Here is a list of all DORA security requirements for your organization. You can print it out and start working on them, before it is too late!
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1. ICT Risk Management Framework
- Establish and maintain a comprehensive ICT risk management framework.
- Integrate ICT risk management into overall risk management processes.
- Define clear roles and responsibilities for ICT risk management.
- Ensure management body oversight and accountability for ICT risks.
- Regularly update the framework to reflect changes in ICT risk landscape.
2. ICT Risk Management Processes
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Identification of ICT Risks
- Continuously identify and assess ICT risks.
- Maintain an inventory of ICT assets and their risk profiles.
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Protection and Prevention Measures
- Implement security policies and controls to mitigate identified risks.
- Ensure data protection and confidentiality.
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Detection Measures
- Establish systems to detect anomalous activities and potential ICT incidents.
- Monitor networks and systems continuously.
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Response and Recovery
- Develop and maintain an ICT incident response plan.
- Ensure business continuity and disaster recovery plans are in place.
- Test response and recovery plans regularly.
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Learning and Evolving
- Analyze incidents to improve future responses.
- Update policies and procedures based on lessons learned.
3. ICT Systems, Protocols, and Tools
- Ensure ICT systems are resilient and secure.
- Implement access controls and authentication mechanisms.
- Regularly update and patch ICT systems.
- Use encryption and other security technologies where appropriate.
- Maintain documentation of ICT systems and protocols.
4. ICT Incident Reporting
- Establish an internal process for ICT incident management.
- Classify ICT incidents based on impact and severity.
- Report major ICT incidents to competent authorities promptly.
- Notify clients and stakeholders about incidents when relevant.
- Keep records of all ICT incidents and reporting actions.
5. Digital Operational Resilience Testing
- Conduct regular ICT security assessments.
- Perform vulnerability assessments and penetration testing.
- Engage in threat-led penetration testing where applicable.
- Address and remediate identified vulnerabilities promptly.
- Document testing methodologies and results.
6. ICT Third-Party Risk Management
- Maintain an up-to-date register of all ICT third-party service providers.
- Conduct due diligence before engaging third-party providers.
- Ensure contracts include:
- Service level agreements (SLAs).
- Security and confidentiality obligations.
- Termination rights and exit strategies.
- Monitor third-party performance and compliance regularly.
- Assess the concentration risk of third-party dependencies.
- Develop contingency plans for third-party service disruptions.
7. Information Sharing Arrangements
- Participate in information-sharing networks where appropriate.
- Share information on cyber threats, vulnerabilities, and incidents.
- Ensure compliance with data protection and confidentiality laws during sharing.
- Establish procedures for receiving and disseminating shared information.
8. Governance and Oversight
- Ensure the management body is actively involved in ICT risk governance.
- Provide regular training on ICT risks to management and staff.
- Assign a senior management function responsible for ICT risks.
- Establish internal audit mechanisms to review ICT risk management.
- Report ICT risk matters to the management body regularly.
9. Specific Provisions for Critical ICT Third-Party Service Providers
- Identify if any ICT third-party providers are deemed critical.
- Ensure critical providers comply with oversight requirements.
- Engage with regulatory bodies regarding critical provider assessments.
- Include contractual clauses allowing for regulatory audits of critical providers.
10. Transitional Measures and Compliance
- Develop a roadmap to achieve full compliance within the implementation period.
- Review and adjust existing policies and contracts to meet DORA requirements.
- Engage with regulators to clarify any compliance uncertainties.
- Monitor for updates or additional guidelines related to DORA.