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DORA simplified RMF
Article 35: Data, system and network security

Requirement description

The financial entities referred to in Article 16(1) of Regulation (EU) 2022/2554 shall, as part of their systems, protocols, and tools, develop and implement safeguards that ensure the security of networks against intrusions and data misuse and that preserve the availability, authenticity, integrity, and confidentiality of data. In particular, financial entities shall, taking into account the classification referred to in Article 30(1) of this Regulation, establish all of the following:

(a) the identification and implementation of measures to protect data in use, in transit, and at rest;

(b) the identification and implementation of security measures regarding the use of software, data storage media, systems and endpoint devices that transfer and store data of the financial entity;

(c) the identification and implementation of measures to prevent and detect unauthorised connections to the financial entity’s network, and to secure the network traffic between the financial entity’s internal networks and the internet and other external connections;

(d) the identification and implementation of measures that ensure the availability, authenticity, integrity, and confidentiality of data during network transmissions;

(e) a process to securely delete data on premises, or that are stored externally, that the financial entity no longer needs to collect or store;

(f) a process to securely dispose of, or decommission, data storage devices on premises, or data storage devices that are stored externally, that contain confidential information;

(g) the identification and implementation of measures to ensure that teleworking and the use of private endpoint devices does not adversely impact the financial entity’s ability to carry out its critical activities in an adequate, timely, and secure manner.

How to fill the requirement

DORA simplified RMF

Article 35: Data, system and network security

Task name
Priority
Status
Theme
Policy
Other requirements
Selection and use of malware detection software on all devices
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Technical cyber security
Malware protection
31
requirements

Examples of other requirements this task affects

12.2: Protection from malware
ISO 27001
12.2.1: Controls against malware
ISO 27001
I09: Haittaohjelmasuojaus
Katakri
6.5: Tietojärjestelmien asennus, ylläpito ja päivitys
Omavalvontasuunnitelma
DE.CM-4: Malicious code detection
NIST
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Selection and use of malware detection software on all devices
1. Task description

Centrally select and install malware detection and repair programs and update them regularly for preventive or regular scanning of computers and media.

Programs should check at least the following:

  • files received over the network or storage media are scanned for malware before use
  • email attachments and downloaded files are scanned for malware before use
  • websites are scanned for malware
Rules ensuring secure network data transfer
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Management of data sets
Management of data sets
4
requirements

Examples of other requirements this task affects

5.1.2: Information transfer
TISAX
PR.AA-04: Identity assertions
NIST 2.0
PR.DS-02: Data-in-transit is protected
NIST 2.0
Article 35: Data, system and network security
DORA simplified RMF
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Rules ensuring secure network data transfer
1. Task description

To protect information transferred via public or private networks from reading or manipulation by third parties, the organization has:

  • Identified and documented network services used to transfer information
  • Determined policies and procedures in accordance with the classification requirements for the use of network services
  • Implemented measures to protect the actual transferred data against unauthorized access
Encryption of laptops
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Technical cyber security
Encryption
20
requirements

Examples of other requirements this task affects

10.1.1: Policy on the use of cryptographic controls
ISO 27001
6.6.4: Fyysisten tilojen, laitteiden ja tulosteiden turvallisuus
Omavalvontasuunnitelma
TEK-18.1: Etäkäyttö - tietojen ja tietoliikenteen salaaminen
Julkri
8.24: Use of cryptography
ISO 27001
21.2.h: Encryption
NIS2
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Encryption of laptops
1. Task description

Laptops are protected by full-disk encryption.

Choosing and using network protection systems
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Technical cyber security
Virtualization
12
requirements

Examples of other requirements this task affects

PR.PT-4: Communications and control networks
NIST
ARCHITECTURE-2: Implement Network Protections as an Element of the Cybersecurity Architecture
C2M2
CC6.6: Logical access security measures against threats from sources outside system boundries
SOC 2
6.11: Alusta- ja verkkopalvelujen tietoturvallinen käyttö tietosuojan ja varautumisen kannalta
Tietoturvasuunnitelma
3.1.1: Management of secure areas
TISAX
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Choosing and using network protection systems
1. Task description

Cyber criminals can exploit configuration errors or technical vulnerabilities in applications, firewalls, or networks to access our information.

