Risk Monitoring and Reporting
Regulated entities should:
- Document and implement monitoring/surveillance and detection policies, techniques and systems (e.g., firewalls, anti–virus, Security Information and Event Management (“SIEM”), etc.);
- Ensure that cybersecurity metrics are developed and monitored;
- Perform ongoing reporting to the governing body (Board Members) of significant risks, status of containment and recovery actions and plans; and
- Ensure periodic reviews and updates of cybersecurity risk management processes are carried out.
Incident Response
Regulated entities should:
- Document policies and procedures for responding to cybersecurity incidents (e.g., Cyber Incident Response Playbooks for data breaches, phishing attacks, malware attacks, Denial of Service (“DoS”), etc.);
- Maintain an appropriate log or enable audit trails;
- Establish a post–incident response review process for material cybersecurity incidents; and
- Document, implement and communicate to staff an escalation process for reporting IT and cybersecurity issues/incidents.
Containment and Recovery
Regulated entities should:
- Establish containment and recovery policies and procedures (e.g., Backup and Test Restore, Disaster Recovery Plan, etc.); and
- Ensure that the containment and recovery plan enables the resumption of operations responsibly.