+DORA Ch. II Sec. II Art. 8 5.

DORA Ch. II Sec. II Art. 8 5.

5.   Financial entities shall identify and document all processes that are dependent on ICT third-party service providers, and shall identify interconnections with ICT third-party service providers that provide services that support critical or important functions.

1. Übersicht

1.1 Referenzen

1.2 Identifizierte Anforderungen

1.3 Related Standards

2. Identifizierte Anforderungen

Anforderungen

3. Related Standards

Standards
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 Third-party Risk Management

Manage third-party risks proportionate to dependency nature, service-related risks, and impact on entity's continuity and availability in case of disruption. Implement a policy for critical function ICT services provided by third-party service providers, considering the location of the service provider (or its parent company), the level of assurance regarding the service providers' risk management framework (including risk mitigation and business continuity measures), the nature of the data shared with the service provider, the location of data processing and storage, group affiliation of the service provider, and the potential impact of the risks and disruptions on the continuity and availability on the activities of the entity. Test response and recovery of critical function-supporting services provided by third parties.
NOREA Pre-Contract Risk Assessment

Perform pre-contract risk assessment. This assessment must assess if: the contract covers services supporting critical or important functions, a service provider is easily replaceable, the risks of sub-contracting are covered, the risks of outsourcing service to a third-country are covered, the risks of bankruptcy are covered on the side of the service provider, supervisory conditions for contracting are met, all contractual risks are identified and assessed (e.g., to cover for ICT concentration risks), the service provider is suitable, and if there are conflicts of interest. Assess service provider resources for ensuring entity compliance with all legal and regulatory requirements.
NOREA Register of Information
Maintain a comprehensive register of information related to contractual arrangements with third-party service providers, distinguishing those supporting critical/important functions. Ensure that the register is in line with all mandatory fields as defined in the ITS on the register of information.
NOREA Contractual Requisites
Only contract with service providers meeting appropriate information security standards (e.g., ISO 27001, SOC, PCI-DSS, etc.) appropriate to the criticaly of services delivered. Determine audit frequency for service providers, ensuring auditors possess requisite skills and knowledge for complex services
NOREA Exit strategies

Develop and periodically test exit strategies and plans, considering risks related to third-party service providers, including potential failure, service quality deterioration, business disruption, and termination of contractual arrangements. Ensure that the exit plan is realistic, feasible, based on plausible scenarios and reasonable assumptions and shall have a planned implementation schedule compatible with the exit and termination terms established in the relevant contractual arrangements. Also, ensure smooth exit and workload migration to another service provider without business disruption, compliance loss, or service quality decline.

The DORA Taskforce has designed an exit plan template that could be of assistence, see: https://www.norea.nl/dora/dora-template-exit-plan 
NOREA Annual Reporting of New Arrangements
Report new service provider arrangements to the regulator, especially those supporting critical or important functions, to the regulator on a yearly basis, with immediate notification for critical services.
SCF Asset-Service Dependencies

Description

Mechanisms exist to identify and assess the security of Technology Assets, Applications and/or Services (TAAS) that support more than one critical business function.

Possible Solutions & Considerations

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

∙ IT Asset Management (ITAM) program

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

∙ IT Asset Management (ITAM) program

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

∙ IT Asset Management (ITAM) program
∙ Configuration Management Database (CMDB)

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

∙ IT Asset Management (ITAM) program
∙ Configuration Management Database (CMDB)

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

∙ IT Asset Management (ITAM) program
∙ Configuration Management Database (CMDB)

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

Asset Management (AST) domain capabilities are ad hoc and inconsistent. Capability criteria associated with this control may include:
▪ Policies, standards & procedures associated with AST domain capabilities provide limited coverage due to the depth and breadth of the existing documentation.
▪ Asset management-related activities are decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
▪ Asset management is informally assigned as an additional duty to existing IT/cybersecurity personnel.
▪ Inventories are manual (e.g., spreadsheets).
▪ Data / process owners maintain limited network diagrams to document the flow of sensitive/regulated data that is specific to their initiative.
▪ Inventory of physical technology assets are assigned to individual users or teams and covers common devices (e.g., laptops, workstations and servers).
▪ No structured process exists to review or share the results of the inventories.

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).

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 i identify and assess the security of Technology Assets, Applications and/or Services (TAAS) that support more than one critical business function.

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

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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