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Mastering DORA ICT third- party risk management
DORA ICT third-party risk management In the evolving landscape of financial regulations, the European Union’s Digital Operational Resilience Act (DORA) stands as a transformative framework. Its implications are far-reaching, especially for financial institutions navigating complex third-party risk environments. DORA mandates a proactive approach to managing ICT third- party relationships, emphasizing the need for robust security, resilience, and compliance. For organizations, this regulation isn’t just a checklist to tick off; it’s a blueprint for enhancing operational resilience in an increasingly interconnected world. With the compliance deadline now passed, the question is: Are you fully prepared? What you’ll learn from this ebook This eBook provides a practical roadmap for achieving DORA compliance, with a focus on ICT third-party risk management. It covers key topics such as? ? vendor due diligence? ? managing third-party risks? ? essential contractual provisions? ? DORA audit process? ? penalties for non-compliance. In addition, we introduce a simplified approach to compliance - VendorGuard. Developed by fintech and DORA experts, this automation tool streamlines vendor monitoring, risk management, and cybersecurity training.
Understanding ICT third-party risk management Third-party risks in Information and Communication Technology (ICT) are an ever-growing concern. With financial institutions relying on vendors and subcontractors for critical services, any failure in these partnerships can lead to severe disruptions. Identify supply chain vulnerabilities Ensure compliance Recognize and address weak points in the ICT supply Adherence to ISO 27001, NIST, and DORA-specific chain. requirements. Enforce contractual security obligations Continuous monitoring Establish clear and enforceable security terms with all Implement proactive risk assessments, penetration vendors. testing, and a robust incident response strategy. The role of automated tools in DORA compliance Audit at the push of a button Employee involvement Comprehensive risk management Keep your teams engaged with regular security tasks and training. Recognize and address weak Continuously evaluate, track, and points in the ICT supply chain. mitigate third-party risks across your ecosystem.
Vendor due diligence checklist The first step in DORA third-party management is performing detailed due diligence. This involves assessing a vendor’s cybersecurity posture, operational resilience, and compliance with industry standards before signing any contracts. Assessment area Key questions to ask vendors Cybersecurity Do you conduct regular penetration tests? How do you protect sensitive data? measures Business continuity What are your disaster recovery protocols? How quickly can you restore services after planning a disruption? Regulatory Are you compliant with EU data protection laws (e.g., GDPR)? Do you align with DORA compliance principles? Key contractual provisions for DORA compliance Once you’re ready to onboard a new vendor, your next DORA concern is contractual safeguards. Your agreements with vendors should clearly define roles, responsibilities, reporting obligations, and penalties for non-compliance. Provision Why it matters Incident reporting Ensures timely notification of breaches or disruptions. Service Level Defines acceptable levels of performance and penalties for failure to meet them. Agreements (SLAs) Audit rights Allows regular audits of vendor compliance and performance.
Managing key risks in third-party relationships When engaging third-party vendors, financial institutions must consider several risk categories. These risks, if not addressed properly, can undermine operational stability, customer trust, and regulatory compliance. Key third-party risks Risk categories Impact Cybersecurity risks Data breaches, ransomware, and other cyber threats can result in sensitive data exposure and significant financial loss. Operational risks Service outages, system downtimes, and disruptions in vendor operations can halt critical banking services, causing wide-reaching operational issues. Compliance risks Failure to ensure that vendors comply with regulations can lead to hefty fines, legal challenges, and reputational damage. Over-reliance on a single vendor creates a single point of failure, putting the entire Concentration risks operation at risk Key metrics to track when evaluating third-parties Metric Explanation Security posture Frequency of vulnerabilities detected and how quickly incidents are addressed. Service reliability Monitoring uptime and adherence to service-level agreements (SLAs). Regulatory alignment Ensuring vendors comply with DORA and related regulations.
The DORA audit process Audits under DORA play a crucial role in ensuring that financial institutions are meeting the regulatory requirements. However, they can be challenging, but understanding the process and preparing the right documentation can make a significant difference. The DORA audit unfolds in several phases, each playing a vital role in assessing your compliance with the regulation. DORA audit phases Audit phase Impact Pre-audit notification Regulators will inform your organization of the audit scope, timelines, and documentation needed. Document Auditors will request documents such as vendor risk assessments, contracts, submission monitoring reports, and incident logs. On-site or remote Auditors will assess your processes and conduct interviews with key staff to evaluate evaluation operational resilience. Regulators provide a report identifying compliance gaps and offering corrective Gap analysis and recommendations. recommendations These audit phases are designed to ensure that your organization’s ICT third-party risk management efforts align with DORA’s requirements. With proactive preparation and clear documentation, you can confidently navigate the audit process and stay compliant. Pre-audit notification Pre-audit notification Pre-audit notification Document submission Document submission Document submission On-site or remote evaluation On-site or remote evaluation On-site or remote evaluation Gap analysis and recommendations Gap analysis and recommendations Gap analysis and recommendations
Essential documentation checklist Document Purpose Update frequency Vendor risk Demonstrates due diligence during Annually or after major changes. assessments onboarding and ongoing evaluations. Contracts and SLAs Provides evidence of regulatory Annually or upon renewal. alignment and vendor accountability. Monitoring reports Tracks vendor performance and risk metrics. Continuously updated. Documents vendor-related disruptions Immediately after each incident. Incident logs and your organization’s response measures. Logs all actions taken to comply with Continuously updated. Audit trails DORA, such as board decisions. Outlines your approach to meeting Reviewed semi-annually. Compliance DORA requirements framework Are you ready for initial DORA audits? Book your first consultation
