detailed incident response plan outlining roles, responsibilities, communication protocols, and escalation procedures. Pitfalls: Lack of a documented incident response plan, inadequate training for incident responders.

3.6 Security Awareness Training: Regular training programs for employees on cybersecurity threats, best practices, and reporting procedures. Example: Mandatory annual security awareness training for all employees covering phishing, social engineering, and password security. Pitfalls: Infrequent or ineffective training.

3.7 Vulnerability Management: Regular vulnerability scanning and penetration testing to identify and address security weaknesses. Example: Conducting quarterly vulnerability scans using automated tools and addressing critical vulnerabilities within a defined timeframe. Pitfalls: Infrequent or inadequate vulnerability scanning.

3.8 Third-Party Risk Management: Assessing and mitigating cybersecurity risks associated with third-party vendors and service providers. Example: Requiring third-party vendors to comply with a security questionnaire and undergo a security assessment before engaging in business. Pitfalls: Failure to assess the security posture of third-party vendors.

3.9 Business Continuity and Disaster Recovery: Plans to ensure business continuity and data recovery in case of disruptions. Example: A detailed disaster recovery plan outlining procedures for restoring critical systems and data in the event of a disaster. Pitfalls: Lack of a comprehensive business continuity and disaster recovery plan.

4. Implementation Guidelines

1. Establish a Cybersecurity Team: Designate individuals responsible for implementing and maintaining this policy.

2. Risk Assessment: Conduct a comprehensive risk assessment to identify and prioritize risks.

3. Policy Deployment: Communicate the policy to all relevant stakeholders.

4. Training: Provide comprehensive cybersecurity awareness training.

5. System Implementations: Implement the necessary security controls.

6. Monitoring: Establish a monitoring process to track the effectiveness of the controls.

Roles and Responsibilities:

  • Chief Information Security Officer (CISO): Overall responsibility for cybersecurity.

  • IT Department: Implementation and maintenance of security controls.

  • Employees: Adherence to the policy and reporting of security incidents.

5. Monitoring and Review

  • Monitoring: Regularly monitor the effectiveness of the implemented controls through security information and event management (SIEM) systems, security audits, and vulnerability scans.

  • Review and Update: The policy should be reviewed and updated at least annually, or more frequently if necessary, to reflect changes in the threat landscape, business operations, and regulatory requirements.

6. Related Documents

  • [Link to Incident Response Plan]

  • [Link to Data Protection Policy]

  • [Link to Acceptable Use Policy]

  • [Link to Vendor Management Policy]

7. Compliance Considerations

This Cybersecurity Policy addresses DORA’s requirements regarding ICT risk management, incident reporting, and recovery, specifically Articles 4, 10, 11, 12, and 13. It also adheres to relevant data protection regulations like GDPR and national cybersecurity laws. Specific DORA clauses addressed include but are not limited to:

  • Article 4: Requirements for ICT risk management, including identification, assessment, and mitigation of risks.

  • Article 10 & 11: Requirements for incident reporting and recovery.

  • Article 12: Requirements for ICT recovery.

  • Article 13: Requirements for third-party risk management.

This template provides a comprehensive framework. You must adapt and expand upon it to fit your specific organization's size, structure, and operational context. Consider consulting with legal and cybersecurity professionals to ensure full compliance with DORA and other relevant regulations.

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