Protection and prevention


TL;DR This article from the EU Digital Operations Resilience Act sets out various measures financial entities must use in order to adequately protect their ICT systems. These measures include developing and documenting an information security policy, establishing a network and infrastructure management system, implementing access policies and strong authentication mechanisms, and implementing policies for patches and updates. Furthermore, financial entities must design their network connection infrastructure so that it can be quickly severed to reduce contagion. All changes to ICT systems must be approved by appropriate lines of management. This article ensures financial entities meet the necessary standards of ICT risk management.
  1. For the purposes of adequately protecting ICT systems and with a view to organising response measures, financial entitiesas defined in Article 2, points (a) to (t) shall continuously monitor and control the security and functioning of ICT systems and tools and shall minimise the impact of ICT riskany reasonably identifiable circumstance in relation to the use of network and information systems which, if materialised, may compromise the security of the network and information systems, of any technology dependent tool or process, of operations and processes, or of the provision of services by producing adverse effects in the digital or physical environment on ICT systems through the deployment of appropriate ICT security tools, policies and procedures.

  2. Financial entitiesas defined in Article 2, points (a) to (t) shall design, procure and implement ICT security policies, procedures, protocols and tools that aim to ensure the resilience, continuity and availability of ICT systems, in particular for those supporting critical or important functionsa function the disruption of which would materially impair the financial performance of a financial entity, or the soundness or continuity of its services and activities, or the discontinued, defective or failed performance of that function would materially impair the continuing compliance of a financial entity with the conditions and obligations of its authorisation, or with its other obligations under applicable financial services law, and to maintain high standards of availability, authenticity, integrity and confidentiality of data, whether at rest, in use or in transit.

  3. In order to achieve the objectives referred to in paragraph 2, financial entitiesas defined in Article 2, points (a) to (t) shall use ICT solutions and processes that are appropriate in accordance with Article 4. Those ICT solutions and processes shall:

    1. ensure the security of the means of transfer of data;

    2. minimise the risk of corruption or loss of data, unauthorised access and technical flaws that may hinder business activity;

    3. prevent the lack of availability, the impairment of the authenticity and integrity, the breaches of confidentiality and the loss of data;

    4. ensure that data is protected from risks arising from data management, including poor administration, processing-related risks and human error.

  4. As part of the ICT riskany reasonably identifiable circumstance in relation to the use of network and information systems which, if materialised, may compromise the security of the network and information systems, of any technology dependent tool or process, of operations and processes, or of the provision of services by producing adverse effects in the digital or physical environment management framework referred to in Article 6(1), financial entitiesas defined in Article 2, points (a) to (t) shall:

    1. develop and document an information security policy defining rules to protect the availability, authenticity, integrity and confidentiality of data, information assetsa collection of information, either tangible or intangible, that is worth protecting and ICT assetsa software or hardware asset in the network and information systems used by the financial entity, including those of their customers, where applicable;

    2. following a risk-based approach, establish a sound network and infrastructure management structure using appropriate techniques, methods and protocols that may include implementing automated mechanisms to isolate affected information assetsa collection of information, either tangible or intangible, that is worth protecting in the event of cyber-attacksa malicious ICT-related incident caused by means of an attempt perpetrated by any threat actor to destroy, expose, alter, disable, steal or gain unauthorised access to, or make unauthorised use of, an asset;

    3. implement policies that limit the physical or logical access to information assetsa collection of information, either tangible or intangible, that is worth protecting and ICT assetsa software or hardware asset in the network and information systems used by the financial entity to what is required for legitimate and approved functions and activities only, and establish to that end a set of policies, procedures and controls that address access rights and ensure a sound administration thereof;

    4. implement policies and protocols for strong authentication mechanisms, based on relevant standards and dedicated control systems, and protection measures of cryptographic keys whereby data is encrypted based on results of approved data classification and ICT riskany reasonably identifiable circumstance in relation to the use of network and information systems which, if materialised, may compromise the security of the network and information systems, of any technology dependent tool or process, of operations and processes, or of the provision of services by producing adverse effects in the digital or physical environment assessment processes;

    5. implement documented policies, procedures and controls for ICT change management, including changes to software, hardware, firmware components, systems or security parameters, that are based on a risk assessment approach and are an integral part of the financial entity’s overall change management process, in order to ensure that all changes to ICT systems are recorded, tested, assessed, approved, implemented and verified in a controlled manner;

    6. have appropriate and comprehensive documented policies for patches and updates.

    For the purposes of the first subparagraph, point (b), financial entitiesas defined in Article 2, points (a) to (t) shall design the network connection infrastructure in a way that allows it to be instantaneously severed or segmented in order to minimise and prevent contagion, especially for interconnected financial processes.

    For the purposes of the first subparagraph, point (e), the ICT change management process shall be approved by appropriate lines of management and shall have specific protocols in place.