Cybersecurity Policy Template

ICT Security Policy: DORA Compliant Template

1. Introduction

1.1 Purpose and Scope:

This ICT Security Policy establishes the organization's commitment to protecting its Information and Communication Technology (ICT) systems, data, and intellectual property from unauthorized access, use, disclosure, disruption, modification, or destruction. This policy applies to all employees, contractors, third-party vendors, and any individuals accessing the organization's ICT systems and data, regardless of location. It aims to ensure compliance with the Digital Operational Resilience Act (DORA) and maintain the operational resilience of the organization's ICT infrastructure.

1.2 Relevance to DORA:

This policy directly addresses several key aspects of DORA, including:

  • ICT risk management: The policy outlines a framework for identifying, assessing, and mitigating ICT-related risks impacting the organization's operational resilience.

  • Incident management: The policy defines procedures for detecting, responding to, and recovering from ICT security incidents.

  • Third-party risk management: The policy addresses the security responsibilities of third-party vendors accessing the organization's systems.

  • Data protection: The policy incorporates measures to protect sensitive data in accordance with DORA and relevant data protection regulations (e.g., GDPR).

  • Business continuity planning: The policy contributes to overall business continuity planning by outlining measures to ensure the continued operation of critical ICT systems.

2. Key Components

This ICT Security Policy comprises the following key components:

  • Access Control: Managing user access to systems and data.

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

  • Network Security: Securing network infrastructure and communications.

  • Endpoint Security: Protecting individual devices (computers, mobile phones, etc.).

  • Incident Management: Responding to and recovering from security incidents.

  • Third-Party Risk Management: Managing security risks associated with external vendors.

  • Security Awareness Training: Educating employees about security threats and best practices.

  • Vulnerability Management: Identifying and mitigating security vulnerabilities.

  • Business Continuity and Disaster Recovery: Planning for disruptions and ensuring system recovery.

3. Detailed Content

3.1 Access Control:

  • In-depth explanation: This section outlines the principles and mechanisms for controlling access to ICT systems and data, based on the principle of least privilege. It includes password management policies, multi-factor authentication (MFA), access control lists (ACLs), and role-based access control (RBAC).

  • Best practices: Implement strong password policies (length, complexity, regular changes), enforce MFA for all sensitive systems, regularly review and update access rights, utilize RBAC to restrict access based on roles and responsibilities.

  • Example: All employees accessing the customer database must use MFA (e.g., password + one-time code from an authenticator app). Access is granted based on job roles defined in the RBAC system, limiting access to only necessary data.

  • Pitfalls: Weak passwords, shared accounts, lack of regular access reviews, failure to implement MFA.

3.2 Data Security:

  • In-depth explanation: This section covers measures to protect data confidentiality, integrity, and availability, including data encryption (both in transit and at rest), data loss prevention (DLP) tools, data backup and recovery procedures, and data classification.

  • Best practices: Encrypt all sensitive data, implement DLP solutions to prevent unauthorized data transfer, perform regular data backups to geographically separate locations, classify data based on sensitivity and apply appropriate security controls.

  • Example: All customer payment information is encrypted both in transit (using HTTPS) and at rest (using disk encryption). Regular backups are performed and stored in a cloud-based repository in a different geographical region.

  • Pitfalls: Lack of data encryption, inadequate backup procedures, insufficient data classification, failure to implement DLP measures.

3.3 Network Security:

  • In-depth explanation: This section covers measures to secure the organization's network infrastructure, including firewalls, intrusion detection/prevention systems (IDS/IPS), virtual private networks (VPNs), and network segmentation.

  • Best practices: Implement robust firewalls, deploy IDS/IPS to detect and prevent malicious activity, use VPNs for remote access, segment the network to isolate critical systems.

  • Example: All network traffic is filtered by a stateful firewall. An IDS monitors network traffic for malicious activity, and alerts are sent to the security team. Remote access is secured using VPNs with strong authentication.

  • Pitfalls: Outdated firewalls, lack of IDS/IPS, inadequate VPN configuration, failure to segment the network.

3.4 Endpoint Security:

  • In-depth explanation: This section addresses the security of individual devices, including antivirus software, endpoint detection and response (EDR) solutions, and device management policies.

  • Best practices: Install and regularly update antivirus software on all devices, deploy EDR solutions to detect and respond to threats, implement device management policies (e.g., password policies, software updates).

  • Example: All company laptops are equipped with antivirus software, EDR, and disk encryption. Regular software updates are enforced through a centralized management system.

  • Pitfalls: Outdated antivirus software, lack of EDR, failure to enforce software updates, weak device security policies.

(Continue with similar detailed explanations for Incident Management, Third-Party Risk Management, Security Awareness Training, Vulnerability Management, and Business Continuity and Disaster Recovery, following the same structure: In-depth explanation, Best practices, Example, Pitfalls.)

4. Implementation Guidelines

  • Step-by-step process:

1. Assessment: Conduct a thorough assessment of current ICT security posture.

2. Gap Analysis: Identify gaps between current state and policy requirements.

3. Implementation Plan: Develop a detailed plan outlining implementation steps, timelines, and resource allocation.

4. Training: Provide comprehensive security awareness training to all employees.

5. Deployment: Implement the security controls outlined in this policy.

6. Testing: Regularly test the effectiveness of security controls.

7. Monitoring: Continuously monitor the security environment.

  • Roles and responsibilities:

* Chief Information Security Officer (CISO): Overall responsibility for ICT security.

* IT Department: Responsible for implementing and maintaining security controls.

* Employees: Responsible for adhering to the policy and reporting security incidents.

5. Monitoring and Review

  • Monitoring: Regular monitoring of security logs, vulnerability scans, penetration testing, security awareness training completion rates, and incident response times.

  • Frequency and process: This policy will be reviewed and updated at least annually, or more frequently as needed, to reflect changes in technology, threats, and regulatory requirements. A formal review process will involve relevant stakeholders, including the CISO, IT department, and legal counsel.

6. Related Documents

  • Incident Response Plan

  • Data Breach Notification Plan

  • Business Continuity Plan

  • Acceptable Use Policy

  • Third-Party Vendor Management Policy

7. Compliance Considerations

  • Specific DORA clauses addressed: This policy directly addresses DORA requirements related to ICT risk management, incident reporting, recovery time objectives (RTOs), and recovery point objectives (RPOs), third-party risk management, and outsourcing.

  • Legal and regulatory requirements: This policy complies with all applicable data protection regulations (e.g., GDPR) and other relevant laws and regulations.

This template provides a comprehensive framework for an ICT Security Policy compliant with DORA. Remember to tailor it to your specific organizational context and risk profile. Regular updates and adherence to this policy are crucial for maintaining operational resilience and protecting your organization from cyber threats.

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