DORA Ch. II Sec. II Art. 8 6.

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.

SCF

Asset Inventories

Description

Mechanisms exist to perform inventories of Technology Assets, Applications, Services and/or Data (TAASD) that:
(1) Accurately reflects the current TAASD in use;
(2) Identifies authorized software products, including business justification details;
(3) Is at the level of granularity deemed necessary for tracking and reporting;
(4) Includes organization-defined information deemed necessary to achieve effective property accountability; and
(5) Is available for review and audit by designated organizational personnel.

Possible Solutions & Considerations

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

∙ IT Asset Management (ITAM) program
∙ Spreadsheet-based asset inventory or Snipe-IT (free, https://snipeitapp.com)
∙ JAMF (https://jamf.com) for Apple device management
∙ Configuration Management Database (CMDB)

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

∙ IT Asset Management (ITAM) program
∙ ManageEngine AssetExplorer (https://manageengine.com)
∙ JAMF (https://jamf.com) or Microsoft Intune for device management
∙ Configuration Management Database (CMDB)

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

∙ IT Asset Management (ITAM) program
∙ ManageEngine AssetExplorer (https://manageengine.com)
∙ Ivanti (https://ivanti.com) or Microsoft Intune
∙ Configuration Management Database (CMDB)
∙ Lansweeper for network device discovery

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

∙ IT Asset Management (ITAM) program
∙ ManageEngine AssetExplorer or Ivanti (https://ivanti.com)
∙ Configuration Management Database (CMDB) (e.g., ServiceNow, Device42)
∙ Integration with network discovery tools (e.g., Nmap, Qualys Asset Inventory)

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

∙ IT Asset Management (ITAM) program
∙ Enterprise ITAM solution (e.g., Ivanti, Snow Software, Flexera)
∙ Configuration Management Database (CMDB) (e.g., ServiceNow CMDB)
∙ Automated asset discovery integrated with vulnerability management
∙ CIS Control 1 & 2 alignment

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

Asset Management (AST) 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 AST domain capabilities are formally documented and centrally-managed by the entity.
▪ Standardized Operating Procedures (SOP) associated with AST 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 AST domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD).
▪ Asset management-related controls are primarily administrative and preventative in nature (e.g., policies, standards, procedures & guidelines).
▪ Asset 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 IT department establishes, maintains and updates an inventory that contains a listing of all organizational-owned TAASD, at a minimum covering common devices (e.g., laptops, workstations and servers).
▪ Inventories may be manual (e.g., spreadsheets) or automated.
▪ Data/process owners for business-critical assets are documented and are reviewed as part of the annual asset inventories.
▪ Software licensing is tracked as part of IT asset inventories.
▪ No structured process exists to review or share the results of the inventories.
▪ Annual IT asset inventories validate or update stakeholders /owners.

Level 3 Well Defined

Asset Management (AST) 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 AST 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 AST domain capabilities are well-documented and kept current by process owners.
▪ An IT Asset Management (ITAM) team, or similar function, is appropriately staffed and supported to implement and maintain AST domain capabilities.
▪ Technology is leveraged to enhance the efficiency and accuracy of ITAM operations (e.g., ITAM platform, (e.g., Configuration Management Database (CMBD) Asset 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 AST 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 perform inventories of TAASD that:
(1) Accurately reflects the current TAASD in use;
(2) Identifies authorized software products, including business justification details;
(3) Is at the level of granularity deemed necessary for tracking and reporting;
(4) Includes organization-defined information deemed necessary to achieve effective property accountability; and
(5) Is available for review and audit by designated organizational personnel.

Level 4 Quantitatively Controlled

Asset Management (AST) 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

Asset Management (AST) 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.

SCF

Updates During Installations / Removals

Description

Mechanisms exist to update asset inventories as part of component installations, removals and asset upgrades.