Cybersecurity Policy Template
Operational Resilience Policy
1. Introduction
1.1 Purpose and Scope: This Operational Resilience Policy outlines the framework and procedures for ensuring the continuity and safety of critical services provided by [Organization Name] in accordance with the Digital Operational Resilience Act (DORA). This policy applies to all departments, business units, and individuals within [Organization Name] responsible for the operation and maintenance of critical services impacting financial markets infrastructure (FMI). The policy aims to identify, assess, manage, and mitigate operational risks that could disrupt the provision of these critical services, ensuring continued functionality during and after disruptive events.
1.2 Relevance to DORA: This policy directly addresses the requirements of DORA, specifically focusing on identifying Important Business Services (IBS), conducting impact assessments, developing and testing resilience strategies, and reporting on operational resilience. It ensures compliance with DORA's mandate to maintain the stability and integrity of the financial system.
2. Key Components
This Operational Resilience Policy comprises the following key components:
Identification of Important Business Services (IBS): Defining and documenting critical services impacting FMI.
Impact Assessment: Evaluating the potential impact of disruptions to IBS.
Resilience Capacity Planning: Defining recovery time objectives (RTOs) and recovery point objectives (RPOs) for each IBS.
Incident Management: Establishing processes for responding to and recovering from incidents affecting IBS.
Testing and Exercising: Regularly testing and validating the effectiveness of resilience strategies.
Governance and Oversight: Establishing roles, responsibilities, and reporting mechanisms.
Continuous Improvement: Implementing a process for reviewing and improving the operational resilience framework.
3. Detailed Content
3.1 Identification of Important Business Services (IBS):
In-depth explanation: This involves a rigorous process to identify all services critical to the organization's operations and those impacting FMI. This requires considering both internal and external dependencies. The identification must be documented and regularly reviewed.
Best practices: Utilize a risk-based approach, involving stakeholders from across the organization. Consider using a standardized methodology for classifying services based on their criticality and impact.
Example: A payment processing system would be considered an IBS due to its direct impact on FMI. Similarly, a system managing client account information would also be classified as an IBS given its centrality to financial operations and the potential ramifications for customers and the market. A less critical system, such as an internal email system, might not be classified as an IBS unless its failure caused knock-on effects on other IBS.
Common pitfalls: Underestimating the interconnectedness of services, overlooking indirect impacts, neglecting to consider third-party dependencies.
3.2 Impact Assessment:
In-depth explanation: Assess the potential impact of disruptions to each IBS, considering severity, duration, and likelihood. This involves analyzing potential threats (e.g., cyberattacks, natural disasters, human error) and their potential consequences.
Best practices: Use quantitative and qualitative methods to assess impact, involving subject matter experts. Consider scenarios analysis (e.g., what-if scenarios).
Example: For the payment processing system (IBS), an impact assessment might conclude that a prolonged outage (e.g., >24 hours) could result in significant financial losses, reputational damage, regulatory penalties, and legal action.
Common pitfalls: Using overly simplistic methodologies, failing to consider cascading effects, neglecting to involve key stakeholders.
3.3 Resilience Capacity Planning:
In-depth explanation: Define RTOs and RPOs for each IBS. RTO is the maximum acceptable downtime, while RPO is the maximum acceptable data loss. Develop recovery strategies including recovery plans and procedures.
Best practices: Set realistic and achievable RTOs and RPOs based on the impact assessment. Prioritize critical services and allocate resources accordingly.
Example: For the payment processing system (IBS), the RTO might be set at 4 hours, and the RPO at 15 minutes. The recovery strategy would include failover systems, backup data centers, and disaster recovery procedures.
Common pitfalls: Setting overly ambitious RTOs and RPOs, neglecting to adequately test recovery plans, failing to consider resource constraints.
3.4 Incident Management:
In-depth explanation: Establish clear procedures for responding to and recovering from incidents affecting IBS. This includes communication protocols, escalation paths, and post-incident reviews.
Best practices: Develop a comprehensive incident response plan with clearly defined roles and responsibilities. Regularly test and update the plan.
Example: A communication plan would clearly define who is responsible for communicating the incident to stakeholders (internal and external), including regulators. Escalation paths should specify who to contact in case of escalating issues.
