Cybersecurity Policy Template
Third-Party Resilience and Security Requirements Policy (DORA Compliant)
1. Introduction
Purpose and scope: This policy outlines the minimum resilience and security requirements for all third-party vendors and suppliers providing goods or services to [Organization Name]. It aims to ensure that third parties maintain appropriate security controls and resilience measures to protect organizational data, systems, and operations, aligning with the principles of the Department of Operational Resilience and Response (DORA) framework. This policy applies to all third-party relationships, regardless of contract type, duration, or the nature of services provided. Exemptions may only be granted by the [Designated Approval Authority, e.g., CISO].
Relevance to DORA: This policy directly addresses DORA's objectives by mandating robust resilience and security measures from third parties. It mitigates the risk of disruptions caused by third-party failures, ensuring the organization's ability to continue operating effectively during and after significant incidents. This aligns with DORA's focus on identifying, managing, and mitigating operational risks, including those stemming from third-party dependencies.
2. Key Components
This policy comprises the following key components:
Third-Party Risk Assessment and Due Diligence: Evaluating the security posture and resilience capabilities of prospective and existing third parties.
Security Requirements: Defining the mandatory security controls and standards that third parties must meet.
Resilience Requirements: Specifying resilience capabilities required to ensure business continuity.
Contractual Obligations: Integrating security and resilience requirements into third-party contracts.
Monitoring and Reporting: Establishing mechanisms for ongoing monitoring and reporting of third-party performance.
Incident Response: Defining procedures for responding to security incidents involving third parties.
Termination and Remediation: Outlining processes for addressing non-compliance and terminating relationships with non-compliant third parties.
3. Detailed Content
a) Third-Party Risk Assessment and Due Diligence:
In-depth explanation: A comprehensive assessment, conducted before engaging a third party, to identify and evaluate potential risks related to their security and resilience. This includes reviewing their security policies, procedures, and controls; conducting background checks; and assessing their operational resilience capabilities.
Best practices: Utilize a standardized risk assessment questionnaire, conduct on-site audits (where appropriate), and leverage third-party risk assessment tools. Consider using a scoring system to prioritize risks.
Example: A questionnaire for a cloud service provider would include questions on data encryption, access controls, disaster recovery planning, incident response capabilities, compliance certifications (e.g., ISO 27001, SOC 2), and their vendor management program.
Common pitfalls: Relying solely on self-assessment questionnaires without independent verification; neglecting to assess the third party's supply chain; failing to consider geographic location and associated risks.
b) Security Requirements:
In-depth explanation: Defining the minimum security controls that third parties must implement, aligned with industry best practices and relevant regulations.
Best practices: Require compliance with industry standards (e.g., ISO 27001, NIST Cybersecurity Framework); mandate multi-factor authentication; enforce strong password policies; implement regular vulnerability scanning and penetration testing; and require data loss prevention (DLP) measures.
Example: All third-party vendors must implement multi-factor authentication for all users accessing organizational systems and data; undergo penetration testing annually; and provide evidence of compliance with ISO 27001.
Common pitfalls: Setting requirements that are too vague or difficult to measure; failing to regularly update security requirements to reflect emerging threats; neglecting to consider specific risks associated with different types of third parties.
c) Resilience Requirements:
In-depth explanation: Defining the minimum resilience capabilities that third parties must maintain to ensure business continuity in the event of disruptions.
Best practices: Require business continuity and disaster recovery plans; mandate regular testing of these plans; require redundancy and failover mechanisms; and specify recovery time objectives (RTOs) and recovery point objectives (RPOs).
Example: The third-party payment processor must maintain a geographically diverse infrastructure with automatic failover capabilities, achieving an RTO of less than 4 hours and an RPO of less than 15 minutes in the event of a major outage.
Common pitfalls: Failing to adequately assess the impact of third-party disruptions on the organization; setting unrealistic RTOs and RPOs; not testing resilience plans regularly.
d) Contractual Obligations:
In-depth explanation: Integrating security and resilience requirements into all third-party contracts, ensuring that the third party is legally obligated to meet these requirements.
