Cybersecurity Policy Template
Oversight and Governance Policy for ICT Risk Management (DORA Compliant)
1. Introduction
1.1 Purpose and Scope: This policy establishes a robust framework for the oversight and governance of Information and Communication Technology (ICT) risk management within [Organization Name], aligning with the requirements of the Digital Operational Resilience Act (DORA). It defines roles, responsibilities, and accountabilities across the organization, ensuring effective identification, assessment, mitigation, and monitoring of ICT risks that could impact the organization's operational resilience. This policy applies to all ICT systems, processes, and data critical to the organization's operations, including those supporting financial services activities.
1.2 Relevance to DORA: This policy directly addresses DORA's requirements regarding ICT risk management, incident reporting, and recovery, ensuring compliance with Articles 4, 5, 6, 7, and 8, amongst others. Specifically, it ensures the establishment of a robust governance structure, clearly defined roles and responsibilities, and effective mechanisms for identifying, assessing, and mitigating ICT risks impacting the organization's ability to provide financial services.
2. Key Components
This Oversight and Governance Policy comprises the following key components:
ICT Risk Governance Structure: Defining roles and responsibilities of the Board, senior management, and relevant committees.
Risk Identification and Assessment: Processes for identifying and assessing ICT risks, including threat modeling and vulnerability analysis.
Risk Mitigation and Treatment: Strategies and plans for mitigating identified risks, including controls implementation and testing.
Incident Management and Response: Procedures for managing and responding to ICT incidents, including escalation paths and communication protocols.
Recovery and Resilience Planning: Development and regular testing of business continuity and disaster recovery plans for ICT systems.
Monitoring and Reporting: Mechanisms for monitoring the effectiveness of ICT risk management processes and reporting to relevant stakeholders.
Third-Party Risk Management: Processes for assessing and managing ICT risks associated with third-party providers.
Data Security and Privacy: Policies and procedures ensuring the confidentiality, integrity, and availability of data.
3. Detailed Content
3.1 ICT Risk Governance Structure:
In-depth explanation: This section defines the roles and responsibilities of the Board, senior management (including the Chief Information Security Officer - CISO), and the ICT Risk Committee (or equivalent). It clarifies accountability for ICT risk management at each level.
Best practices: Establish a clear reporting line for ICT risk matters to the Board, with regular reporting on key risk indicators (KRIs). The ICT Risk Committee should be composed of individuals with diverse expertise and independent oversight capabilities.
Example: The Board is ultimately responsible for overseeing ICT risk management. The CISO is accountable for the day-to-day management of ICT risks and reports directly to the Chief Operating Officer (COO). The ICT Risk Committee, chaired by a non-executive director, reviews risk assessments, mitigation plans, and incident reports.
Common pitfalls: Lack of clear roles and responsibilities, insufficient Board engagement, lack of independent oversight, and inadequate resources allocated to ICT risk management.
3.2 Risk Identification and Assessment: (Repeat this structure for each key component)
In-depth explanation: This section outlines the methodology for identifying and assessing ICT risks, including threat modeling, vulnerability assessments, penetration testing, and business impact analysis (BIA).
Best practices: Use a risk register to document identified risks, their likelihood, and their potential impact. Employ a standardized risk assessment framework (e.g., NIST Cybersecurity Framework). Conduct regular vulnerability scans and penetration testing.
Example: The organization uses a combination of automated vulnerability scanning tools, penetration testing by external security experts, and threat modeling workshops to identify potential risks. The BIA identifies critical systems and their dependencies to determine the impact of potential disruptions.
Common pitfalls: Incomplete risk identification, inaccurate risk assessment, failure to consider emerging threats, and lack of documented evidence.
3.3 Risk Mitigation and Treatment:
In-depth explanation: This section describes how identified risks are mitigated, including implementing security controls, developing incident response plans, and establishing recovery strategies.
Best practices: Implement a layered security approach, utilizing multiple controls to protect against various threats. Regularly review and update mitigation plans based on risk assessments and emerging threats.
Example: Implementation of multi-factor authentication, intrusion detection systems, data loss prevention tools, and regular security awareness training for employees. Development of a comprehensive incident response plan outlining procedures for identifying, containing, eradicating, recovering from, and learning from security incidents.
Common pitfalls: Insufficient resources allocated to implement controls, inadequate testing of controls, and lack of monitoring of control effectiveness.
3.4 Incident Management and Response:
In-depth explanation: This section details the procedures for managing and responding to ICT incidents, including escalation procedures, communication protocols, and post-incident reviews.
Best practices: Establish clear escalation paths for reporting and managing incidents. Develop communication plans to ensure timely and effective communication with stakeholders. Conduct regular incident response drills and exercises.
Example: A detailed incident response plan outlining roles and responsibilities, communication protocols, and escalation procedures for different types of ICT incidents. The plan includes a dedicated communication channel for reporting incidents and regular exercises to test the effectiveness of the plan.
