Cybersecurity Policy Template
Regulatory Reporting Policy: ICT Incidents, Outages, and Security Breaches
1. Introduction
Purpose and Scope: This policy outlines the procedures for reporting Information and Communications Technology (ICT) incidents, outages, and security breaches to relevant regulatory authorities in compliance with the Digital Operational Resilience Act (DORA). It applies to all ICT systems and services critical to the organisation's operations, impacting the provision of financial services. This includes, but is not limited to, trading platforms, payment systems, customer relationship management (CRM) systems, and data centres.
Relevance to DORA: DORA mandates robust incident reporting frameworks for financial institutions. This policy ensures compliance with Articles 28 and 29 of DORA, specifically addressing timely and accurate reporting of ICT incidents, outages, and security breaches that materially impact the provision of financial services. It supports the establishment of a strong ICT risk management framework, aligning with DORA's objectives to enhance the resilience of the financial sector.
2. Key Components
This Regulatory Reporting Policy includes the following key components:
Incident Definition and Classification: Clear definitions of what constitutes an ICT incident, outage, and security breach, with a tiered classification system based on severity and impact.
Reporting Thresholds: Specific criteria for determining which incidents require mandatory reporting to regulatory authorities.
Reporting Procedures: Step-by-step instructions on how to report incidents, including contact information for relevant authorities, required information, and escalation paths.
Communication Plan: Procedures for internal and external communication during and after an incident.
Documentation and Record Keeping: Requirements for maintaining detailed records of all reported incidents, including investigation findings, remedial actions, and lessons learned.
Testing and Training: Regular testing of the reporting procedures and training for relevant personnel.
Review and Improvement: Mechanisms for regularly reviewing and improving the effectiveness of the policy and procedures.
3. Detailed Content
3.1 Incident Definition and Classification:
In-depth explanation: This section defines various incident types (e.g., denial-of-service attacks, data breaches, hardware failures, software bugs) and their corresponding severity levels (e.g., critical, major, minor) based on factors such as duration of impact, business disruption, financial loss, and reputational damage.
Best practices: Use a standardized incident classification framework, aligning with industry best practices and regulatory guidance. Consider using a quantitative scoring system to objectively assess severity.
Example:
* Incident Type: Data Breach – unauthorized access to customer Personally Identifiable Information (PII).
* Severity: Critical – widespread impact on 10,000+ customers, significant financial and reputational damage.
* Classification: Requires immediate notification to relevant regulatory authorities (e.g., within 24 hours).
Common pitfalls: Vague definitions, inconsistent classification, lack of clear severity criteria.
3.2 Reporting Thresholds:
In-depth explanation: This section outlines the specific criteria that trigger mandatory reporting to regulatory authorities. It should consider factors like impact on service availability, financial losses, customer impact, and regulatory expectations.
Best practices: Define clear and measurable thresholds. Consult with legal counsel to ensure compliance with all applicable regulations.
Example: Mandatory reporting is required for any incident resulting in:
* Complete outage of a critical system for more than 4 hours.
* Unauthorized access to sensitive customer data impacting more than 1000 customers.
* Financial losses exceeding €1 million.
Common pitfalls: Setting thresholds that are too high or too low, resulting in either under-reporting or unnecessary reporting.
3.3 Reporting Procedures:
In-depth explanation: This section provides a detailed step-by-step process for reporting incidents, including the designated point of contact, the required information (e.g., incident type, date, time, impact, root cause, remedial actions), and the method of reporting (e.g., secure email, dedicated portal).
Best practices: Use a standardized reporting form and ensure that the reporting process is well-documented and easily accessible.
Example: Upon detection of a critical incident, the incident response team leader must:
1. Immediately initiate the incident response plan.
2. Collect all relevant information.
3. Complete the incident report form within 2 hours.
4. Submit the report to the designated regulatory authority via secure email within 24 hours.
Common pitfalls: Lack of clear procedures, insufficient information provided in the report, delayed reporting.
3.4 Communication Plan:
In-depth explanation: This outlines procedures for internal communication (keeping stakeholders informed) and external communication (e.g., informing customers and the public as appropriate).
Best practices: Prepare pre-written templates for communication messages, ensuring clarity and consistency.
Example: A press release template for public communication in case of a significant outage.
Common pitfalls: Inconsistent messaging, delayed communication, lack of transparency.
3.5 Documentation and Record Keeping:
In-depth explanation: This section outlines the requirements for maintaining detailed records of all reported incidents, including all related documentation, investigation findings, remedial actions taken, and lessons learned.
Best practices: Establish a secure and auditable system for storing incident reports and related documentation, compliant with data retention policies.
Example: Each incident report must include: date/time of occurrence, impact assessment, root cause analysis, remedial actions, and follow-up actions.
Common pitfalls: Incomplete documentation, inadequate record-keeping systems, lack of data security.
3.6 Testing and Training:
In-depth explanation: This section describes the regular testing of the reporting procedures through simulations and drills and training for personnel involved in incident response and reporting.
Best practices: Conduct regular table-top exercises and full-scale simulations to test the effectiveness of the reporting procedures.
Example: Annual simulation exercises focusing on various incident scenarios.
Common pitfalls: Insufficient training, lack of testing, outdated procedures.
3.7 Review and Improvement:
In-depth explanation: This describes the process for reviewing the effectiveness of the policy and procedures, identifying areas for improvement, and making necessary updates.
Best practices: Regular reviews should be conducted at least annually, or more frequently following significant incidents.
Example: Annual review by the ICT risk management committee, including assessment of effectiveness of the reporting process.
Common pitfalls: Infrequent reviews, lack of proactive improvements, failure to learn from past incidents.
4. Implementation Guidelines:
1. Establish a dedicated Incident Response Team: Assign roles and responsibilities (e.g., incident manager, communication lead, technical experts).
2. Develop and implement the reporting procedures: Create standardized forms, communication templates, and documentation requirements.
3. Train personnel: Conduct comprehensive training for all relevant staff on incident reporting procedures.
4. Establish monitoring and review mechanisms: Set up a system for tracking incidents, analysing effectiveness, and initiating improvement measures.
5. Communicate the policy: Ensure all staff are aware of the policy and their responsibilities.
5. Monitoring and Review:
The policy will be reviewed annually by the ICT Risk Management Committee. The effectiveness will be monitored through regular reporting of key metrics (e.g., number of incidents reported, time to report, accuracy of reports). Post-incident reviews will be conducted for all major incidents to identify areas for improvement.
6. Related Documents:
ICT Risk Management Policy
Business Continuity Plan
Incident Response Plan
Data Security Policy
7. Compliance Considerations:
This policy addresses the requirements of DORA, specifically Articles 28 and 29 concerning incident reporting and ICT risk management. It also considers other relevant legal and regulatory requirements, including data protection regulations (e.g., GDPR). Legal counsel should be consulted to ensure full compliance with all applicable laws and regulations.
This detailed template provides a robust foundation for a DORA-compliant Regulatory Reporting Policy. Remember to tailor it to your specific organization's context and regulatory environment. Regular review and updates are crucial to maintain compliance and effectiveness.
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