Best practices: Include specific clauses addressing security requirements, incident reporting, data protection, and liability.
Example: The contract with a data analytics vendor must include a clause specifying their obligations related to data encryption, access controls, incident reporting, and data breach notification.
Common pitfalls: Failing to include specific, measurable requirements in contracts; relying on generic contract templates without tailoring them to specific risks; neglecting to address liability in case of a breach.
e) Monitoring and Reporting:
In-depth explanation: Establishing a process for ongoing monitoring of third-party compliance with security and resilience requirements, including regular reporting and audits.
Best practices: Utilize security information and event management (SIEM) systems; conduct regular security assessments and audits; establish key risk indicators (KRIs); and require regular compliance reports from third parties.
Example: Monthly reports from the cloud service provider detailing security incidents, vulnerability scans, and system uptime.
Common pitfalls: Lack of visibility into third-party activities; insufficient monitoring capabilities; failure to act on identified risks.
f) Incident Response:
In-depth explanation: Defining procedures for responding to security incidents involving third parties, including communication protocols, escalation paths, and remediation strategies.
Best practices: Establish clear communication channels; develop a joint incident response plan with key third parties; and regularly test the incident response plan.
Example: A detailed incident response plan outlining roles, responsibilities, and communication protocols in the event of a data breach involving a third-party payment processor.
Common pitfalls: Lack of coordination between the organization and its third parties; insufficient communication during an incident; inadequate remediation strategies.
g) Termination and Remediation:
In-depth explanation: Outlining the process for addressing non-compliance and terminating relationships with non-compliant third parties.
Best practices: Establish clear escalation paths; define remediation plans; and include termination clauses in contracts.
Example: If a third-party vendor fails to address a critical security vulnerability within a specified timeframe, the contract can be terminated.
Common pitfalls: Failing to address non-compliance promptly; lacking a clear process for termination; neglecting to document remediation efforts.
4. Implementation Guidelines
1. Establish a Third-Party Risk Management Program: Develop a comprehensive program with clearly defined roles, responsibilities, and procedures.
2. Develop a Third-Party Risk Assessment Questionnaire: Create a standardized questionnaire tailored to different types of third parties.
3. Integrate Security and Resilience Requirements into Contracts: Ensure all contracts explicitly include security and resilience clauses.
4. Implement Monitoring and Reporting Mechanisms: Establish a system for tracking third-party compliance and reporting on key metrics.
5. Develop Incident Response Procedures: Create a detailed plan for responding to security incidents involving third parties.
6. Train Personnel: Educate employees on the importance of third-party risk management and their roles in the program.
Roles and Responsibilities:
Third-Party Risk Management Team: Responsible for overseeing the program, conducting risk assessments, and monitoring compliance.
IT Security Team: Responsible for assessing security controls and implementing security measures.
Business Units: Responsible for identifying and managing their own third-party relationships.
Legal Department: Responsible for reviewing and approving contracts.
5. Monitoring and Review
This policy will be reviewed and updated at least annually or more frequently as needed, to reflect changes in the threat landscape, regulatory requirements, and organizational needs. The effectiveness of this policy will be monitored through regular reviews of third-party risk assessments, compliance reports, and incident reports. Key performance indicators (KPIs) will track the number of high-risk third parties, the number of security incidents involving third parties, and the time taken to remediate security vulnerabilities.
6. Related Documents
[Organization Name]'s Information Security Policy
[Organization Name]'s Business Continuity Plan
[Organization Name]'s Incident Response Plan
[Organization Name]'s Data Protection Policy
7. Compliance Considerations
This policy addresses relevant clauses and controls within the DORA framework, particularly those related to operational resilience, incident management, and third-party risk management. It also addresses legal and regulatory requirements relevant to data protection, such as the GDPR and CCPA (where applicable). Specific legal and regulatory requirements will need to be mapped to individual contracts and risk profiles. This policy needs to be updated to incorporate any future DORA guidance or regulatory changes.
This template provides a comprehensive framework. It is crucial to tailor it to your organization's specific circumstances, risk profile, and industry regulations. Regular updates and engagement with legal and security experts are essential for maintaining the policy's effectiveness.
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