Common pitfalls: Lack of clear roles and responsibilities, inadequate communication, insufficient training, inadequate post-incident analysis.
3.5 Testing and Exercising:
In-depth explanation: Regularly test and exercise the resilience strategies, including incident response plans and recovery procedures. This should include simulated disruptions of varying severities.
Best practices: Use a combination of tabletop exercises, functional tests, and full-scale simulations. Document all test results and use them to improve the resilience framework.
Example: Conduct a tabletop exercise to simulate a cyberattack on the payment processing system. This would involve key personnel reviewing the incident response plan and practicing their roles.
Common pitfalls: Insufficient testing, unrealistic scenarios, inadequate documentation of test results.
3.6 Governance and Oversight:
In-depth explanation: Define roles, responsibilities, and reporting mechanisms for operational resilience. Establish a steering committee to oversee the program.
Best practices: Clearly define roles and responsibilities, assign ownership for each aspect of the resilience framework. Regularly report on progress and identify areas for improvement.
Example: A Chief Resilience Officer (CRO) could be responsible for overseeing the program. Departmental heads would be responsible for implementing the policy within their departments.
Common pitfalls: Lack of clear accountability, insufficient oversight, inadequate communication.
3.7 Continuous Improvement:
In-depth explanation: Establish a process for continuously reviewing and improving the operational resilience framework. This includes learning from incidents, incorporating best practices, and adapting to evolving threats.
Best practices: Regularly review the policy and procedures, conduct post-incident reviews, and incorporate lessons learned.
Example: After each incident, a post-incident review should be conducted to identify root causes, areas for improvement, and implement corrective actions.
Common pitfalls: Failing to learn from incidents, neglecting to adapt to changing threats.
4. Implementation Guidelines
1. Form a steering committee: Establish a cross-functional team to oversee the implementation of the policy.
2. Identify IBS: Conduct a thorough assessment to identify all IBS within the organization.
3. Conduct impact assessments: Evaluate the potential impact of disruptions to each IBS.
4. Develop recovery plans: Define RTOs and RPOs and develop recovery strategies.
5. Develop and test incident response plans: Create detailed procedures for responding to and recovering from incidents.
6. Implement monitoring and reporting mechanisms: Establish a system for tracking key metrics and reporting on progress.
7. Conduct regular testing and exercises: Regularly test the effectiveness of the resilience strategies.
Roles and Responsibilities: (Specific roles and responsibilities should be defined based on the organizational structure.) For example:
Chief Resilience Officer (CRO): Overall responsibility for operational resilience.
Department Heads: Implementation within their respective departments.
IT Department: Responsible for technical aspects of resilience.
Risk Management Department: Responsible for risk assessment and mitigation.
5. Monitoring and Review
The effectiveness of this Operational Resilience Policy will be monitored through:
Regular reporting: Monthly reports to the steering committee on key performance indicators (KPIs), such as incident frequency, recovery time, and RPO/RTO adherence.
Internal audits: Regular audits to assess compliance with the policy and identify areas for improvement.
Post-incident reviews: Comprehensive reviews of all incidents affecting IBS to identify root causes and implement corrective actions.
The policy will be reviewed and updated annually or as needed, based on regulatory changes, emerging threats, and lessons learned.
6. Related Documents
Incident Management Policy
Business Continuity Plan
Disaster Recovery Plan
Cyber Security Policy
Third-Party Risk Management Policy
7. Compliance Considerations
This Operational Resilience Policy directly addresses the requirements of DORA, specifically focusing on:
Article 3(1): Identification of IBS.
Article 4: Impact assessment.
Article 5: Resilience capacity planning and implementation.
Article 6: Testing and exercising resilience measures.
Article 7: Incident reporting.
This policy also considers all relevant legal and regulatory requirements concerning data protection, financial market integrity, and operational security, aligning with national and international best practices. It’s crucial to consult with legal counsel to ensure full compliance with all applicable regulations.
This template provides a comprehensive framework. Specific details should be tailored to the organization's unique circumstances, size, and the specific services it provides. Regular updates and reviews are essential to ensure continued relevance and effectiveness.
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