Cybersecurity Policy Template
ICT Risk Management Policy (DORA Compliant)
1. Introduction
1.1 Purpose and Scope: This policy establishes a framework for identifying, assessing, managing, and mitigating Information and Communication Technology (ICT) risks within [Organization Name]. It aims to ensure the confidentiality, integrity, and availability (CIA triad) of ICT systems and data, aligning with the Digital Operational Resilience Act (DORA) requirements and promoting operational resilience. This policy applies to all ICT systems, data, and processes used by [Organization Name], including but not limited to networks, servers, applications, databases, and endpoints.
1.2 Relevance to DORA: This policy directly addresses DORA's requirements for ICT risk management, particularly focusing on identifying and mitigating risks that could significantly disrupt critical operations. It ensures compliance with articles related to incident reporting, recovery time objectives (RTOs), recovery point objectives (RPOs), and the implementation of robust ICT risk management processes. Specific DORA clauses addressed are detailed in Section 7.
2. Key Components
This ICT Risk Management Policy includes the following key components:
Risk Identification and Assessment: Identifying potential ICT risks and assessing their likelihood and impact.
Risk Treatment and Mitigation: Defining strategies to address identified risks, including avoidance, mitigation, transfer, and acceptance.
Incident Management: Establishing procedures for handling ICT incidents and security breaches.
Business Continuity and Disaster Recovery: Planning for business disruptions and ensuring timely recovery of critical ICT systems.
Vulnerability Management: Identifying and addressing vulnerabilities in ICT systems.
Third-Party Risk Management: Managing risks associated with third-party vendors and suppliers.
Security Awareness Training: Educating employees about ICT security risks and best practices.
Monitoring and Review: Regularly monitoring the effectiveness of the policy and reviewing it periodically.
3. Detailed Content
3.1 Risk Identification and Assessment:
In-depth explanation: This involves systematically identifying potential threats (e.g., cyberattacks, natural disasters, human error) and vulnerabilities (e.g., software bugs, weak passwords, insufficient access controls) that could impact ICT systems and data. A risk assessment matrix should be used to quantify the likelihood and impact of each identified risk.
Best practices: Use a combination of qualitative and quantitative methods, including risk registers, threat modeling, vulnerability scanning, and penetration testing. Involve subject matter experts from various departments.
Example: A risk assessment might identify the risk of a ransomware attack (threat) exploiting a vulnerability in outdated software (vulnerability). The likelihood might be assessed as "medium" due to the prevalence of ransomware, and the impact might be assessed as "high" due to potential data loss and operational disruption.
Common pitfalls: Failing to consider all potential threats, relying solely on qualitative assessments, neglecting human error as a risk factor.
3.2 Risk Treatment and Mitigation:
In-depth explanation: This involves developing strategies to address identified risks. Strategies include avoidance (e.g., not using a specific technology), mitigation (e.g., implementing security controls), transfer (e.g., purchasing cyber insurance), and acceptance (e.g., accepting a low-likelihood, low-impact risk).
Best practices: Prioritize risks based on their likelihood and impact. Implement a layered security approach. Regularly review and update mitigation strategies.
Example: For the ransomware risk identified above, mitigation strategies could include patching outdated software, implementing multi-factor authentication, and conducting regular backups.
Common pitfalls: Failing to implement chosen mitigation strategies, insufficient resource allocation for risk treatment.
3.3 Incident Management:
In-depth explanation: This involves establishing procedures for responding to ICT incidents and security breaches. This includes incident reporting, investigation, containment, eradication, recovery, and post-incident review.
Best practices: Define roles and responsibilities, establish clear communication channels, maintain an incident response plan, regularly test the plan. Comply with DORA's incident reporting requirements.
Example: An incident response plan should outline the steps to take if a ransomware attack occurs, including isolating infected systems, notifying relevant stakeholders, and engaging with law enforcement if necessary.
Common pitfalls: Inadequate incident response plan, lack of communication, failure to follow established procedures.
3.4 Business Continuity and Disaster Recovery:
In-depth explanation: This involves planning for business disruptions and ensuring the timely recovery of critical ICT systems and data. This includes defining RTOs and RPOs for critical systems.
Best practices: Develop comprehensive business continuity and disaster recovery plans, regularly test the plans, maintain backups, and establish an alternative site or cloud-based infrastructure.
Example: The RTO for the company's online banking system might be 4 hours, and the RPO might be 24 hours. The disaster recovery plan should detail how to restore the system within these timeframes.
Common pitfalls: Insufficient testing of plans, inadequate backup procedures, lack of an alternative site.
3.5 - 3.8 (Vulnerability Management, Third-Party Risk Management, Security Awareness Training, Monitoring and Review): Similar detailed explanations, best practices, examples, and common pitfalls can be provided for these sections, mirroring the structure above.
4. Implementation Guidelines
Step 1: Establish a cross-functional ICT Risk Management team.
Step 2: Conduct a comprehensive ICT risk assessment.
Step 3: Develop risk treatment plans.
Step 4: Implement security controls and mitigation strategies.
Step 5: Develop and test incident response, business continuity, and disaster recovery plans.
Step 6: Implement security awareness training programs.
Step 7: Establish monitoring and review procedures.
Roles and Responsibilities: Define roles and responsibilities for all members of the ICT Risk Management team, including responsibility for risk identification, assessment, treatment, reporting, and oversight.
5. Monitoring and Review
This policy will be reviewed and updated at least annually or more frequently if necessary due to significant changes in the ICT environment, regulatory requirements, or significant incidents. Key performance indicators (KPIs) will track the effectiveness of the implemented risk management strategies, including the number of security incidents, the time taken to resolve incidents, and the effectiveness of mitigation strategies. Regular reporting to senior management is crucial.
6. Related Documents
[Organization Name]'s Data Protection Policy
[Organization Name]'s Security Awareness Training Program
[Organization Name]'s Incident Response Plan
[Organization Name]'s Business Continuity Plan
[Organization Name]'s Disaster Recovery Plan
7. Compliance Considerations
This ICT Risk Management Policy addresses the following DORA requirements (replace with specific article numbers):
Article X: Incident reporting and management
Article Y: Recovery time objectives (RTOs) and recovery point objectives (RPOs)
Article Z: Third-party risk management
Article W: ICT security standards and controls
This policy also considers relevant legal and regulatory requirements, including [mention specific national or EU regulations relevant to data protection and cybersecurity]. The organization will ensure ongoing compliance with all applicable laws and regulations.
This template provides a comprehensive framework. Specific details need to be tailored to the organization's size, structure, and ICT infrastructure. Consult with legal and cybersecurity experts to ensure full compliance with DORA and all applicable regulations.
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