Cybersecurity Policy Template
Penetration Testing and Vulnerability Assessment Policy
1. Introduction
1.1 Purpose and Scope: This policy establishes a framework for regular penetration testing and vulnerability assessments (PTVA) across all Information and Communication Technology (ICT) systems within [Organization Name]. The objective is to proactively identify and mitigate security vulnerabilities, ensuring the confidentiality, integrity, and availability of data and systems, in accordance with the Digital Operational Resilience Act (DORA). This policy applies to all ICT systems processing, or supporting the processing of, financial transactions and critical functions, as defined by DORA.
1.2 Relevance to DORA: DORA mandates robust ICT risk management, including the identification and remediation of vulnerabilities. This policy directly addresses DORA's requirements for ICT risk management, incident reporting, and resilience testing by establishing a structured approach to PTVA. It contributes to fulfilling obligations related to:
ICT risk management: Identifying and assessing vulnerabilities is a cornerstone of effective ICT risk management.
Incident reporting: Regular PTVA can help prevent incidents by identifying vulnerabilities before they are exploited.
Resilience testing: Penetration testing simulates real-world attacks, assessing the resilience of systems to malicious activity.
Recovery time objectives (RTO) and recovery point objectives (RPO): PTVA informs the setting of realistic RTOs and RPOs by identifying vulnerabilities that could impact recovery times.
2. Key Components
This policy encompasses the following key components:
Scope Definition: Clearly defining which systems and applications are included in the PTVA program.
Testing Methodology: Outlining the types of penetration testing (e.g., black box, white box, grey box) and vulnerability scanning techniques employed.
Frequency and Scheduling: Establishing a regular schedule for PTVA activities based on risk assessment.
Reporting and Remediation: Defining the process for reporting vulnerabilities and managing their remediation.
Vendor Management: Addressing security requirements for third-party vendors who manage critical ICT systems.
Roles and Responsibilities: Clearly assigning roles and responsibilities for all stakeholders involved in the PTVA process.
3. Detailed Content
3.1 Scope Definition:
In-depth explanation: This section defines the specific ICT systems and applications covered by the PTVA program. This should include a detailed inventory, categorized by criticality based on DORA's definition of critical functions and transactions.
Best practices: Utilize a risk-based approach. Prioritize systems handling sensitive financial data or supporting critical business functions.
Example: The PTVA program covers all systems involved in payment processing (e.g., payment gateways, transaction databases), customer relationship management (CRM) systems containing sensitive customer data, and internal network infrastructure. Systems with low risk and limited financial impact may be assessed less frequently.
Common pitfalls: Failing to accurately identify all critical systems; omitting third-party systems; insufficiently classifying systems by risk level.
3.2 Testing Methodology:
In-depth explanation: This section outlines the types of penetration testing and vulnerability scanning to be performed. It should specify the testing methodologies (e.g., OWASP testing guide, NIST guidelines), tools to be used, and the scope of each test (e.g., network, application, physical).
Best practices: Utilize a combination of automated vulnerability scanning and manual penetration testing to achieve comprehensive coverage. Employ a variety of testing methodologies (black box, white box, grey box) to simulate different attack scenarios.
Example: Annual black-box penetration testing of the payment gateway, quarterly vulnerability scans of all web applications, and biannual white-box penetration testing of internal network infrastructure.
Common pitfalls: Relying solely on automated scanning; neglecting manual penetration testing; failing to consider the specific vulnerabilities relevant to the systems being tested.
3.3 Frequency and Scheduling:
In-depth explanation: This section details the frequency of PTVA activities, based on a risk assessment. High-risk systems should be tested more frequently.
Best practices: Develop a schedule that balances the need for frequent testing with resource constraints. Consider using a risk matrix to prioritize systems for testing.
Example: Payment gateway: Monthly vulnerability scans, bi-annual penetration tests; CRM system: Quarterly vulnerability scans, annual penetration test; Internal network: Annual vulnerability scans, biennial penetration tests.
