Cybersecurity Policy Template
Reporting and Documentation Policy
1. Introduction
Purpose and Scope: This policy outlines the requirements for reporting and documentation within [Organization Name] to ensure compliance with the Digital Operational Resilience Act (DORA), maintain operational resilience, and facilitate effective incident management and regulatory reporting. This policy applies to all employees, contractors, and third-party providers involved in the organization's digital operational services.
Relevance to DORA: DORA mandates robust incident reporting, documentation, and oversight of digital operational resilience. This policy ensures compliance with DORA’s requirements for reporting significant incidents, maintaining comprehensive records, and facilitating effective communication with supervisors, senior management, and relevant regulatory authorities. Specific DORA articles addressed are detailed in Section 7.
2. Key Components
This Reporting and Documentation Policy encompasses the following key components:
Incident Reporting: Procedures for reporting incidents impacting digital operational services.
Incident Documentation: Detailed records of incidents, including root cause analysis and remediation actions.
Internal Reporting: Communication pathways for reporting incidents to supervisors and senior management.
External Reporting: Procedures for reporting incidents to regulatory authorities as required by DORA.
Records Management: Procedures for storing, retrieving, and disposing of documentation related to incidents and operational resilience.
Third-Party Management: Reporting and documentation requirements for third-party providers of digital operational services.
3. Detailed Content
3.1 Incident Reporting:
In-depth explanation: This section defines reportable incidents (e.g., significant incidents impacting availability, integrity, confidentiality, or authenticity of digital operational services), outlines the reporting process (e.g., using a dedicated incident management system), and specifies escalation paths. It should include thresholds for reporting based on impact and severity.
Best practices: Use a clear and concise incident reporting form; establish clear timelines for reporting; ensure reports include sufficient detail to facilitate effective investigation and remediation; utilize automated reporting tools where possible.
Example: A significant service outage affecting online banking for more than 4 hours must be reported within 1 hour to the Incident Management Team and within 4 hours to senior management and the relevant regulatory authority (e.g., European Banking Authority - EBA). The report must include impact assessment, initial root cause analysis, and planned remediation steps.
Common pitfalls: Delays in reporting, insufficient information in reports, inconsistent reporting procedures across teams.
3.2 Incident Documentation:
In-depth explanation: This section defines the required documentation for each incident, including detailed descriptions, timelines, involved parties, root cause analysis, remedial actions, and lessons learned. It should specify the format, storage location, and retention period for incident records.
Best practices: Employ a structured approach to documentation; use a consistent template; ensure documentation is accurate, complete, and verifiable; maintain a centralized repository for incident records.
Example: For a data breach incident, documentation should include details of the affected data, the source of the breach, the timeline of events, the number of individuals affected, mitigation actions taken, and any subsequent regulatory reporting. Documentation should follow a predefined template and be stored in a secure, auditable system.
Common pitfalls: Incomplete or inaccurate documentation; lack of consistency in documentation style; failure to conduct proper root cause analysis; inadequate storage and retrieval of documents.
3.3 Internal Reporting:
In-depth explanation: This section details the internal communication channels for incident reporting, including escalation procedures, notification lists, and communication protocols. It should specify who needs to be notified, when, and how.
Best practices: Establish clear escalation paths; use appropriate communication channels (e.g., email, phone, dedicated communication platform); document all communication related to incidents; ensure timely communication to relevant stakeholders.
Example: A level 1 incident (minor) is reported to the IT Help Desk. A level 3 incident (major, impacting multiple services) is escalated to the Incident Management Team, then to the CIO, and finally to the CEO, depending on the severity and impact. All communication should be documented in the incident management system.
Common pitfalls: Failure to escalate incidents promptly; lack of clear communication channels; inconsistent communication procedures; inadequate documentation of communication.
3.4 External Reporting:
In-depth explanation: This section outlines the procedures for reporting incidents to regulatory authorities as required by DORA. It specifies which incidents require external reporting, the required content of the report, and the timelines for submission.
