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DORA simplified RMF
Article 31: ICT risk management

Requirement description

1. The financial entities referred to in Article 16(1) of Regulation (EU) 2022/2554 shall include in their simplified ICT risk management framework all of the following:

(a) a determination of the risk tolerance levels for ICT risk, in accordance with the risk appetite of the financial entity;

(b) the identification and assessment of the ICT risks to which the financial entity is exposed;

(c) the specification of mitigation strategies at least for the ICT risks that are not within the risk tolerance levels of the financial entity;

(d) the monitoring of the effectiveness of the mitigation strategies referred to in point (c);

(e) the identification and assessment of any ICT and information security risks resulting from any major change in ICT system or ICT services, processes, or procedures, and from ICT security testing results and after any major ICT-related incident.

2. The financial entities referred to in paragraph 1 shall carry out and document the ICT risk assessment periodically commensurate to the financial entities’ ICT risk profile.

3. The financial entities referred to in paragraph 1 shall continuously monitor threats and vulnerabilities that are relevant to their critical or important functions, and information assets and ICT assets, and shall regularly review the risk scenarios impacting those critical or important functions.

4. The financial entities referred to in paragraph 1 shall set out alert thresholds and criteria to trigger and initiate ICT-related incident response processes.

How to fill the requirement

DORA simplified RMF

Article 31: ICT risk management

Task name
Priority
Status
Theme
Policy
Other requirements
Identification and documentation of cyber security risks
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Risk management and leadership
Risk management
42
requirements

Examples of other requirements this task affects

T04: Turvallisuusriskien hallinta
Katakri
13 §: Tietoaineistojen ja tietojärjestelmien tietoturvallisuus
TiHL
24. Responsibility of the controller
GDPR
5. Principles relating to processing of personal data
GDPR
8.3: Information security risk treatment
ISO 27001
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Identification and documentation of cyber security risks
1. Task description

The organization proactively seeks to list and assess the likelihood and severity of various cyber security risks. The documentation shall include the following:

  • Description of the risk
  • Evaluated impact and likelihood of the risk
  • Tasks for managing the risk or other treatment options
  • Acceptability of the risk
Risk management procedure -report publishing and maintenance
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Risk management and leadership
Risk management
42
requirements

Examples of other requirements this task affects

T04: Turvallisuusriskien hallinta
Katakri
5.1.1: Policies for information security
ISO 27001
8.2: Information security risk assessment
ISO 27001
ID.GV-4: Processes
NIST
ID.RA-5: Risk evaluation
NIST
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Risk management procedure -report publishing and maintenance
1. Task description

The organization has defined procedures for assessing and treating cyber security risks. The definition includes at least:

  • Risk identification methods
  • Methods for risk analysis
  • Criteria for risk evaluation (impact and likelihood)
  • Risk priorisation, treatment options and defining control tasks
  • Risk acceptance criteria
  • Process implementation cycle, resourcing and responsibilities
  • The results should be included into the organization risk management process

The task owner regularly checks that the procedure is clear and produces consistent results.

Treatment process and documentation of occurred security incidents
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Incident management
Incident management and response
49
requirements

Examples of other requirements this task affects

T06: Turvallisuuspoikkeamien hallinta
Katakri
32. Security of processing
GDPR
12. Transparent information, communication and modalities for the exercise of the rights of the data subject
GDPR
16.1.5: Response to information security incidents
ISO 27001
6.4: Menettelytavat virhe- ja ongelmatilanteissa
Omavalvontasuunnitelma
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Treatment process and documentation of occurred security incidents
1. Task description

All security incidents are addressed in a consistent manner to improve security based on what has happened.

