Cybersecurity Policy Template
Phishing and Social Engineering Awareness Policy
1. Introduction
Purpose and Scope: This policy outlines the organization's commitment to protecting its data and systems from phishing, social engineering attacks, and other cyber threats. It aims to educate all employees on identifying, avoiding, and reporting such threats, aligning with the Digital Operational Resilience Act (DORA) requirements for robust cybersecurity measures. This policy applies to all employees, contractors, and third-party users with access to the organization's systems and data.
Relevance to DORA: DORA mandates that financial institutions implement effective measures to identify, manage, and mitigate operational risks, including cybersecurity threats. This policy directly supports DORA’s objectives by:
Strengthening ICT resilience: By educating employees on cybersecurity threats, this policy reduces the likelihood of successful phishing and social engineering attacks, thereby strengthening ICT resilience.
Incident reporting and management: The policy establishes clear procedures for reporting suspected incidents, enabling timely response and mitigation efforts as required by DORA.
Business continuity planning: Reducing the risk of successful cyberattacks contributes to the overall business continuity planning objectives mandated by DORA.
Operational risk management: This policy forms a crucial part of the overall operational risk management framework required by DORA, by addressing a key vector of operational risk.
2. Key Components
The policy comprises the following key components:
Definition of Phishing and Social Engineering: Clear definitions and examples.
Identifying Phishing and Social Engineering Attempts: Techniques and red flags.
Reporting Procedures: Step-by-step instructions on reporting suspected incidents.
Safe Email and Internet Practices: Best practices for secure online behavior.
Password Security: Guidelines for creating and managing strong passwords.
Consequences of Non-Compliance: Clarification of disciplinary actions.
Training and Awareness Program: Details of ongoing training and awareness initiatives.
3. Detailed Content
a) Definition of Phishing and Social Engineering:
In-depth explanation: Phishing involves deceptive attempts to acquire sensitive information such as usernames, passwords, and credit card details by disguising as a trustworthy entity in electronic communication. Social engineering manipulates individuals into divulging confidential information or performing actions that compromise security.
Best practices: Use clear, concise language to define both terms, providing visual aids where appropriate (e.g., examples of phishing emails).
Example: A phishing email might mimic a legitimate bank notification, urging the recipient to update their account details via a malicious link. A social engineering attack could involve an imposter calling and pretending to be IT support, requesting password information to "fix a problem".
Common pitfalls: Failing to differentiate between various types of phishing (e.g., spear phishing, whaling) or neglecting to explain the psychological manipulation tactics used in social engineering.
b) Identifying Phishing and Social Engineering Attempts:
In-depth explanation: This section details common red flags, such as suspicious email addresses, grammatical errors, urgent requests, unusual links, and requests for personal information.
Best practices: Provide a checklist of red flags with clear explanations and visual examples.
Example: An email with misspellings in the sender's name or organization name, a link that doesn't match the expected domain (e.g., a link to `googIe.com` instead of `google.com`), or a request to immediately transfer funds or provide login credentials.
Common pitfalls: Oversimplifying the techniques used by attackers. Including outdated examples that no longer reflect current phishing tactics.
c) Reporting Procedures:
In-depth explanation: Clearly outline the steps employees should take to report suspected phishing or social engineering attempts. Include contact details for the relevant security team or designated personnel.
Best practices: Provide a dedicated reporting channel (e.g., email address, hotline number, online form) and guarantee confidentiality for reporters.
Example: "If you suspect a phishing email, DO NOT click any links or open any attachments. Forward the email to [[email protected]] and then delete it from your inbox."
Common pitfalls: Lack of clarity in reporting procedures, making it difficult for employees to know how to report. Not providing appropriate channels for reporting.
d) Safe Email and Internet Practices:
In-depth explanation: Cover topics such as verifying sender identities, avoiding suspicious links and attachments, using strong passwords, regularly updating software, and being wary of unsolicited communication.
Best practices: Use simple language and visual aids to explain complex concepts. Provide clear examples of safe browsing habits.
Example: Always hover over links before clicking to see the actual URL. Be cautious of emails requesting urgent action or threatening consequences.
Common pitfalls: Providing overwhelming information; not tailoring the advice to the specific context of employees' daily tasks.
e) Password Security:
In-depth explanation: Emphasize the importance of using strong, unique passwords for all accounts, and encourage the use of password managers.
Best practices: Provide guidelines on creating strong passwords (length, complexity, character types), recommend password managers, and highlight the dangers of password reuse.
Example: "Use a password manager to generate and store unique, complex passwords for each of your accounts. Avoid using easily guessable information like birthdays or pet names."
Common pitfalls: Not providing clear guidance on password complexity or neglecting the importance of password managers.
f) Consequences of Non-Compliance:
In-depth explanation: Clearly state the disciplinary actions that will be taken against employees who violate this policy.
Best practices: Align disciplinary actions with the organization's existing code of conduct and HR policies.
Example: Failure to report a suspected phishing attempt may result in disciplinary action, up to and including termination of employment.
Common pitfalls: Failing to define clear consequences or being inconsistent in enforcement.
g) Training and Awareness Program:
In-depth explanation: Detail the organization's ongoing training program to educate employees about phishing and social engineering threats.
Best practices: Regularly conduct phishing simulations and awareness campaigns to reinforce learning.
Example: Annual security awareness training, including interactive modules and phishing simulations, quarterly email newsletters with security tips.
Common pitfalls: Infrequent or ineffective training, leading to low employee awareness.
4. Implementation Guidelines
Step-by-step process:
1. Policy Review and Approval: Draft the policy, obtain legal review, and secure senior management approval.
2. Communication and Dissemination: Distribute the policy to all employees via email, intranet, and/or during meetings.
3. Training and Awareness: Implement the outlined training and awareness program.
4. Reporting Mechanism Setup: Establish and communicate the designated reporting channels.
5. Monitoring and Evaluation: Develop metrics to track policy effectiveness and address any identified gaps.
Roles and Responsibilities:
IT Security Team: Responsible for developing, implementing, and maintaining the policy, conducting security awareness training, and investigating security incidents.
HR Department: Responsible for incorporating the policy into employee onboarding and disciplinary procedures.
All Employees: Responsible for adhering to the policy and reporting suspected security incidents.
5. Monitoring and Review
Monitoring Effectiveness: Track the number of phishing and social engineering attempts reported, the success rate of phishing simulations, employee participation in training, and the overall reduction in security incidents.
Frequency and Process: Review and update the policy annually or whenever significant changes occur in the threat landscape or regulatory requirements. The review should include a gap analysis against current DORA requirements.
6. Related Documents
Incident Response Plan
Data Security Policy
Acceptable Use Policy
Business Continuity Plan
7. Compliance Considerations
This policy directly addresses DORA’s requirements for:
ICT risk management: By proactively educating employees and providing clear reporting procedures, the policy reduces the likelihood and impact of ICT incidents.
Incident reporting and resolution: The policy establishes clear procedures for reporting and managing security incidents, enabling prompt remediation and mitigating operational disruption.
Business continuity management: Reducing the risk of successful cyberattacks contributes to maintaining business continuity.
This policy must comply with all relevant data protection laws and regulations (e.g., GDPR, CCPA) within the organization’s jurisdiction. Specific DORA clauses related to operational resilience, incident reporting, and ICT risk management are directly addressed. Legal counsel should be consulted to ensure full compliance.
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