+DORA Ch. II Sec. II Art. 13 3.

DORA Ch. II Sec. II Art. 13 3.

3.   Lessons derived from the digital operational resilience testing carried out in accordance with Articles 26 and 27 and from real life ICT-related incidents, in particular cyber-attacks, along with challenges faced upon the activation of ICT business continuity plans and ICT response and recovery plans, together with relevant information exchanged with counterparts and assessed during supervisory reviews, shall be duly incorporated on a continuous basis into the ICT risk assessment process. Those findings shall form the basis for appropriate reviews of relevant components of the ICT risk management framework referred to in Article 6(1).

1. Overview

1.1 References

1.2 Identified Requirements

1.3 Related Standards

2. Identified Requirements

Requirements

3. Related Standards

Standards
NOREA Critical and Important Functions
Identify, classify and adequately document all critical and important functions. This process involves determining which functions are essential for the entity's operational stability and continuity. Review as needed, and at least yearly, the adequacy of this classification.
NOREA Clear Segregation of Duties (SoD)
Establish Segregation of Duties (SoD) with regard to risk management functions, following the three lines of defence model or internal risk management and control model.
NOREA ICT Risk management framework

A sound, comprehensive and well-documented ICT risk management framework is in place. Which as goal to address all ICT risks properly and ensure a high level of digital resilience. The reponsibility for risk management is properly assigned to a control function. 

The ICT risk management framework shall be documented and reviewed at least annually, or periodically for microenterprises, with immediate reviews triggered by major ICT-related incidents or supervisory feedback. Continuous improvement will be ensured by incorporating lessons learned from implementation, monitoring, and audits. The report of the review will be prepared according to the requirements as stated in chapter 5 (Article 27) of the RTS RM and will be made available for submission to the competent authority upon request. 

Assess new standards and relevant technology developments in the field of information security, cybersecurity and resilience on a continuous basis and make proposals on how they can strengthen the information security and cybersecurity control measures of the institution.
NOREA Annual Framework Review and Audit Process

The effectiveness of the risk management framework is monitored based on the risk exposure over time to critical or important business functions. Implement a reviewing and auditing process, with a minimum yearly review of the framework, triggered by major ICT incidents, regulator instructions, or major audit findings. 

The tasks of verifying compliance with ICT risk management requirements may be outsourced to intra-group or external undertakings. In case of such outsourcing, the financial entity remains fully responsible for the verification of compliance with the ICT risk management requirements.
NOREA Third-Party (Multi-vendor) Risk Management Program

Maintain a comprehensive third-party risk management program which includes:

  • A register of information related to the use of thirdparty service providers, especially those supporting critical or important functions (see also control 17.3).
  • Put in place a policy on the management of ICT third-parties, including the criteria for determining the criticality of service providers and the internal responsibilities for managing third-parties.
  • Ensuring that senior management reviews the policy and designate a member to monitor relations with the third-parties and the contractual arrangements.
  • A (holistic) multi-vendor strategy, if deemed relevant,  showing key dependencies on ICT third-party service providers and explaining the rationale behind the procurement mix of ICT third-party service providers.  
NOREA Protection Measures

Implement policies and procedures to protect all information, ICT assets, and relevant physical ICT components and infrastructures. At least the following policies shall be established and maintained.

  • Security policy
  • Human resources policy
  • Encryption and cryptographic control policy
  • Identity and access management (IAM) policy
  • Change management policy
  • Network security policy
  • ICT operating policies and procedures
  • (Crisis) Communication policy
  • Vulnerability and patch management policy
  • Back up policy
  • Project management policy
  • Physical and environmental security policy
  • Business continuity policy with response and recovery plans (including testing plans), see control1.4 *
  • ICT third-party service providers management policy, see control 1.1. *
  • Operations of ICT assets (ensuring network security, protect against intrusions and data misuse and defining how the entity operates, monitors, controls, and restores ICT assets, including the documentation of ICT operations).

* must be approved by the Management body
SCF Contingency Plan Root Cause Analysis (RCA) & Lessons Learned

Description

Mechanisms exist to conduct a Root Cause Analysis (RCA) and "lessons learned" activity every time the contingency plan is activated.

Possible Solutions & Considerations

Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2

∙ Root Cause Analysis (RCA) (After Action Review (AAR), lessons learned, etc.)

Small Business (10-49 staff) / BLS Firm Size Classes 3-4

∙ Root Cause Analysis (RCA) (After Action Review (AAR), lessons learned, etc.)