In the incident treatment process:

  • the reported incident is confirmed (or found unnecessary to record)
  • the type and cause of incident is documented
  • the risks associated with the incident are documented
  • the risks are re-evaluated and treated if that is necessary after the incident
  • risk mitigation measures or a decision their acceptance is documented
  • people who need to be informed of the results of the incident treatment are identified (including external ones)
  • possible need for a post-incident analysis is determined
Process for managing technical vulnerabilities
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Development and cloud
Technical vulnerability management
38
requirements

Examples of other requirements this task affects

12.6.1: Management of technical vulnerabilities
ISO 27001
14.2.1: Secure development policy
ISO 27001
ID.RA-1: Asset vulnerabilities
NIST
PR.IP-12: Vulnerability management plan
NIST
RS.AN-5: Vulnerability management process
NIST
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Process for managing technical vulnerabilities
1. Task description

The organization has defined a process for addressing identified technical vulnerabilities.

Some vulnerabilities can be fixed directly, but vulnerabilities that have a significant impact should also be documented as security incidents. Once a vulnerability with significant impacts has been identified:

  • risks related to the vulnerability and the necessary actions are identified (e.g. patching the system or other management tasks)
  • necessary actions are scheduled
  • all actions taken are documented
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
10
requirements

Examples of other requirements this task affects

5.7: Threat intelligence
ISO 27001
77: Menettely toimintaympäristön seuraamiseen
Digiturvan kokonaiskuvapalvelu
Article 13: Learning and evolving
DORA
4.1: Tietojärjestelmien tietoturvallisuus
TiHL tietoturvavaatimukset
ID.RA-2: Cyber threat intelligence is received from information sharing forums and sources.
CyberFundamentals
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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)
Creating and maintaining incident response plans
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Incident management
Incident management and response
7
requirements

Examples of other requirements this task affects

4.1.1: Establish plans for incident management
NSM ICT-SP
ID.IM-04: Incident response and cybersecurity plans
NIST 2.0
PR.IR-03: Meeting resilience requirements
NIST 2.0
RC.RP-01: Recovery plan
NIST 2.0
RS.MA-01: Incident response plan execution
NIST 2.0
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Creating and maintaining incident response plans
1. Task description

The organization should create and maintain incident response plans. The response plans should include at least:

  • Incident or the type of incident for which the plan has been made
  • Goal for plan
  • Responsible persons and related stakeholders and contact information
  • Planned immediate actions
  • Planned next steps
Defining security events and incidents
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Incident management
Incident management and response
4
requirements

Examples of other requirements this task affects

1.6.1: Reporting of security events
TISAX
DE.AE-08: Incidents declaration criteria
NIST 2.0
17.9: Establish and Maintain Security Incident Thresholds
CIS 18
Article 31: ICT risk management
DORA simplified RMF
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Defining security events and incidents
1. Task description

Organisation must develop a clear, comprehensive definition of what constitutes a reportable security event or observation, ensuring it covers the following categories:

  • Personnel misconduct or misbehavior.
  • Intrusion, theft, unauthorized access to security zones, and vulnerabilities in security zones.
  • Cybersecurity incidents such as vulnerabilities in IT systems, and detected successful or unsuccessful cyber-attacks.
  • Supplier and partner incidents that could negatively impact the security of the organization.

Organisation must have a defined procedure for reporting of incidents and it should be communicated to the personnel:

  • Design and implement effective reporting mechanisms tailored to perceived risks.
  • Ensure these mechanisms are well communicated and accessible to all employees, stakeholders, and relevant parties to facilitate timely and accurate reporting of security events.
  • Conduct training sessions and awareness programs to ensure that all relevant employees and stakeholders understand the definition of reportable security events and are familiar with the reporting mechanisms.
Enabling asset-based risk management in the ISMS
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Risk management and leadership
Risk management
5
requirements

Examples of other requirements this task affects

Article 8: Identification
DORA
2.5: Riskienhallinta
TiHL tietoturvavaatimukset
5.2.2: Seperation of testing and development environments
TISAX
1.1.3: Identify the organisation’s processes for ICT risk management
NSM ICT-SP
Article 31: ICT risk management
DORA simplified RMF
See all related requirements and other information from tasks own page.
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Enabling asset-based risk management in the ISMS
1. Task description

The organization must enable asset based risk management from the ISMS settings.