An organization must use defense-in-depth technologies to protect against, detect, and respond to cyber-attacks. The techniques should be suitable for controlling physical, logical and administrative controls.

Security of teleworking and privatively owned endpoints
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Remote work and mobile devices
Mobile device management
1
requirements

Examples of other requirements this task affects

Article 35: Data, system and network security
DORA simplified RMF
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Security of teleworking and privatively owned endpoints
1. Task description

The organization should have measures to ensure that teleworking and use of private endpoint devices are secured enough to not cause an impact to the organizations critical activities.

Safe destruction of data
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Management of data sets
Management of data sets
1
requirements

Examples of other requirements this task affects

Article 35: Data, system and network security
DORA simplified RMF
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Safe destruction of data
1. Task description

The organization must have process to securely delete data that in longer needs either on premises or data that is stored externally.

There also must be a secure process to dispose and decommission data storage devices, on-premises or external, that contain confidential information.

Implementing data deletion policies and using certified data erasure tools can enhance data security and compliance.

Using trust-based access control
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
System management
Access control and authentication
3
requirements

Examples of other requirements this task affects

2.5.2: Restrict access to internal services from external locations
NSM ICT-SP
2.2.6: Control access to services based on knowledge of users and devices
NSM ICT-SP
Article 35: Data, system and network security
DORA simplified RMF
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Using trust-based access control
1. Task description

Control access to services based on knowledge of users and devices.

One example is if a user logs in via an unmanaged device (the organisation trusts the user but does not control the device) and gains access to fewer services than if the user logs in via an organisation-managed device (the organisation knows both the user and the device).

Encryption and addressing protections for secure data transfer
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Technical cyber security
Encryption
3
requirements

Examples of other requirements this task affects

5.1.2: Information transfer
TISAX
3.10: Encrypt Sensitive Data in Transit
CIS 18
Article 35: Data, system and network security
DORA simplified RMF
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Encryption and addressing protections for secure data transfer
1. Task description

The organisation must have measures for ensuring correct addressing and correct transfer of information.

An electronic data exchange must be conducted using content or transport encryption suitable for the classification of data in transfer.

Arranging suitable equipment and storage equipment for teleworking
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Remote work and mobile devices
Remote work
8
requirements

Examples of other requirements this task affects

11.2.6: Security of equipment and assets off-premises
ISO 27001
6.2.2: Teleworking
ISO 27001
6.7: Remote working
ISO 27001
7.9: Security of assets off-premises
ISO 27001
2.1.4: Regulation for remote work
TISAX
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Arranging suitable equipment and storage equipment for teleworking
1. Task description

Arranging suitable equipment and storage for teleworking if the use of personal equipment beyond the control of the organization is not permitted.

If personal devices are used organization should utilize separate profiles (e.g. using Apple® Configuration Profile or AndroidTM Work Profile) to separate work data and apps from personal data and apps.

Endpoint security management system
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Remote work and mobile devices
Mobile device management
16
requirements

Examples of other requirements this task affects

13.1.1: Network controls
ISO 27001
6.2.1: Mobile device policy
ISO 27001
PR.PT-4: Communications and control networks
NIST
HAL-19: Tietojen käsittely
Julkri
8.1: User endpoint devices
ISO 27001
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Endpoint security management system
1. Task description

Endpoint security management system can be used to demand the desired security criteria from the devices before they are allowed to connect to the network resources. Devices can be laptops, smartphones, tablets or industry-specific hardware.

Criteria for the use of network resources may include e.g. approved operating system, VPN and antivirus systems, and the timeliness of these updates.

Encryption of portable media
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Technical cyber security
Encryption
22
requirements

Examples of other requirements this task affects

8.3.1: Management of removable media
ISO 27001
8.3.3: Physical media transfer
ISO 27001
10.1.1: Policy on the use of cryptographic controls
ISO 27001
PR.PT-2: Removable media
NIST
A.11.4: Protecting data on storage media leaving the premises
ISO 27018
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Encryption of portable media
1. Task description

Storing confidential information on removable media should be avoided. When removable media is used to transfer confidential information, appropriate security is used (e.g., full disk encryption with pre-boot authentication).