Medium Business (50-249 staff) / BLS Firm Size Classes 5-6

∙ Root Cause Analysis (RCA) (After Action Review (AAR), lessons learned, etc.)

Large Business (250-999 staff) / BLS Firm Size Classes 7-8

∙ Root Cause Analysis (RCA) (After Action Review (AAR), lessons learned, etc.)

Enterprise (> 1,000 staff) / BLS Firm Size Class 9

∙ Root Cause Analysis (RCA) (After Action Review (AAR), lessons learned, etc.)

SCR-CMM

Level 0 Not Performed

Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.

Level 1 Performed Informally

Business Continuity & Disaster Recovery (BCD) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with BCD domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Contingency management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Limited technologies exist to support near real-time network infrastructure failover (e.g., redundant ISPs, redundant power, etc.).

Level 2 Planned Tracked

Business Continuity & Disaster Recovery (BCD) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with BCD domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with BCD domain capabilities are documented and maintained by process owners.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with BCD domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Business Continuity / Disaster Recovery (BC/DR)-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ BC/DR may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.

Level 3 Well Defined

Business Continuity & Disaster Recovery (BCD) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with BCD domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Standardized Operating Procedures (SOP) associated with BCD domain capabilities are well-documented and kept current by process owners.
▪ A Business Continuity & Disaster Recovery (BC/DR) team, or similar function, is appropriately staffed and supported to implement and maintain BCD domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of BC/DR operations (e.g., BC/DR planning software, Disaster Recovery as a Service (DRaaS), Orchestration and Automation Tools, etc.).
▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with BCD domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls).
▪ An implemented and operational capability exists to conduct a Root Cause Analysis (RCA) and "lessons learned" activity every time the contingency plan is activated.

Level 4 Quantitatively Controlled

Utilize SCR-CMM Level 3 criteria definitions:
▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control.
▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.

Level 5 Continuously Improving

Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions:
▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control.
▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies.
▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.
SCF Root Cause Analysis (RCA) & Lessons Learned

Description

Mechanisms exist to incorporate lessons learned from analyzing and resolving cybersecurity and data protection incidents to reduce the likelihood or impact of future incidents.

Possible Solutions & Considerations

Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2

∙ Root Cause Analysis (RCA)

Small Business (10-49 staff) / BLS Firm Size Classes 3-4

∙ Root Cause Analysis (RCA)

Medium Business (50-249 staff) / BLS Firm Size Classes 5-6

∙ Root Cause Analysis (RCA)

Large Business (250-999 staff) / BLS Firm Size Classes 7-8

∙ Root Cause Analysis (RCA)

Enterprise (> 1,000 staff) / BLS Firm Size Class 9

∙ Root Cause Analysis (RCA)

SCR-CMM

Level 0 Not Performed

Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.

Level 1 Performed Informally

SCR-CMM Level 1 criteria definitions are not available for this control:
▪ A reasonable person would conclude this control requires a structured process.
▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality.

Level 2 Planned Tracked

Incident Response (IRO) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with IRO domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners.
▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with IRO domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Incident response-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Incident response management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ IT and/or cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.
▪ Incident responders provide After Action Review (AAR) feedback on what worked, what did not work and ways to improve future responses to similar incidents.
▪ A formal Root Cause Analysis (RCA) is performed that documents the findings in a report for both technical and business leadership management.

Level 3 Well Defined

Incident Response (IRO) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Policies and standards associated with IRO domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function.
▪ Cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery.
▪ An incident response team, or similar function, is appropriately staffed and supported to implement and maintain IRO domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of incident response operations (e.g., incident management software, etc.).
▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with IRO domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls).
▪ An implemented and operational capability exists to incorporate lessons learned from analyzing and resolving cybersecurity and data protection incidents to reduce the likelihood or impact of future incidents.

Level 4 Quantitatively Controlled

Incident Response (IRO) capabilities, in addition to being standardized across the entity and centrally managed to ensure consistency across Technology Assets, Applications, Services and/or Data (TAASD), efforts are metrics driven to provide sufficient insight for decision makers to predict optimal performance, ensure continued operations and/or identify areas for improvement. Capability criteria associated with this control reasonably expect the following criteria to exist:
▪ Applicable SCR-CMM Level 3 (Well Defined) capabilities are implemented and operational.
▪ Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
▪ Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
▪ Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
▪ Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
▪ Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
▪ Business and technical stakeholders are involved in reviewing and approving proposed changes to evolve capabilities.

Level 5 Continuously Improving

Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions:
▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control.
▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies.
▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.
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