Common pitfalls: Inconsistent testing frequency; neglecting to update the schedule based on risk changes; insufficient resources allocated for testing.
3.4 Reporting and Remediation:
In-depth explanation: This section outlines the process for reporting vulnerabilities identified during PTVA activities. It should define the format of vulnerability reports, the escalation process for critical vulnerabilities, and the remediation process. Include timelines for remediation.
Best practices: Use a standardized vulnerability management system to track vulnerabilities, their severity, and their remediation status. Establish clear remediation priorities based on risk level.
Example: Vulnerability reports will be submitted within 5 business days of testing completion. Critical vulnerabilities (CVSS score 9+) must be remediated within 24 hours, high-severity vulnerabilities (CVSS score 7-8) within 72 hours, and medium-severity vulnerabilities (CVSS score 4-6) within 30 days.
Common pitfalls: Inconsistent reporting; lack of clear escalation procedures; failure to track remediation progress; inadequate prioritization of vulnerabilities.
3.5 Vendor Management:
In-depth explanation: This section details how the organization ensures the security of its ICT systems managed by third-party vendors. This includes contractual requirements for security testing and reporting.
Best practices: Include specific security requirements in vendor contracts, requiring regular security assessments and penetration testing of their systems. Regularly audit vendor security practices.
Example: All vendors managing critical ICT systems will be required to provide annual penetration testing reports and vulnerability scan results.
Common pitfalls: Lack of oversight of vendor security practices; insufficient contractual security requirements.
3.6 Roles and Responsibilities:
In-depth explanation: This section clarifies roles and responsibilities for each stakeholder involved in the PTVA process, including security teams, IT operations, and business units.
Best practices: Clearly define roles and responsibilities to avoid confusion and ensure accountability.
Example: The Information Security team is responsible for planning and overseeing PTVA activities. The IT Operations team is responsible for implementing remediation measures. Business units are responsible for providing access and information necessary for testing.
Common pitfalls: Unclear roles and responsibilities; lack of accountability; insufficient communication between stakeholders.
4. Implementation Guidelines
1. Risk Assessment: Conduct a thorough risk assessment to identify critical systems and prioritize them for testing.
2. Selection of Testing Tools and Methodology: Choose appropriate tools and methodologies based on the type of systems being tested.
3. Develop Testing Schedule: Create a schedule based on the risk assessment and available resources.
4. Establish Reporting and Remediation Process: Define clear procedures for reporting vulnerabilities and tracking remediation efforts.
5. Training and Awareness: Train personnel involved in the PTVA process.
6. Documentation: Document all aspects of the PTVA program, including the risk assessment, testing schedule, reports, and remediation efforts.
5. Monitoring and Review
This policy will be reviewed and updated at least annually, or more frequently if significant changes occur to the organization's ICT infrastructure or risk profile. Effectiveness will be monitored by:
Tracking Remediation Timelines: Monitoring the time taken to remediate vulnerabilities.
Analyzing Penetration Testing Reports: Identifying trends and patterns in vulnerabilities.
Reviewing Key Risk Indicators (KRIs): Regularly monitoring KRIs related to cybersecurity incidents and vulnerabilities.
6. Related Documents
Incident Response Plan
Data Security Policy
ICT Risk Management Framework
7. Compliance Considerations
This policy directly addresses DORA's requirements for ICT risk management, incident reporting, and resilience testing. Specific DORA clauses addressed include (refer to specific DORA article numbers as applicable based on the final legislation in your jurisdiction): Those pertaining to ICT risk management, resilience testing, and incident reporting for financial institutions. This policy also considers all relevant legal and regulatory requirements, including data protection regulations (e.g., GDPR).
This template provides a comprehensive framework. Remember to adapt it to your specific organization's context and regulatory environment, including consulting legal counsel to ensure full compliance with DORA and other relevant legislation. Regular updates are crucial to maintain effectiveness in the ever-evolving landscape of cybersecurity threats.
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