Article 15 Digital Operational Resilience Act (DORA), ICT-Related Incident Management Process

Article 15 of the Digital Operational Resilience Act (DORA) outlines comprehensive requirements for the management of ICT-related incidents by financial entities. This article establishes the framework for detecting, managing, and notifying incidents, with a focus on ensuring an effective response and long-term resilience. The provisions detailed in Article 15 emphasize the importance of early detection, systematic handling, and thorough follow-up to prevent recurrence and mitigate impacts.

Establishing an ICT-Related Incident Management Process

Financial entities are required to establish and implement a robust ICT-related incident management process. This process is crucial for the early detection, management, and notification of ICT-related incidents. To enhance their readiness, entities must implement early warning indicators to serve as alerts for potential incidents. These indicators help in promptly identifying issues before they escalate, thereby allowing for a more effective response.

The incident management process should be designed to detect and address incidents in a structured manner. This includes setting up mechanisms to monitor ICT systems continuously, which helps in identifying anomalies or disruptions early. The goal is to ensure that incidents are managed efficiently and that the organization can respond swiftly to minimize any adverse effects on its operations and services.

Integrated Monitoring and Handling Processes

To ensure consistency and integration in managing ICT-related incidents, financial entities must establish appropriate processes. These processes should cover all aspects of incident handling, from monitoring and detection to resolution and follow-up. An integrated approach ensures that incidents are managed in a unified manner, which is critical for identifying root causes and implementing effective corrective actions.

Entities must focus on understanding the underlying causes of incidents and taking steps to address them to prevent recurrence. This involves analyzing the incidents thoroughly, implementing solutions to fix the root causes, and refining procedures to avoid similar issues in the future. Effective monitoring and follow-up are key components in maintaining operational resilience and reducing the likelihood of future incidents.

Detailed Requirements For Incident Management Process

Article 15 specifies several key components that the ICT-related incident management process must include:

(a) Procedures for Incident Identification and Classification

The process must establish clear procedures for identifying, tracking, logging, categorizing, and classifying ICT-related incidents. Incidents should be categorized based on their priority, severity, and the criticality of the affected services. This classification helps in prioritizing response efforts and allocating resources effectively. Entities should adhere to the criteria outlined in Article 16(1) for consistent and effective incident classification.

(b) Role Assignment and Responsibility

It is essential to assign specific roles and responsibilities for managing different types of ICT-related incidents. The incident management process should define the roles of individuals and teams involved in handling various incident scenarios. This includes designating personnel for different tasks, such as incident response, communication, and technical resolution, to ensure that the process is well-coordinated and efficient.

(c) Communication and Notification Plans

The process must outline comprehensive plans for communication with staff, external stakeholders, and the media. These plans should align with the requirements specified in Article 13, which covers the responsible disclosure and communication of ICT-related incidents. Additionally, the process should include procedures for notifying clients, internal escalation mechanisms, handling ICT-related customer complaints, and providing information to financial entities acting as counterparts when appropriate.

(d) Reporting to Senior Management

Major ICT-related incidents must be reported to relevant senior management. The incident management process should ensure that senior management is informed about significant incidents, including their impact, the response actions taken, and any additional controls implemented. This communication is crucial for keeping the management body updated and involved in strategic decision-making related to incident response and prevention.

(e) Response Procedures

Finally, the process must establish procedures for responding to ICT-related incidents. These response procedures should focus on mitigating the impact of incidents, restoring services to operational status, and ensuring security. Timely and effective response is essential for minimizing disruptions and safeguarding the integrity of ICT systems and services.

In summary, Article 15 of DORA sets forth detailed requirements for the management of ICT-related incidents. By implementing a comprehensive incident management process, financial entities can enhance their operational resilience, ensure effective response to incidents, and prevent future occurrences. The structured approach outlined in Article 15 helps entities manage ICT risks more effectively, ensuring continuity and security in their operations.