Common pitfalls: Lack of a clear incident response plan, inadequate communication during incidents, failure to conduct post-incident reviews, and delays in incident reporting to regulators.
3.5 Recovery and Resilience Planning:
In-depth explanation: This section covers the development and testing of business continuity and disaster recovery plans for ICT systems.
Best practices: Develop comprehensive plans that address various scenarios, including natural disasters, cyberattacks, and equipment failures. Regularly test and update plans to ensure their effectiveness.
Example: A comprehensive business continuity plan that includes alternative sites for critical systems, data backup and recovery procedures, and communication plans for employees and customers. Regular testing of the plan through drills and simulations.
Common pitfalls: Inadequate planning, infrequent testing of plans, lack of realistic scenarios, and insufficient resources allocated to recovery efforts.
3.6 Monitoring and Reporting:
In-depth explanation: This section defines the mechanisms for monitoring the effectiveness of ICT risk management processes and reporting to stakeholders.
Best practices: Use key risk indicators (KRIs) to monitor the effectiveness of controls and identify emerging risks. Regularly report on ICT risk management performance to the Board, senior management, and the ICT Risk Committee.
Example: Monthly reporting on key security metrics, including the number of security incidents, vulnerabilities discovered, and the time taken to remediate vulnerabilities. Quarterly review of the ICT risk register by the ICT Risk Committee.
Common pitfalls: Lack of effective monitoring mechanisms, infrequent reporting, and inadequate analysis of monitoring data.
3.7 Third-Party Risk Management:
In-depth explanation: This section outlines the process for assessing and managing ICT risks associated with third-party providers.
Best practices: Conduct due diligence on third-party providers, including security assessments and background checks. Include contractual requirements for security controls and incident reporting.
Example: A standardized due diligence questionnaire for assessing the security posture of third-party providers. Inclusion of security clauses in contracts with third-party providers, specifying their responsibilities for data security and incident reporting.
Common pitfalls: Failure to conduct adequate due diligence, insufficient contractual requirements, and lack of monitoring of third-party performance.
3.8 Data Security and Privacy:
In-depth explanation: This section outlines policies and procedures to ensure the confidentiality, integrity, and availability of data.
Best practices: Implement data encryption, access control measures, and data loss prevention tools. Comply with relevant data privacy regulations (e.g., GDPR).
Example: A data security policy that outlines data classification, access control rules, and encryption requirements. Implementation of data loss prevention tools to prevent sensitive data from leaving the organization's network.
Common pitfalls: Inadequate data classification, insufficient access controls, failure to comply with data privacy regulations, and lack of data backup and recovery procedures.
4. Implementation Guidelines
4.1 Step-by-Step Process:
1. Establish the ICT Risk Committee: Define its membership, charter, and reporting lines.
2. Conduct a comprehensive ICT risk assessment: Identify and assess all significant ICT risks.
3. Develop risk mitigation plans: Outline specific controls and actions to mitigate identified risks.
4. Implement security controls: Deploy necessary security technologies and processes.
5. Develop incident response and business continuity plans: Establish procedures for managing ICT incidents and ensuring operational resilience.
6. Establish monitoring and reporting mechanisms: Define key risk indicators (KRIs) and reporting frequency.
7. Train employees: Conduct awareness training on ICT security and incident reporting.
8. Regularly review and update the policy: Ensure the policy remains relevant and effective.
4.2 Roles and Responsibilities: (Detailed breakdown for each role mentioned above)
5. Monitoring and Review
This policy will be reviewed and updated at least annually or more frequently as needed, following significant changes in the organization's ICT infrastructure, regulatory landscape, or risk profile. The ICT Risk Committee will oversee the monitoring process, utilizing KRIs and regular reports to assess the effectiveness of the policy and its implementation. Internal audits and external assessments will also contribute to the review process.
6. Related Documents
Incident Management Policy
Business Continuity Plan
Disaster Recovery Plan
Data Security Policy
Third-Party Risk Management Policy
Information Security Policy
7. Compliance Considerations
This policy directly addresses several key aspects of DORA, including but not limited to:
Article 4 (Governance): Establishes a robust governance structure for ICT risk management.
Article 5 (Risk Management): Outlines processes for identifying, assessing, and mitigating ICT risks.
Article 6 (Incident Reporting): Defines procedures for reporting and managing ICT incidents.
Article 7 (ICT Security): Addresses requirements for securing ICT systems and data.
Article 8 (Recovery): Sets out the requirements for business continuity and disaster recovery planning.
The policy should also be aligned with other relevant regulations and standards, such as GDPR, NIS2, and national cybersecurity laws. Legal counsel should be consulted to ensure full compliance with all applicable regulations. Non-compliance with this policy may result in disciplinary action, up to and including termination of employment.
This template provides a comprehensive framework. It should be adapted to reflect the specific circumstances and risk profile of your organization. Remember to involve legal and security experts throughout the implementation process to ensure compliance and effectiveness.
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