Smartphone and tablet encryption
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Technical cyber security
Encryption
4
requirements

Examples of other requirements this task affects

10.1.1: Policy on the use of cryptographic controls
ISO 27001
Article 35: Data, system and network security
DORA simplified RMF
See all related requirements and other information from tasks own page.
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Smartphone and tablet encryption
1. Task description

Devices that support full-device encryption are selected as smartphones and tablets for work use, and encryption is turned on.

Defining suitable locations and needed protections for remote work
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Remote work and mobile devices
Remote work
7
requirements

Examples of other requirements this task affects

6.2.2: Teleworking
ISO 27001
PR.AC-3: Remote access management
NIST
6.7: Remote working
ISO 27001
2.1.4: Regulation for remote work
TISAX
1.3.1: Identify the users of the information systems
NSM ICT-SP
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Defining suitable locations and needed protections for remote work
1. Task description

When working remotely, the employee must follow the following guidelines:

  • remote work may only be performed in rooms where eavesdropping is not possible
  • remote work must be agreed in advance (e.g. on a one-off basis or in an employment contract with flexible work arrangements) or remote work must be requested by the employer
  • the employee must ensure the required security for remote work equipment (e.g. backup, malware protection, firewall, encryption, updates)
Documentation of interfaces for data systems
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
System management
Data system management
24
requirements

Examples of other requirements this task affects

8.1.1: Inventory of assets
ISO 27001
22 §: Tietojen luovuttaminen teknisen rajapinnan avulla viranomaisten välillä
TiHL
23 §: Katseluyhteyden avaaminen viranomaiselle
TiHL
24 §: Tietoaineistojen luovuttaminen teknisen rajapinnan avulla muille kuin viranomaisille
TiHL
DE.AE-1: Baseline of network operations
NIST
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Documentation of interfaces for data systems
1. Task description

The organization maintains documentation of interfaces and other connections between data system and the data transmission methods used in the interfaces.

The documentation concerning the interfaces shall be reviewed regularly and after significant changes to data systems.

Protection of data in transit
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Technical cyber security
Encryption
17
requirements

Examples of other requirements this task affects

PR.DS-2: Data-in-transit
NIST
21.2.h: Encryption
NIS2
Article 9a: Protection
DORA
5.1.2: Information transfer
TISAX
9.8 §: Salaus
Kyberturvallisuuslaki
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Protection of data in transit
1. Task description

The data to be transmitted must be protected using cryptographic methods. The protection of the confidentiality and integrity of the data transmitted applies to the internal and external network and to all systems that can transmit data. These include:

  • Servers
  • Computers
  • Mobile devices
  • Printers

The data to be transferred can be protected by physical or logical means.

  • Physical protection is obtained from a protected distribution system, for example an optical fiber line, which has sufficient protection to prevent, for example, electromagnetic leakage and controls to prevent its unauthorized use.
  • Logical protection is achieved with strong encryption of communications.
Measures for data transfer of services in accordance with information security goals
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Development and cloud
Cloud service management
2
requirements

Examples of other requirements this task affects

PI1.4: Procedures for availability accodring to objectives
SOC 2
Article 35: Data, system and network security
DORA simplified RMF
See all related requirements and other information from tasks own page.
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Measures for data transfer of services in accordance with information security goals
1. Task description

The organization must implement practices and procedures so that the information coming out of the services is complete and timely. The procedures must take into account:

  • Protection of outgoing information, when stored or transferred, from theft, destruction, modification or other events affecting the integrity of the information
  • Outcoming information is shared only with intended targets< /li>
  • Logging of outgoing data
Use of a DLP-system
Critical
High
Normal
Low
Fully done
Mostly done
Partly done
Not done
Email and phishing
Email and web browser
9
requirements

Examples of other requirements this task affects

18.1.2: Intellectual property rights
ISO 27001
18.1.3: Protection of records
ISO 27001
8.12: Data leakage prevention
ISO 27001
C1.1: Identification and maintainment of confidental information
SOC 2
ID.AM-5: Resources are prioritized based on their classification, criticality, and business value.
CyberFundamentals
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Use of a DLP-system
1. Task description

The DLP system aims to prevent the loss or leakage of sensitive data. The system can be used to prevent unwanted actions by monitoring, detecting and preventing the processing of sensitive data without meeting the desired conditions. Blocking can be done during use (in-use, terminal operations), in motion (in-transit, network traffic) or in storage locations (at-rest).

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