ICT Risk Management

Organisations operating within the financial industry will be required to have a documented ICT risk management framework in place that allows it to identify, assess and address ICT risk, as well as ensuring high levels of digital operational resilience. This will require:  

• A continuous monitoring of ICT risk 
• Business continuity plans to be put in place, 
• Processes for analysing and learning from incidents when they do occur  

The regulation also designates the organisation’s managing body as being responsible for managing ICT risk and sufficient education on the topic and appropriately maturing their GRC (Governance, Risk & Compliance) procedure.

Climb’s DORA Checklist:

• Do you have a control in place to measure against DORA compliance ?
• Is there an asset lifecycle policy and procedure in place?
• Do you have assets checked for compliance with standard software packages to meet security requirements?
• Are all assets fully inventoried and assessed for vulnerabilities?
• Is there a process in place to ensure systems are up to date?
• Has resiliency been accounted for both systems and data?

ICT-related incident reporting

Financial institutions will need to establish processes for monitoring, logging and classifying ICT network performance issues and ICT-related incidents. The point(s) of failure needs to be identified and reported to the appropriate authorities promptly. 

This will create multiple layers of control, define alert thresholds and criteria to trigger and initiate ICT-related incident response processes.

Climb’s DORA Checklist:

• Do you have a solution in place to provide observability across on-premises, cloud assets and applications?
• Is a system of alerting in place that can initiate automated incidents for action?
• Can you confirm processes are in place to safeguard from cyber threats?
• Do you have the ability to perform cyber resilience testing?

Digital operational resilience testing

Financial entities will be required to implement the ICT business continuity policy through dedicated, appropriate and documented arrangements, plans, procedures and mechanisms aiming to:  

• Ensure the continuity of the financial entity’s critical or important functions 
• Quickly, appropriately and effectively respond to, and resolve, all ICT-related incidents in a way that limits damage and priorities the resumption of activities and recovery actions 
• Activate, without delay, dedicated plans that enable containment measures, processes and technologies suited to each type of ICT-related incident and prevent further damage, as well as tailored response and recovery procedures established

Climb’s DORA Checklist:

• Does the capability exist for dependency mapping?
• Is there a process for business continuity testing?
• Are data recovery solutions and procedures in place?

ICT third-party risk management

Entities are required to structure their contracts with third parties to ensure that proper due diligence and ongoing assessment of any third-party relationships can be performed. They’ll also need specific processes for identifying and continuously evaluating critical third-party service providers. 

Organisations will also be required to keep a register of all of their third-party relationships. These contracts are required to include:  

• Service level descriptions including updates and revisions. 
• Confirmed assistance in case of an ICT-related incident at no additional cost or at a previously determined cost. 
• Full cooperation with the competent authorities and resolution authorities of the financial entity. 
• Termination rights and related minimum notice periods.  
• Participation in the financial entities’ ICT security awareness programs and digital operational resilience training. 
• Participate and fully cooperate in a threat led penetration test of the financial entity. 

Climb’s DORA Checklist:

• Is a process in place for the continual review of TPRM?
• Is there a full inventory of all assets?
• Are assets fully assessed for vulnerabilities?
• Does a method exist for providing updates to assets?

Information sharing

This pillar is in place to promote information and intelligence sharing between trusted financial institutions to improve digital resiliency. They are required to implement mechanisms and procedures to review and take action, to ensure any shared information remains secure.

Climb’s DORA Checklist:

• Do you share sensitive content internally within the organisation?
• Does the content only get shared utilising the organisations secure network?
• Is a method employed to audit and control access to shared content ?
• Is content shared externally of the organisation to other third parties?
• Do you have a method employed to audit and control access to externally shared content?
• Are there any legal, financial or sensitive implications associated with the content?
• Is a method employed to audit and control access to shared content?