Cybersecurity Policy Template

Internal Audit and Assurance Policy: ICT Resilience and Security

1. Introduction

1.1 Purpose and Scope: This policy establishes a framework for regular internal audits and assurance activities to ensure compliance with ICT resilience and security policies, aligning with the Digital Operational Resilience Act (DORA). The scope encompasses all ICT systems, applications, and data that are critical to the organization's operations and the provision of financial services. This includes, but is not limited to, network infrastructure, databases, applications, cloud services, and data centers.

1.2 Relevance to DORA: DORA mandates robust ICT resilience and security measures. This policy directly supports DORA's requirements by providing a mechanism for:

  • Identifying and assessing ICT risks: Regular audits identify vulnerabilities and weaknesses in ICT systems.

  • Ensuring effective risk management: Audits verify the implementation and effectiveness of risk mitigation strategies.

  • Demonstrating compliance: Audit reports provide evidence of compliance with DORA and internal policies.

  • Improving incident response: Audits identify weaknesses that could impact incident response capabilities.

  • Promoting continuous improvement: Regular reviews and updates ensure the policy remains relevant and effective.

2. Key Components

This policy comprises the following key components:

  • Audit Scope and Frequency: Defines what systems and processes are audited and how often.

  • Audit Methodology: Details the approach and techniques used for conducting audits.

  • Reporting and Remediation: Outlines the reporting process and requirements for addressing identified deficiencies.

  • Roles and Responsibilities: Clearly defines the roles and responsibilities of individuals and teams involved in the audit process.

  • Documentation and Record Keeping: Specifies the types of documentation required and how they should be maintained.

  • Independent Oversight: Describes the mechanism for independent oversight of the audit process.

3. Detailed Content

3.1 Audit Scope and Frequency:

  • In-depth explanation: This section specifies the ICT systems, applications, and data included in the audit scope. It should prioritize critical systems impacting financial services. A risk-based approach should determine audit frequency. Higher-risk systems should be audited more frequently (e.g., quarterly). Lower-risk systems may be audited annually.

  • Best practices: Categorize systems by risk level (high, medium, low) using a documented risk assessment methodology. Use a schedule to ensure all systems are audited within a defined timeframe.

  • Example: High-risk systems (e.g., core banking system, payment processing system) will be audited quarterly. Medium-risk systems (e.g., customer relationship management system) will be audited semi-annually. Low-risk systems (e.g., internal communication platform) will be audited annually.

  • Common pitfalls: Failing to include all critical systems, inconsistent audit frequency, neglecting to update the scope based on changes in the IT environment.

3.2 Audit Methodology:

  • In-depth explanation: This section describes the audit methodology, including the use of checklists, questionnaires, vulnerability scans, penetration testing, and interviews. It should specify the standards and frameworks used (e.g., ISO 27001, NIST Cybersecurity Framework).

  • Best practices: Use a combination of methods to obtain a comprehensive assessment. Document the methodology clearly for repeatability and consistency. Use standardized templates and checklists.

  • Example: Audits will use a combination of vulnerability scans (Nessus), penetration testing (ethical hacking), review of security logs, and interviews with system administrators. A standardized checklist will be used to ensure consistent coverage of key controls.

  • Common pitfalls: Relying solely on one method, lack of documentation, inconsistent application of the methodology.

3.3 Reporting and Remediation:

  • In-depth explanation: This section defines the format and content of audit reports. It should include a summary of findings, recommendations for remediation, and a timeline for implementation. It should also detail the process for tracking and verifying the implementation of remediation actions.

  • Best practices: Use a standardized reporting template. Prioritize findings based on their severity and potential impact. Require management responses to all findings. Track remediation progress using a dedicated system.

  • Example: Audit reports will follow a standardized template, including an executive summary, detailed findings, remediation recommendations, and a responsible party and completion date. A remediation tracker will monitor progress and ensure timely completion.

