Cybersecurity Policy Template

Vulnerability Management and Patch Management Policy

1. Introduction

Purpose and Scope: This policy outlines the procedures for identifying, assessing, remediating, and tracking ICT vulnerabilities and applying security patches across all organizational systems and applications. This encompasses all hardware, software, firmware, and network devices within the organization's control, including on-premises, cloud-based, and mobile assets. The goal is to minimize the organization's attack surface and reduce its exposure to cyber threats, aligning with the principles of the Digital Operational Resilience Act (DORA).

Relevance to DORA: This policy directly addresses DORA's requirements for ICT risk management, incident reporting, and resilience. By establishing a robust vulnerability and patch management program, the organization demonstrates its commitment to identifying and mitigating ICT risks, enabling timely detection and response to incidents, and ensuring the continued operation of critical services. Specifically, it contributes to compliance with articles relating to incident reporting, risk management, and ICT risk mitigation.

2. Key Components

The policy will include the following key components:

  • Vulnerability Identification and Assessment: Methods for discovering vulnerabilities.

  • Vulnerability Prioritization: Criteria for ranking vulnerabilities based on risk.

  • Patch Management Process: Procedures for deploying security patches.

  • Exception Management: Process for handling exceptions to patching.

  • Reporting and Monitoring: Mechanisms for tracking progress and identifying trends.

  • Incident Response Integration: How vulnerability management integrates with incident response.

  • Vendor Management: Managing vulnerabilities in third-party software and services.

  • Training and Awareness: Educating staff on the importance of vulnerability management.

3. Detailed Content

3.1 Vulnerability Identification and Assessment:

  • In-depth Explanation: This section details the methods used to identify vulnerabilities, including vulnerability scanners (e.g., Nessus, QualysGuard), penetration testing, security audits, and manual reviews of system configurations. It also outlines the process for assessing the severity and potential impact of identified vulnerabilities using a standardized scoring system (e.g., CVSS).

  • Best Practices: Utilize automated vulnerability scanners regularly, conduct penetration testing at least annually, and incorporate manual reviews for critical systems. Prioritize scans based on criticality of the asset.

  • Example: The organization will conduct automated vulnerability scans weekly on all production servers using QualysGuard. Critical vulnerabilities (CVSS score >= 7.0) will be addressed within 72 hours. Penetration testing will be performed annually by a certified third-party security assessor.

  • Common Pitfalls: Ignoring low-severity vulnerabilities, neglecting regular scanning, and failing to adequately assess the impact of vulnerabilities.

3.2 Vulnerability Prioritization:

  • In-depth Explanation: This outlines the criteria for prioritizing vulnerabilities based on their severity (CVSS score), exploitability, and potential impact on business operations. A risk matrix will be used to categorize vulnerabilities into high, medium, and low priority.

  • Best Practices: Use a standardized risk scoring system (CVSS) and factor in business impact and exploitability. Prioritize vulnerabilities affecting critical systems and those with readily available exploits.

  • Example: A vulnerability with a CVSS score of 9.0 affecting the organization's payment gateway will be classified as high priority and addressed immediately. A vulnerability with a CVSS score of 4.0 affecting a non-critical internal system will be classified as low priority and addressed within a reasonable timeframe.

  • Common Pitfalls: Failing to consider business impact, inconsistent prioritization, and neglecting vulnerabilities in less-critical systems.

3.3 Patch Management Process:

  • In-depth Explanation: This section details the process for obtaining, testing, deploying, and verifying the successful application of security patches. It includes procedures for pre-deployment testing in a non-production environment and a rollback plan in case of issues.

  • Best Practices: Implement a centralized patch management system, establish a formal testing process, and automate patch deployment where possible. Maintain detailed records of patch deployments.

  • Example: Before deploying a patch to production systems, it will be tested in a staging environment. A change management process will be followed, including approvals and documentation. Successful deployment will be verified through post-deployment scans.

  • Common Pitfalls: Deploying patches without testing, insufficient rollback planning, and inadequate communication with stakeholders.

3.4 Exception Management:

  • In-depth Explanation: This outlines the process for requesting and approving exceptions to the patch management policy. Exceptions should be justified and documented, with a clear remediation plan.

  • Best Practices: Establish a clear exception request process with defined approval authorities. Exceptions should be temporary and reviewed regularly.

  • Example: If a patch causes incompatibility with a critical application, a formal exception request must be submitted, approved by the CIO, and include a remediation plan with a timeline for resolving the incompatibility.

  • Common Pitfalls: Granting exceptions too readily, failing to document exceptions, and neglecting to review and close exceptions.

(Sections 3.5 - 3.8 follow a similar structure as above. Examples below illustrate further components):

3.5 Reporting and Monitoring:

  • Example: Weekly reports on vulnerability remediation progress, monthly summaries of identified vulnerabilities, and quarterly reviews of the effectiveness of the vulnerability management program.

3.6 Incident Response Integration:

  • Example: Identified vulnerabilities that are actively exploited in an incident will trigger immediate remediation efforts and an incident response plan activation.

3.7 Vendor Management:

  • Example: Contracts with vendors will include specific clauses on vulnerability disclosure and patch management responsibilities. Regular vulnerability assessments of third-party software and services.

3.8 Training and Awareness:

  • Example: Annual security awareness training for all employees covering safe patching practices and reporting vulnerabilities.

4. Implementation Guidelines

  • Step-by-step process:

1. Conduct a baseline assessment of existing systems and applications.

2. Implement vulnerability scanning tools.

3. Develop a vulnerability prioritization matrix.

4. Establish a patch management process.

5. Develop an exception management process.

6. Implement reporting and monitoring mechanisms.

7. Integrate vulnerability management with incident response.

8. Establish vendor management procedures.

9. Conduct regular security awareness training.

  • Roles and Responsibilities: Define roles and responsibilities for vulnerability scanning, patch management, exception management, and reporting. (e.g., Security Team, IT Operations, Application Owners)

5. Monitoring and Review

  • Monitoring Effectiveness: Regular review of vulnerability scan results, patch deployment rates, exception request numbers, and incident reports related to vulnerabilities. Key metrics include time to remediate high-risk vulnerabilities and the number of open vulnerabilities.

  • Frequency and Process: The policy will be reviewed and updated at least annually or more frequently if significant changes occur (e.g., new technologies, regulatory changes). Review will include assessment of effectiveness against established metrics and industry best practices.

6. Related Documents

  • Incident Response Plan

  • Data Security Policy

  • Risk Management Framework

  • IT Security Architecture

7. Compliance Considerations

This policy addresses several DORA requirements, including:

  • Article 4 (Risk Management): By establishing a robust vulnerability management program, the organization demonstrates its commitment to proactive risk management.

  • Article 6 (Incident Reporting): The policy's integration with the incident response plan ensures timely reporting of vulnerabilities exploited in security incidents.

  • Article 8 (ICT Security Measures): The policy directly contributes to the implementation of appropriate ICT security measures.

  • Article 10 (Outsourcing): The vendor management section addresses the specific requirements for managing risks related to outsourced ICT services.

This policy should also consider relevant national and EU regulations concerning data protection (GDPR) and cybersecurity, ensuring compliance with all applicable legal and regulatory requirements. Failure to comply with DORA can result in substantial penalties.

This comprehensive template provides a framework. Specific details should be tailored to the organization's size, complexity, and risk profile. Regular updates and improvements are crucial to maintain effectiveness.

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