How VendorGuard meets DORA requirements Requirement Relevant DORA article(s) How VendorGuard helps ICT third-party risk Article 28(2) ? Coordinates with vendors to strategy and complete questionnaire? assessments Financial entities must adopt and regularly review a strategy ? Delivers technical and legal for managing ICT third-party risks as part of their ICT risk analysis for compliance with management framework. recommendation? ? Provides automated quarterly updates to the vendor registry Contractual Articles 28(4), 28(5), 28(6) Provides addendum templates to requirements ensure the inclusion of all DORA- Contracts with ICT third-party service providers must include? mandated clauses. ? Access rights for financial entities, auditors, and competent authorities? ? Obligations for incident reporting and performance updates? ? Provisions ensuring cooperation with authorities. Monitoring and Article 28(1) ? Automates vendor monitorin? oversight ? Generates risk-based task? Financial entities must monitor the performance and risks ? Provides real-time oversight associated with ICT third-party service providers. Exit strategies Article 28(2) Provides exit strategies tailored to critical vendor relationships, ensuring Policies must include termination procedures and exit business continuity. strategies to ensure business continuity if a service is disrupted. Register of information Article 28(3) ? Manages your vendor register, including DORA’s 15 mandatory Maintain a comprehensive register of all contractual template? arrangements with ICT third-party service providers, including? ? Ensures data accuracy with regular updates and annual ? The nature of services provided? reports ? Associated risks and the criticality of functions? ? Details on subcontractors. Trainings Articles 6(1), 11 ? Automates cybersecurity training with 1-on-1 employee engagemen? Financial entities must ensure vendors are trained on ? Tracks progress and provides cybersecurity risks and operational resilience, with proof of complianc? documented evidence for regulators. ? Updates content to align with evolving standards
Understanding DORA penalties The cost of ignoring compliance Non-compliance with DORA can be costly, both financially and administratively. The penalties for failing to meet the regulatory standards are severe. Financial penalties Administrative penalties Criminal penalties Non-compliance with DORA can Repeated or severe violations can Executives may face criminal lead to fines of up to €2 million or lead to license suspension or liability for gross negligence under 2% of annual turnover for mandatory corrective actions DORA, with potential imprisonment cybersecurity failures. Late incident imposed by regulators. These for wilful non-compliance that reporting may result in fines costly measures ensure causes significant financial starting at €250,000, depending organizations address deficiencies disruptions on the risk posed. to maintain market stability.
CyberUpgrade is a platform that helps offload 80% of ICT security and What is compliance tasks. CyberUpgrade? It’s like having a dedicated cybersecurity and compliance team running on autopilot 24/7 and at the cost of a monthly subscription. Audit at a push of a button. Extract information, evaluate risk & present results. We have you covered. Our platform stores, evaluates, and compares evidence against requirements, identifies vulnerabilities, groups them by severity, and generates reports. Push security tasks and training to each individual employee. Capture compliance status and factual evidence over and over again. CyberUpgrade ensures every team member's active involvement, crucial for accurately capturing operational compliance and evidence.
VendorGuard Key features & benefits Contract updates Vendor inventory Risk assessment & reporting Ensure that all third-party Build and maintain a contracts include the critical comprehensive vendor inventory. Collect vendor compliance data, provisions required by DORA. assess risks, and generate detailed reports with recommendations. Resolution plans Ongoing reporting & compliance monitoring Exit & continuity planning Develop and enforce tailored resolution plans and monitor Provide regular security state Create exit strategies for critical progress. reports and track vendor vendors, ensuring smooth compliance to ensure continued transitions if necessary. adherence to DORA.
VendorGuard goes beyond a typical compliance tool. We provide a proactive, Why choose strategic solution to streamline vendor risk management, reduce operational risk, and enhance efficiency. Our expertise in DORA ensures that your vendor VendorGuard? ecosystem remains resilient and compliant. Key benefits of working with us Efficiency Reduced risk Free up internal resources to focus on strategic A proactive, tailored approach that ensures full DORA initiatives while we handle vendor management. compliance and mitigates vendor-related risks. Cost savings Peace of mind Optimize vendor performance and negotiate better Trust us to manage vendor relationships professionally, terms to drive long-term savings. ethically, and in full compliance with DORA. “Working with CyberUpgrade on preparation to DORA regulation has been a game-changer for our project. Their agility and speed in adapting to our needs, combined with impeccable attention to detail, have moved us a very long way in quite short time.” Roman Loban
CyberUpgrade key pillars Advisory Team Copilot CoreGuardian ? Consulting & Guidanc? ? Engages every employee and ? Evidence databas? ? Practical CyberSe? initiates assessment? ? Report automatio? ? Fast ICT Compliance ? Includes 1000+ pre-defined ? 24/7 monitoring workflows for streamlined compliance Solutions Black Box Pen Tests Black Box Pen Tests Black Box Pen Tests Data Leak Scan Data Leak Scan Data Leak Scan Static Code Analysis Static Code Analysis Static Code Analysis Phishing Simulator Phishing Simulator Phishing Simulator Vulnerability Scan Vulnerability Scan Vulnerability Scan Cloud Misconfiguration Scan Cloud Misconfiguration Scan Cloud Misconfiguration Scan And more And more And more Generate and easily access compliance documentation. Audits shouldn't be a huge project or burden for your team.
With third-party risk management – you will VendorGuard , you get more than just have a trusted partner dedicated to strengthening your company’s operational resilience. At CyberUpgrade, we bring deep expertise in DORA and third-party risk management, simplifying complexities with tailored guidance and real-time support. We help you maintain a resilient, compliant vendor ecosystem. Ready for DORA compliance? Take control of your vendor risk management today and ensure resilience for tomorrow. Contact us for a tailored quote. More info available on www.cyberupgrade.net Book a Demo