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Digital Operational Resilience Act (DORA)
Article 13: Learning and evolving

Requirement description

1. Financial entities shall have in place capabilities and staff to gather information on vulnerabilities and cyber threats, ICT-related incidents, in particular cyber-attacks, and analyse the impact they are likely to have on their digital operational resilience.
2. Financial entities shall put in place post ICT-related incident reviews after a major ICT-related incident disrupts their core activities, analysing the causes of disruption and identifying required improvements to the ICT operations or within the ICT business continuity policy referred to in Article 11. Financial entities, other than microenterprises, shall, upon request, communicate to the competent authorities, the changes that were implemented following post ICT-related incident reviews as referred to in the first subparagraph. The post ICT-related incident reviews referred to in the first subparagraph shall determine whether the established procedures were followed and the actions taken were effective, including in relation to the following:
(a) the promptness in responding to security alerts and determining the impact of ICT-related incidents and their severity;
(b) the quality and speed of performing a forensic analysis, where deemed appropriate;
(c) the effectiveness of incident escalation within the financial entity;
(d) the effectiveness of internal and external communication.
3. Lessons derived from the digital operational resilience testing carried out in accordance with Articles 26 and 27 and from real life ICT-related incidents, in particular cyber-attacks, along with challenges faced upon the activation of ICT business continuity plans and ICT response and recovery plans, together with relevant information exchanged with counterparts and assessed during supervisory reviews, shall be duly incorporated on a continuous basis into the ICT risk assessment process. Those findings shall form the basis for appropriate reviews of relevant components of the ICT risk management framework referred to in Article 6(1). L 333/36 EN Official Journal of the European Union 27.12.2022
4. Financial entities shall monitor the effectiveness of the implementation of their digital operational resilience strategy set out in Article 6(8). They shall map the evolution of ICT risk over time, analyse the frequency, types, magnitude and evolution of ICT-related incidents, in particular cyber-attacks and their patterns, with a view to understanding the level of
ICT risk exposure, in particular in relation to critical or important functions, and enhance the cyber maturity and preparedness of the financial entity.
5. Senior ICT staff shall report at least yearly to the management body on the findings referred to in paragraph 3 and put forward recommendations.
6. Financial entities shall develop ICT security awareness programmes and digital operational resilience training as compulsory modules in their staff training schemes. Those programmes and training shall be applicable to all employees and to senior management staff, and shall have a level of complexity commensurate to the remit of their functions. Where appropriate, financial entities shall also include ICT third-party service providers in their relevant training schemes in accordance with Article 30(2), point (i).
7. Financial entities, other than microenterprises, shall monitor relevant technological developments on a continuous basis, also with a view to understanding the possible impact of the deployment of such new technologies on ICT security requirements and digital operational resilience. They shall keep up-to-date with the latest ICT risk management processes, in order to effectively combat current or new forms of cyber-attacks.

How to fill the requirement

Digital Operational Resilience Act (DORA)

Article 13: Learning and evolving

Task name
Priority
Status
Theme
Policy
Other requirements
Staff guidance and training procedure in cyber security
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Personnel security
Cyber security training
48
requirements

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29. Processing under the authority of the controller or processor
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32. Security of processing
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7.2.1: Management responsibilities
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7.2.2: Information security awareness, education and training
ISO27 Full
4 §: Tiedonhallinnan järjestäminen tiedonhallintayksikössä
TiHL
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Staff guidance and training procedure in cyber security
1. Task description

Our organization has defined procedures for maintaining staff's cyber security awareness.These may include e.g. the following things:

  • staff receive instructions describing the general guidelines of digital security related to their job role
  • staff receive training to maintain the appropriate digital and cyber security skills and knowledge required for the job role
  • staff demonstrate through tests that they have the security skills and knowledge required for the job role

Training should focus on the most relevant security aspects for each job role and include often enough the basics, which concern all employees:

  • employee's personal security responsibilities (e.g. for devices and processed data)
  • policies relevant for everyone (e.g. security incident reporting)
  • guidelines relevant for everyone (e.g. clean desk)
  • organization's security roles (who to contact with problems)
The goals of threat intelligence and the collection of information related to information security threats
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Development and cloud
Technical vulnerability management
8
requirements

Examples of other requirements this task affects

5.7: Threat intelligence
ISO27k1 Full
77: Menettely toimintaympäristön seuraamiseen
Sec overview
Article 13: Learning and evolving
DORA
4.1: Tietojärjestelmien tietoturvallisuus
TiHL: Tietoturva
ID.RA-2: Cyber threat intelligence is received from information sharing forums and sources.
CyFun
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The goals of threat intelligence and the collection of information related to information security threats
1. Task description

Organization carries out threat intelligence by gathering information about information security threats related to its operations and how to protect against them. The goal is to increase awareness of the threat environment, so that own security level can be better evaluated and adequate control measures implemented.

