+DORA Ch. II Sec. II Art. 8 1.

DORA Ch. II Sec. II Art. 8 1.

1.   As part of the ICT risk management framework referred to in Article 6(1), financial entities shall identify, classify and adequately document all ICT supported business functions, roles and responsibilities, the information assets and ICT assets supporting those functions, and their roles and dependencies in relation to ICT risk. Financial entities shall review as needed, and at least yearly, the adequacy of this classification and of any relevant documentation.

1. Übersicht

1.1 Referenzen

1.2 Identifizierte Anforderungen

1.3 Related Standards

2. Identifizierte Anforderungen

Anforderungen

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 Resilient Systems

Use and maintain ICT systems, protocols, and tools that are up to date and:

  • Tailored to the magnitude of ICT operations
  • Reliable
  • Equipped with sufficient capacity to accurately process data and to deal with peak orders, message or transaction volumes as needed
  • Technologically resilient to deal with additional processing needs under stressed market conditions or other adverse market conditions
NOREA Inventory Management

Keep an inventory of (ICT) assets, monitor their life-cycle and update it periodically and upon every major change in the network, the IT infrastructure, and processes and procedures supporting business functions. Keep records of the following for each ICT asset: unique identifier, location (physical or logical), asset classification, identity of asset owner, information for specific risk assessment on legacy systems, business functions or services supported, business continuity requirements (e.g., RTO, RPO), exposure to external networks, including the internet, links and interdependencies among assets and business functions using each asset, and the end dates of the ICT third-party service provider’s regular, extended and custom support services after which it is no longer supported by its supplier or by an ICT third-party service provider.

Ideally, inventory management is perfomed in an automated and continuous fashion.
NOREA Asset Classification and Documentation

Identify, classify and document all ICT-supported business functions, including the assets supporting them, and detail the roles and dependencies of these assets in relation to ICT risk. Additionally, identify and document all ICT-supported business functions dependent on ICT third-party service providers, and identify the services provided by third-party providers that support critical or important business functions. Make a mapping of critical (ICT) assets based on a criticality assessment, which must include network resources, hardware equipment, and resources on remote sites. This mapping should also incorporate the configuration of assets and their links and interdependencies with other assets. The criticality assessment should follow clear criteria to evaluate the ICT risk related to business functions, taking into account the potential impact of confidentiality, integrity, and availability losses. Review the adequacy of this classification and documentation at least on a yearly basis, ensuring it meets the requirements for maintaining accurate and up-to-date asset records.

 
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 Business Process Definition

Description

Mechanisms exist to define business processes with consideration for security, compliance and resilience that determines:
(1) The resulting risk to organizational operations, assets, individuals and other organizations; and
(2) Information protection needs arising from the defined business processes and revises the processes as necessary, until an achievable set of protection needs is obtained.

Possible Solutions & Considerations

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

∙ Defined business processes
∙ Product / project management
∙ Defined technical requirements
∙ Defined business requirements

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

∙ Defined business processes
∙ Product / project management
∙ Defined technical requirements
∙ Defined business requirements

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

∙ Defined business processes
∙ Product / project management
∙ Defined technical requirements
∙ Defined business requirements
∙ System Development Lifecycle (SDLC) governance / oversight

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

∙ Defined business processes
∙ Product / project management
∙ Defined technical requirements
∙ Defined business requirements
∙ System Development Lifecycle (SDLC) governance / oversight

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

∙ Defined business processes
∙ Product / project management
∙ Defined technical requirements
∙ Defined business requirements
∙ System Development Lifecycle (SDLC) governance / oversight

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

Project & Resource Management (PRM) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with PRM domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Project management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ IT and/or cybersecurity personnel work with data/process owners to help ensure secure practices are implemented throughout the System Development Lifecycle (SDLC) for all high-value projects.

Level 2 Planned Tracked

Project & Resource Management (PRM) 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 PRM domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with PRM 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 PRM domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Project & Resource Management -related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Project & Resource Management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel.
▪ The Chief Information Officer (CIO), or similar function, analyzes the organization's business strategy and prioritizes the objectives and resourcing of the security function, based on broader business requirements.
▪ A Project Management Office (PMO), or project management function, enables the implementation of cybersecurity and data protection-related resource planning controls across the System Development Lifecycle (SDLC) for all high-value projects.
▪ The PM function enables project involvement for Information Assurance Program (IAP) as part of the organization's established project management processes to ensure both cybersecurity and data protection principles are identified and implemented.

Level 3 Well Defined

Project & Resource Management (PRM) 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 PRM 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 PRM domain capabilities are well-documented and kept current by process owners.
▪ A Project Management Office (PMO), or similar function, is appropriately staffed and supported to implement and maintain PRM domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of project and resource management operations (e.g., project management solution, 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 PRM 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).
▪ The Chief Information Officer (CIO), or similar function, analyzes the organization's business strategy and prioritizes the objectives and resourcing of the security function, based on broader business requirements.
▪ An implemented and operational capability exists to define business processes with consideration for security, compliance and resilience that determines:
(1) The resulting risk to organizational operations, assets, individuals and other organizations; and
(2) Information protection needs arising from the defined business processes and revises the processes as necessary, until an achievable set of protection needs is obtained.

Level 4 Quantitatively Controlled

Project & Resource Management (PRM) 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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