  • Common pitfalls: Inconsistent reporting formats, lack of prioritization of findings, inadequate tracking of remediation efforts.

3.4 Roles and Responsibilities:

  • In-depth explanation: Clearly defines roles (e.g., Internal Audit team, ICT department, management) and responsibilities in planning, executing, and following up on audits.

  • Best practices: Assign clear responsibilities to ensure accountability. Provide adequate training to individuals involved in the audit process.

  • Example: The Internal Audit team is responsible for planning and executing audits. The ICT department is responsible for providing access to systems and data. Management is responsible for approving remediation plans and monitoring progress.

  • Common pitfalls: Unclear roles and responsibilities, lack of training, inadequate communication.

3.5 Documentation and Record Keeping:

  • In-depth explanation: Specifies the types of documents to be maintained (e.g., audit plans, audit reports, remediation plans, risk assessments). It should outline retention policies.

  • Best practices: Use a secure document management system. Implement version control. Ensure documents are easily accessible and auditable.

  • Example: All audit documentation will be stored in a secure, centralized repository. Retention policy: audit reports – 7 years, remediation plans – 2 years after completion.

  • Common pitfalls: Poor record-keeping practices, lack of version control, difficulty accessing documents.

3.6 Independent Oversight:

  • In-depth explanation: This section describes how the audit process is overseen independently, ensuring objectivity and impartiality. This might involve an external audit or a review by a dedicated audit committee.

  • Best practices: Establish an independent oversight body to review audit plans, reports, and the overall effectiveness of the internal audit function.

  • Example: The Audit Committee reviews the annual audit plan and reports. An external audit is conducted every three years to assess the effectiveness of the internal audit function.

  • Common pitfalls: Lack of independent oversight, bias in the audit process.

4. Implementation Guidelines

1. Develop a detailed audit plan: Identify critical systems, define audit scope and frequency, and assign responsibilities.

2. Develop audit procedures: Establish standardized checklists, questionnaires, and testing procedures.

3. Train audit personnel: Provide training on the audit methodology, relevant regulations (DORA), and internal policies.

4. Conduct pilot audits: Conduct pilot audits to test the procedures and refine the approach.

5. Implement the audit program: Commence regular audits according to the plan.

6. Monitor remediation efforts: Track remediation actions and ensure timely completion.

7. Review and update the policy: Regularly review and update the policy to ensure its relevance and effectiveness.

5. Monitoring and Review

The effectiveness of this policy will be monitored through:

  • Regular review of audit reports: Analysis of trends and patterns in audit findings to identify areas for improvement.

  • Feedback from stakeholders: Gathering feedback from audit participants and management to assess the policy's effectiveness.

  • Annual review of the policy: Formal review of the policy by the Audit Committee to ensure its continued relevance and alignment with DORA and other regulations.

6. Related Documents

  • ICT Resilience and Security Policy

  • Incident Management Policy

  • Business Continuity Plan

  • Data Protection Policy

  • Risk Management Framework

7. Compliance Considerations

This policy directly addresses several aspects of DORA, including:

  • Article 4 (Risk Management): The policy ensures a robust framework for identifying, assessing, and mitigating ICT risks.

  • Article 5 (ICT risk assessment and management): Regular audits verify the implementation and effectiveness of risk management measures.

  • Article 7 (Incident reporting and management): Audits identify potential weaknesses impacting incident response capabilities.

  • Article 10 (Oversight and supervision): The policy includes provisions for independent oversight of the audit process.

This policy should also consider any relevant national or regional legal and regulatory requirements related to data protection, cybersecurity, and financial services. Compliance with GDPR, for example, is crucial and should be integrated into the audit process.

This template provides a comprehensive framework. Organizations should tailor it to their specific circumstances, ensuring it aligns with their unique risk profile and regulatory requirements. Remember to consult with legal and compliance professionals to ensure full compliance with DORA and all applicable regulations.

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