When collecting threat intelligence, all three levels must be taken into account:

  • strategic threat intelligence (e.g. information on the growing types of attackers and attacks)
  • tactical threat intelligence (e.g. information about tools and technologies used in attacks)
  • operational threat intelligence (e.g. details of specific attacks)

Principles related to threat intelligence should include:

  • setting targets for threat intelligence
  • identification, verification and selection of information sources used in threat intelligence
  • gathering threat intelligence
  • data processing for analysis (e.g. translation, formatting, compression)
Regular analysis and utilization of information related to information security threats
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Development and cloud
Technical vulnerability management
11
requirements

Examples of other requirements this task affects

5.7: Threat intelligence
ISO27k1 Full
23: Häiriöiden- ja poikkeamienhallintaprosessi
Sec overview
THREAT-2: Respond to Threats and Share Threat Information
C2M2: MIL1
Article 13: Learning and evolving
DORA
3.1.2: Subscribe to vulnerability intelligence services
NSM ICT-SP
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Regular analysis and utilization of information related to information security threats
1. Task description

Organization carries out threat intelligence by analyzing and utilizing collected information about relevant cyber security threats related and corresponding protections.

When analyzing and utilizing the collected threat intelligence information, the following points must be taken into account:

  • analyzing how the threat intelligence information relates to to our own operations
  • analyzing how relevant threat intelligence information is to our operations
  • communicating and sharing information in an understandable form to relevant persons
  • utilizing the findings of threat intelligence to determine the adequacy of technical protections, technologies used and information security testing methods for analysis
Learning from testing operational resilience
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Risk management and leadership
Cyber security management
3
requirements

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Article 13: Learning and evolving
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RC.IM-1: Recovery plans incorporate lessons learned.
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Learning from testing operational resilience
1. Task description

Organisation should have a process to analyse and learn from the operational resilience testing results, from actual cyber security incidents and from experiences of activating continuity plans. Relevant information and experiences should be exchanged with counterparts.

The lessons learned should be incorporated in to the cyber risk management process.

The organisation's top management should have a yearly report about the lessons from senior ICT staff along with recommendations for improvements.

Monitoring and analysing effectiveness of digital operational resilience strategy
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Risk management and leadership
Cyber security management
1
requirements

Examples of other requirements this task affects

Article 13: Learning and evolving
DORA
See all related requirements and other information from tasks own page.
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Monitoring and analysing effectiveness of digital operational resilience strategy
1. Task description

The organisation must monitor the effectiveness of their digital operational resilience strategy. This should include at least:

  • Mapping of ICT risk evaluation over time
  • Analyse frequency, type, scale and evolution of incidents
  • Special focus should be in patterns of cyber attacks

This should increase the awareness of exposure to cyber attack related risk especially with important and critical functions and preparedness against cyber attacks.

Follow-up analysis for security incidents
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Incident management
Incident management and response
22
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6.4: Menettelytavat virhe- ja ongelmatilanteissa
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RS.AN-2: The impact of the incident
NIST
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Follow-up analysis for security incidents
1. Task description

If it is difficult to identify the source of a security incident based on the primary treatment, a separate follow-up analysis is performed for the incident, in which the root cause is sought to be identified.

Regular periodic analysis and learning of incidents
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Incident management
Incident management and response
29
requirements

Examples of other requirements this task affects

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PR.IP-7: Protection processes
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PR.IP-8: Protection effectiveness
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DE.DP-5: Detection processes improvment
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RS.AN-2: The impact of the incident
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Regular periodic analysis and learning of incidents
1. Task description

The knowledge gained from analyzing and resolving security incidents should be used to reduce the likelihood of future incidents and their impact.

The organization regularly analyzes incidents as a whole. This process examines the type, amount and cost of incidents with the aim of identifying recurrent and significant incidents that need more action.