Best practices: Establish a clear process for identifying incidents requiring regulatory reporting; use a standardized reporting template; ensure timely submission of reports; maintain records of all communication with regulatory authorities.
Example: A significant incident causing material disruption to critical financial services, such as a prolonged outage of payment processing systems, must be reported to the EBA within 24 hours. The report should follow the EBA's prescribed format and include details such as impact assessment, remediation steps and investigation timeline.
Common pitfalls: Failure to identify and report significant incidents; delays in reporting; incomplete or inaccurate reporting; lack of communication with regulatory authorities.
3.5 Records Management:
In-depth explanation: This section defines the procedures for managing incident records, including storage, retention, and disposal. It should specify the retention periods for different types of documentation and the methods for ensuring data security and integrity.
Best practices: Utilize a secure and auditable records management system; implement robust access controls; ensure regular backups; comply with data retention and disposal regulations.
Example: Incident reports are retained for 7 years, while supporting documentation may be retained for shorter or longer periods, depending on its significance. A secure, cloud-based document management system with access control and versioning features will be used.
Common pitfalls: Inadequate security measures; inconsistent retention periods; difficulty in retrieving records; failure to comply with data protection regulations.
3.6 Third-Party Management:
In-depth explanation: This outlines the reporting and documentation requirements for third-party providers. It includes contractual obligations related to incident reporting, documentation, and data sharing.
Best Practices: Include clear incident reporting clauses in contracts with third-party providers; establish regular communication channels; perform due diligence on third-party providers' resilience capabilities.
Example: Contracts with cloud providers will require them to report significant service disruptions within a specified timeframe, provide detailed incident reports, and maintain comprehensive documentation in line with DORA and this policy.
Common pitfalls: Lack of clarity in contractual agreements; insufficient oversight of third-party providers; failure to address incident reporting responsibilities in contracts.
4. Implementation Guidelines
1. Training: Conduct training for all relevant personnel on the updated policy and procedures.
2. System Implementation: Implement or update incident management systems to support the policy requirements.
3. Documentation Updates: Update all relevant internal documentation to reflect the changes.
4. Communication: Communicate the updated policy to all employees, contractors, and third-party providers.
5. Testing: Conduct regular testing of the incident reporting and documentation procedures.
Roles and Responsibilities:
Incident Manager: Responsible for coordinating incident response, documentation, and reporting.
IT Security Team: Responsible for security incident response and reporting.
Legal Department: Responsible for advising on legal and regulatory compliance.
Senior Management: Responsible for oversight of the policy's implementation and effectiveness.
5. Monitoring and Review
The effectiveness of this policy will be monitored through regular reviews of incident reports, audits of documentation, and feedback from stakeholders. The policy will be reviewed and updated at least annually, or more frequently as needed, to reflect changes in regulatory requirements, technology, or business needs. Key performance indicators (KPIs) will track incident reporting times, documentation completeness, and regulatory compliance.
6. Related Documents
Incident Management Plan
Business Continuity Plan
Data Security Policy
Risk Management Framework
7. Compliance Considerations
This policy directly addresses DORA's requirements concerning:
Article 3 (Significant Incidents): Defines reportable incidents and their escalation paths, ensuring compliance with reporting obligations.
Article 4 (Incident Reporting): Establishes procedures for internal and external reporting of significant incidents.
Article 6 (Management of ICT-related risks): Supports the management of ICT risks through proactive incident management and documentation.
Article 17 (Supervisory Powers): Facilitates cooperation with regulatory authorities by providing clear procedures for reporting and providing documentation.
This policy also addresses relevant legal and regulatory requirements relating to data protection (GDPR), data security, and financial services regulations applicable to [Organization Name]. Compliance with these regulations is a necessary element of DORA compliance.
This template provides a robust foundation for a DORA-compliant Reporting and Documentation Policy. It should be adapted to reflect the specific circumstances and requirements of [Organization Name]. Regular review and updates are critical to maintain compliance and operational resilience.
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