+DORA Ch. VI Art. 45 1.
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DORA Ch. VI Art. 45 1.
1. Financial entities may exchange amongst themselves cyber threat information and intelligence, including indicators of compromise, tactics, techniques, and procedures, cyber security alerts and configuration tools, to the extent that such information and intelligence sharing:
- (a) aims to enhance the digital operational resilience of financial entities, in particular through raising awareness in relation to cyber threats, limiting or impeding the cyber threats’ ability to spread, supporting defence capabilities, threat detection techniques, mitigation strategies or response and recovery stages;
- (b) takes places within trusted communities of financial entities;
- (c) is implemented through information-sharing arrangements that protect the potentially sensitive nature of the information shared, and that are governed by rules of conduct in full respect of business confidentiality, protection of personal data in accordance with Regulation (EU) 2016/679 and guidelines on competition policy.
1. Übersicht
1.1 Referenzen
1.2 Identifizierte Anforderungen
1.3 Related Standards
2. Identifizierte Anforderungen
Anforderungen
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Anforderung |
3. Related Standards
Standards
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Anforderung |
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NOREA
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Incident Classification Criteria
Classify ICT-related incidents based on their impact using the following criteria: number of clients/customers or financial counterparts affected, number of transactions affected, reputational damage, duration of the incident and downtime of services, geographical spread of the incident, data loss in relation to the CIA-triad, criticality of the services affected, and the overall economic impact of the incident.
An incident is considered major if (1) any malicious unauthorised access to network and information systems is identified, which may result to data losses or (2) the thresholds of two additional criteria are met (refer to the DORA RTS IM (Major Incidents) sheet for the thresholds). Also, take into account recurring incidents, where recurring incidents are considered major when (1) the incidents have occurred at least twice within 6 months, (2) the incidents have the same apparent root cause, (3) the incidents collectively categorise as a major incident.
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NOREA
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Cyber Threat Classification Criteria and Information Exchenge
Classify significant cyber threats. A threat is considered significant if it has a high probability of materialisation, could meet any of the criteria that classify as a 'major incident' when materialised, and when it could affect or could have affected critical or important functions of the financial entity, or could affect other financial entities, third party providers, clients or financial counterparts.
Cyber threat information and intelligence may be exchanged with other financial entities, ensuring such sharing enhances digital operational resilience. In this case, ensure that the exchange includes information such as indicators of compromise, tactics, techniques, procedures, alerts, and configuration tools. The exchange must occur within trusted communities and be governed by information-sharing arrangements that safeguard business confidentiality, personal data , and respect competition law. These arrangements shall clearly define participation conditions, address the potential involvement of public authorities and ICT third-party providers, and specify operational aspects, including the use of secure IT platforms. Notify competent authorities upon joining or leaving such arrangements.
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SCF
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Contacts With Groups & Associations
Description
Mechanisms exist to establish contact with selected groups and associations within the security, compliance and resilience communities to:
(1) Facilitate ongoing cybersecurity and data protection education and training for organizational personnel;
(2) Maintain currency with recommended cybersecurity and data protection practices, techniques and technologies; and
(3) Share current cybersecurity and/or data protection-related information including threats, vulnerabilities and incidents.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ ISACA chapters (https://www.isaca.org)
∙ ISC2 chapters (https://www.isc2.org)
∙ IAPP chapters (https://iapp.org)
∙ CISA free resources and advisories (https://www.cisa.gov)
∙ SANS reading room, vendor security blogs
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ ISACA chapters (https://www.isaca.org)
∙ ISC2 chapters (https://www.isc2.org)
∙ IAPP chapters (https://iapp.org)
∙ CISA free resources and advisories (https://www.cisa.gov)
∙ MS-ISAC free membership (https://www.cisecurity.org/ms-isac)
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ ISACA chapters (https://www.isaca.org)
∙ ISC2 chapters (https://www.isc2.org)
∙ IAPP chapters (https://iapp.org)
∙ CISA advisories and threat alerts (https://www.cisa.gov)
∙ Sector-specific ISAC membership
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ ISACA chapters (https://www.isaca.org)
∙ ISC2 chapters (https://www.isc2.org)
∙ IAPP chapters (https://iapp.org)
∙ Sector ISAC active membership (e.g., FS-ISAC, H-ISAC)
∙ CISA Cyber Information Sharing program
∙ InfraGard membership (https://www.infragard.org)
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ ISACA enterprise membership (https://www.isaca.org)
∙ ISC2 enterprise programs (https://www.isc2.org)
∙ IAPP enterprise membership (https://iapp.org)
∙ Sector ISAC leadership participation
∙ InfraGard and CISA partnership programs
∙ Sector-specific policy engagement (FS-ISAC, NTIA, 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
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
Cybersecurity & Data Protection Governance (GOV) 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 GOV domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with GOV 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 GOV domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Governance-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ No formal Governance, Risk & Compliance (GRC) team exists. GRC roles are assigned to existing IT and/or cybersecurity personnel.