Asset-based risk management should be set to cover all needed asset types with high enough criticality. The asset based risk management should be used at least for:

  • System providers
  • Data systems
  • Data stores
  • Other stakeholders
  • Other assets
Change management procedure for significant changes to data processing services
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Development and cloud
Secure development
28
requirements

Examples of other requirements this task affects

14.2.2: System change control procedures
ISO 27001
14.2.4: Restrictions on changes to software packages
ISO 27001
PR.DS-6: Integrity checking
NIST
TEK-17: Muutoshallintamenettelyt
Julkri
8.32: Change management
ISO 27001
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Change management procedure for significant changes to data processing services
1. Task description

Inadequate change management is a common cause of incidents for digital services.

An organization shall document the change management process that must be followed whenever significant changes are made to developed digital services or other computing services that affect cyber security. The process includes requirements e.g. for the following:

  • Defining and documenting the change
  • Assessing the risks and defining the necessary control measures
  • Other impact assessment of the change
  • Testing and quality assurance
  • Managed implementation of the change
  • Updating a change log
Assessment of the impact and likelihood of the risks and the scales used
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Risk management and leadership
Risk management
9
requirements

Examples of other requirements this task affects

ID.RA-4: Impacts on business
NIST
Article 6: ICT risk management framework
DORA
2.5: Riskienhallinta
TiHL tietoturvavaatimukset
1.4.1: Management of Information Security Risks
TISAX
ID.RA-04: Impacts and likelihoods of threats
NIST 2.0
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Assessment of the impact and likelihood of the risks and the scales used
1. Task description

As part of the security risk assessment, the organization shall make assessments of the severity and probability of the risk materializing.

The organization shall have a clearly instructed risk scale that allows each participant in the risk assessment to decide on the appropriate level of severity and probability.

Risk level accepted by the organization
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Risk management and leadership
Risk management
19
requirements

Examples of other requirements this task affects

ID.RM-2: Risk tolerance
NIST
ID.RM-3: Informing of risk tolerance
NIST
6.1: Information security risk management
ISO 27001
RISK-1: Establish and Maintain Cyber Risk Management Strategy and Program
C2M2
21.2.a: Risk management and information system security
NIS2
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Risk level accepted by the organization
1. Task description

The organization must determine an acceptable level for risks. The level is calculated based on the likelihood, impact and control of the risks.

Riskien käsittelyvaiheessa määriteltyjen tietoturvallisuustoimenpiteiden arviointi
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Risk management and leadership
Risk management
5
requirements

Examples of other requirements this task affects

HAL-06: Riskienhallinta
Julkri
RISK-4: Respond to Cyber Risk
C2M2
CC5.1: Control activities for mitigation of risks
SOC 2
1.4.1: Management of Information Security Risks
TISAX
Article 31: ICT risk management
DORA simplified RMF
See all related requirements and other information from tasks own page.
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Riskien käsittelyvaiheessa määriteltyjen tietoturvallisuustoimenpiteiden arviointi
1. Task description

Tietoturvariskien hallintaa toteuttaessaan organisaation on tunnistettava käsittelyä vaativat riskit ja määriteltävä näille käsittelysuunnitelmat, jotka usein koostuvat uusista tietoturvallisuustoimenpiteistä.

Organisaatio on määritellyt, kuinka säännöllisesti arvioidaan kokonaisuutena määriteltyjä käsittelysuunnitelmia ja niiden oikeasuhtaisuutta riskeille täytettyihin arvioihin (riskin vakavuus ja todennäköisyys) verrattuna.

Monitoring the status of risk management
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Risk management and leadership
Risk management
8
requirements

Examples of other requirements this task affects

14.5.2): Aukščiausiosios vadovybės atsakomybė
NIS2 Lithuania
19: Riskienhallinan tilanteen seuraaminen
Digiturvan kokonaiskuvapalvelu
CC5.1: Control activities for mitigation of risks
SOC 2
Article 6: ICT risk management framework
DORA
2.5: Riskienhallinta
TiHL tietoturvavaatimukset
See all related requirements and other information from tasks own page.
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Monitoring the status of risk management
1. Task description

Implemented risk management measures and the overall situation of risk management are checked regularly.

The operating model for monitoring the status of risk management is clearly described.