If recurrent incidents requiring response are identified, based on them:

  • new management tasks are created or current ones expanded
  • security guidelines in this area are refined or extended
  • a case example of the incident is created that is used to train staff to respond to or avoid similar incidents

Tasks included in the policy

Task name
Priority
Status
Theme
Policy
Other requirements
No items found.

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1.1 (MIL2): Manage IT and OT Asset Inventory
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1.1.1: Availability of information security policies
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1.1.1: Identify the organisation’s strategy and priorities
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1.1.2: Identify the organisation’s structures and processes for security management
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1.1.3: Identify the organisation’s processes for ICT risk management
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1.1.4: Identify the organisation’s tolerances for ICT risk
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1.1.5: Identify the organisation’s deliverables, information systems and supporting ICT functions
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1.1.6: Identify information processing and data flow
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1.2 (MIL2): Manage Information Asset Inventory
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1.2 (MIL3): Manage Information Asset Inventory
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1.2.1: Establish a process to identify devices and software in use at the organisation
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1.2.1: Scope of Information Security management
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1.2.2: Establish organisational guidelines for approved devices and software
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1.2.2: Information Security Responsibilities
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1.2.3: Identify devices in use at the organisation
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1.2.3: Information Security requirements in projects
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1.2.4: Definition of responsibilities with service providers
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1.2.4: Identify the software in use at the organisation
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1.2: Manage Information Asset Inventory
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1.3 (MIL2): Manage IT and OT Asset Configuration
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1.3 (MIL3): Manage IT and OT Asset Configuration
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1.3.1: Identification of information assets
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1.3.1: Identify the users of the information systems
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1.3.2: Classification of information assets
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1.3.2: Identify and define the different user categories
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1.3.3: Identify roles and responsibilities linked especially to ICT security
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1.3.3: Use of approved external IT services
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1.3.4: Use of approved software
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1.3: Manage IT and OT Asset Configuration
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1.4 (MIL2): Manage Changes to IT and OT Assets
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1.4 (MIL3): Manage Changes to IT and OT Assets
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1.4.1: Management of Information Security Risks
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1.4: Manage Changes to IT and OT Assets
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1.5 (MIL1): Management Activities for the ASSET domain
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1.5 (MIL2): Management Activities for the ASSET domain
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1.5 (MIL3): Management Activities for the ASSET domain
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1.5.1: Assessment of policies and requirements
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1.5.2: External review of ISMS
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1.5: Management Activities for the ASSET domain
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1.6.1: Reporting of security events
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1.6.2: Management of reported events
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1.6.3: Crisis preparedness
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10 §: Johdon vastuu
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10. Processing of personal data relating to criminal convictions and offences
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10.1 (MIL2): Establish Cybersecurity Program Strategy
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10.1.1: Policy on the use of cryptographic controls
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10.1.2: Key management
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10.1: Continuous improvement
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10.1: Cryptographic controls
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10.2 (MIL2): Establish and Maintain Cybersecurity Program
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10.2 (MIL3): Establish and Maintain Cybersecurity Program
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10.2: Establish and Maintain Cybersecurity Program
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10.2: Non-conformity and corrective action
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10.3 (MIL1): Management Activities for the PROGRAM domain
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10.3 (MIL2): Management Activities for the PROGRAM domain
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10.3 (MIL3): Management Activities for the PROGRAM domain
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10.3: Management Activities for the PROGRAM domain
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10: Cryptography
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10: Cryptography
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10: Cybersecurity Program Management (PROGRAM)
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11. Processing which does not require identification
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11.1.2: Physical entry controls
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11.1.3: Securing offices, rooms and facilities
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11.1.4: Protecting against external and environmental threats
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11.1.5: Working in secure areas
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11.1.6: Delivery and loading areas
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11.1: Secure areas
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11.2.1: Equipment siting and protection
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11.2.2: Supporting utilities
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11.2.3: Cabling security
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11.2.4: Equipment maintenance
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11.2.5: Removal of assets
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11.2.6: Security of equipment and assets off-premises
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11.2.7: Secure disposal or re-use of equipment
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11.2.7: Secure disposal or re-use of equipment
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11.2.8: Unattended user equipment
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11.2.9: Clear desk and clear screen policy
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11: Physical and environmental security
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11: Physical and environmental security
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12.2: Protection from malware
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