▪ Cybersecurity and data privacy personnel identify and maintain contact information for local, regional and national cybersecurity / data privacy groups and associations.
Level 3 Well Defined
Cybersecurity & Data Protection Governance (GOV) 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 GOV 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 GOV domain capabilities are well-documented and kept current by process owners.
▪ The entity's GRC team, or similar function, is appropriately staffed and supported to implement and maintain GOV 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).
▪ Technology is leveraged to enhance the efficiency and accuracy of governance, risk management and compliance operations (e.g., GRC platform).
▪ An implemented and operational capability exists to establish contact with selected groups and associations within the security, compliance and resilience communities to:
(1) Facilitate ongoing cybersecurity and data protection education and training for organizational personnel;
(2) Maintain currency with recommended cybersecurity and data protection practices, techniques and technologies; and
(3) Share current cybersecurity and/or data protection-related information including threats, vulnerabilities and incidents.
Level 4 Quantitatively Controlled
Cybersecurity & Data Protection Governance (GOV) 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
Cybersecurity & Data Protection Governance (GOV) 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.
▪ Based on predictive analysis, process improvements are implemented according to “continuous improvement” practices that affect process changes.
▪ Stakeholders make time-sensitive decisions to support operational efficiency, which may include automated remediation actions.
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SCF
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Threat Intelligence Program
Description
Mechanisms exist to implement a threat intelligence program that includes a cross-organization information-sharing capability that can influence the development of the system and security architectures, selection of security solutions, monitoring, threat hunting, response and recovery activities.
Possible Solutions & Considerations
Micro-Small Business (<10 staff) / BLS Firm Size Classes 1-2
∙ Subscribe to free threat intelligence feeds (e.g., CISA alerts)
Small Business (10-49 staff) / BLS Firm Size Classes 3-4
∙ CISA alerts subscription
∙ Basic threat awareness program
Medium Business (50-249 staff) / BLS Firm Size Classes 5-6
∙ Threat intelligence program
Large Business (250-999 staff) / BLS Firm Size Classes 7-8
∙ Threat intelligence program
Enterprise (> 1,000 staff) / BLS Firm Size Class 9
∙ Threat intelligence program
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
Threat Management (THR) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with THR domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Threat 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 subscribe to threat feeds to maintain situational awareness of emerging threats.
Level 2 Planned Tracked
Threat Management (THR) 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 THR domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with THR 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 THR domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Threat management-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Threat management 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
Threat Management (THR) 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 THR 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 THR domain capabilities are well-documented and kept current by process owners.
▪ A threat management team, or similar function, is appropriately staffed and supported to implement and maintain THR domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of threat management operations (e.g., threat intelligence solution, bug bounty 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 THR 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 implement a threat intelligence program that includes a cross-organization information-sharing capability that can influence the development of the system and security architectures, selection of security solutions, monitoring, threat hunting, response and recovery activities.
Level 4 Quantitatively Controlled
Threat Management (THR) 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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