Consideration of threat intelligence findings in the information security risk management process
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Development and cloud
Technical vulnerability management
4
requirements

Examples of other requirements this task affects

5.7: Threat intelligence
ISO 27001
3.3.4: Obtain and process threat information from relevant sources
NSM ICT-SP
ID.IM-02: Improvements from security tests and exercises
NIST 2.0
Article 31: ICT risk management
DORA simplified RMF
See all related requirements and other information from tasks own page.
Go to >
Consideration of threat intelligence findings in the information security risk management process
1. Task description

Organization must consider the threat intelligence process findings in the information security risk management process. Threat intelligence can detect, for example, the proliferation of certain types of attacks or the development of new technologies, based on which assessments of certain information security risks must be updated, which may lead to the need to reduce risks through treatment plans.

Continuous improvement of the risk management process
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Risk management and leadership
Risk management
12
requirements

Examples of other requirements this task affects

21: Riskienhallintaprosessin kehittäminen
Digiturvan kokonaiskuvapalvelu
21.2.a: Risk management and information system security
NIS2
Article 6: ICT risk management framework
DORA
1.4.1: Management of Information Security Risks
TISAX
8 §: Kyberturvallisuutta koskeva riskienhallinnan toimintamalli
Kyberturvallisuuslaki
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Continuous improvement of the risk management process
1. Task description

The organization has an operating model for continuously improving the functionality and efficiency of the risk management process.

In the improvement, it is possible to use e.g. general standards (e.g. ISO 27005) or feedback from people involved in risk management.

Tasks included in the policy

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

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38: Kiberuzbrukumu attiecināšana
NIS2 Latvia
1.1 (MIL2): Manage IT and OT Asset Inventory
C2M2
1.1 (MIL3): Manage IT and OT Asset Inventory
C2M2
1.1.1: Availability of information security policies
TISAX
1.1.1: Identify the organisation’s strategy and priorities
NSM ICT-SP
1.1.2: Identify the organisation’s structures and processes for security management
NSM ICT-SP
1.1.3: Identify the organisation’s processes for ICT risk management
NSM ICT-SP
1.1.4: Identify the organisation’s tolerances for ICT risk
NSM ICT-SP
1.1.5: Identify the organisation’s deliverables, information systems and supporting ICT functions
NSM ICT-SP
1.1.6: Identify information processing and data flow
NSM ICT-SP
1.1: Establish and Maintain Detailed Enterprise Asset Inventory
CIS 18
1.2 (MIL2): Manage Information Asset Inventory
C2M2
1.2 (MIL3): Manage Information Asset Inventory
C2M2
1.2.1: Establish a process to identify devices and software in use at the organisation
NSM ICT-SP
1.2.1: Scope of Information Security management
TISAX
1.2.2: Establish organisational guidelines for approved devices and software
NSM ICT-SP
1.2.2: Information Security Responsibilities
TISAX
1.2.3: Identify devices in use at the organisation
NSM ICT-SP
1.2.3: Information Security requirements in projects
TISAX
1.2.4: Definition of responsibilities with service providers
TISAX
1.2.4: Identify the software in use at the organisation
NSM ICT-SP
1.2: Address Unauthorized Assets
CIS 18
1.2: Manage Information Asset Inventory
C2M2
1.3 (MIL2): Manage IT and OT Asset Configuration
C2M2
1.3 (MIL3): Manage IT and OT Asset Configuration
C2M2
1.3.1: Identification of information assets
TISAX
1.3.1: Identify the users of the information systems
NSM ICT-SP
1.3.2: Classification of information assets
TISAX
1.3.2: Identify and define the different user categories
NSM ICT-SP
1.3.3: Identify roles and responsibilities linked especially to ICT security
NSM ICT-SP
1.3.3: Use of approved external IT services
TISAX
1.3.4: Use of approved software
TISAX
1.3: Manage IT and OT Asset Configuration
C2M2
1.3: Utilize an Active Discovery Tool
CIS 18
1.4 (MIL2): Manage Changes to IT and OT Assets
C2M2
1.4 (MIL3): Manage Changes to IT and OT Assets
C2M2
1.4.1: Management of Information Security Risks
TISAX
1.4: Manage Changes to IT and OT Assets
C2M2
1.4: Use Dynamic Host Configuration Protocol (DHCP) Logging to Update Enterprise Asset Inventory
CIS 18
1.5 (MIL1): Management Activities for the ASSET domain
C2M2
1.5 (MIL2): Management Activities for the ASSET domain
C2M2
1.5 (MIL3): Management Activities for the ASSET domain
C2M2
1.5.1: Assessment of policies and requirements
TISAX
1.5.2: External review of ISMS
TISAX
1.5: Management Activities for the ASSET domain
C2M2
1.5: Use a Passive Asset Discovery Tool
CIS 18
1.6.1: Reporting of security events
TISAX
1.6.2: Management of reported events
TISAX
1.6.3: Crisis preparedness
TISAX
10 §: Johdon vastuu
Kyberturvallisuuslaki
10. Processing of personal data relating to criminal convictions and offences
GDPR
10.1 (MIL2): Establish Cybersecurity Program Strategy
C2M2
10.1 (MIL3): Establish Cybersecurity Program Strategy
C2M2
10.1.1: Policy on the use of cryptographic controls
ISO 27001
10.1.2: Key management
ISO 27001
10.1.2: Key management
ISO 27017
10.1: Cryptographic controls
ISO 27001
10.1: Cryptographic controls
ISO 27017
10.1: Deploy and Maintain Anti-Malware Software
CIS 18
10.1: Establish Cybersecurity Program Strategy
C2M2
10.1: Non-conformity and corrective action
ISO 27001
10.2 (MIL2): Establish and Maintain Cybersecurity Program
C2M2
10.2 (MIL3): Establish and Maintain Cybersecurity Program
C2M2
10.2: Establish and Maintain Cybersecurity Program
C2M2
10.2: Configure Automatic Anti-Malware Signature Updates
CIS 18
10.2: Continuous improvement
ISO 27001
10.3 (MIL1): Management Activities for the PROGRAM domain
C2M2
10.3 (MIL2): Management Activities for the PROGRAM domain
C2M2
10.3 (MIL3): Management Activities for the PROGRAM domain
C2M2
10.3: Disable Autorun and Autoplay for Removable Media
CIS 18
10.3: Management Activities for the PROGRAM domain
C2M2
10.4: Configure Automatic Anti-Malware Scanning of Removable Media
CIS 18
10.5: Enable Anti-Exploitation Features
CIS 18
10.6: Centrally Manage Anti-Malware Software
CIS 18
10.7: Use Behavior-Based Anti-Malware Software
CIS 18
10: Cryptography
ISO 27001
10: Cryptography
ISO 27017
10: Cybersecurity Program Management (PROGRAM)
C2M2
10: Prosessi väärinkäytöksiin reagoimiseksi
Digiturvan kokonaiskuvapalvelu
11 §: Poikkeamailmoitukset viranomaiselle
Kyberturvallisuuslaki
11. Processing which does not require identification
GDPR
11.1.1: Physical security perimeter
ISO 27001
11.1.2: Physical entry controls
ISO 27001
11.1.3: Securing offices, rooms and facilities
ISO 27001
11.1.4: Protecting against external and environmental threats
ISO 27001
11.1.5: Working in secure areas
ISO 27001
11.1.6: Delivery and loading areas
ISO 27001
11.1: Establish and Maintain a Data Recovery Process
CIS 18
11.1: Secure areas
ISO 27001
11.2.1: Equipment siting and protection
ISO 27001
11.2.2: Supporting utilities
ISO 27001
11.2.3: Cabling security
ISO 27001
11.2.4: Equipment maintenance
ISO 27001
11.2.5: Removal of assets
ISO 27001
11.2.6: Security of equipment and assets off-premises
ISO 27001
11.2.7: Secure disposal or re-use of equipment
ISO 27001
11.2.7: Secure disposal or re-use of equipment
ISO 27017
11.2.8: Unattended user equipment
ISO 27001
11.2.9: Clear desk and clear screen policy
ISO 27001
11.2: Equipment
ISO 27001