Cyber Security Policy: Prakasam District Cooperative Central Bank Limited
Cyber Security Policy: Prakasam District Cooperative Central Bank Limited
Limited
1 DEFINITION
The use of the term “Bank” is in reverence to the Prakasam District Cooperative Central Bank
Ltd.
2 Introduction
a. Use of Information Technology by Prakasam District Cooperative Central Bank Ltd and
their constituents has grown rapidly and is now an integral part of the operational
strategies of banks. As per the Reserve Bank guide lines on Information Security,
Electronic Banking, Technology Risk Management and Cyber Frauds (G.Gopalakrishna
Committee), wherein it was indicated that the measures suggested for implementation
cannot be static and our Bank need to pro-actively create/fine-tune/modify their
policies, procedures and technologies based on new developments and emerging
concerns.
b. Since then, the use of technology by DCCB has gained further momentum. On the other
hand, the number, frequency and impact of cyber incidents / attacks have increased
manifold in the recent past, more so in the case of financial sector including banks,
underlining the urgent need to put in place a robust cyber security/resilience framework
at banks and to ensure adequate cyber-security preparedness among banks on a
continuous basis. In view of the low barriers to entry, evolving nature, growing
scale/velocity, motivation and resourcefulness of cyber-threats to the banking system, it
is essential to enhance the resilience of the banking system by improving the current
defenses in addressing cyber risks. These would include, but not limited to, putting in
place an adaptive Incident Response, Management and Recovery framework to deal
with adverse incidents/disruptions, if and when they occur.
c. The Cyber Security Policy serves several purposes. The main purpose is to inform Bank
users: employees, contractors and other authorized users of their obligatory
requirements for protecting the technology and information assets of the Bank. The
Cyber Security Policy describes the technology and information assets that we must
protect and identifies many of the threats to those assets.
d. The Cyber Security Policy also describes the user’s responsibilities and privileges. What
is considered acceptable use? What are the rules regarding Internet access? The policy
answers these questions, describes user limitations and informs users there will be
penalties for violation of the policy. This document also contains procedures for
responding to incidents that threaten the security of the Bank computer systems and
network.
in the banking industry business landscape has experienced dramatic changes in the past
decade and the pace of change shows no signs of abatement. Intense competition has
necessitated new economics, new organizations and new market dynamics. Banks are targeting
like different channels like internet banking and ATM’s, increased customer base using
technology as an enabler, everywhere banking and a renewed and invigorated emphasis on
customer.
These forces have driven banks to constantly improve business processes and to make them
effective and efficient. It has also created an intense demand for processing large amount of
information within banks to assist faster information availability and better decision making in
response to the changing business environment. The ability of technology to meet these needs
has transformed information technology from a support function to an integral part of core
processes spanning across all business functions and processes.
The contemporary banking processes involve 24/7 uptime, real time data update, ATM’s
network, internet banking, anytime-anywhere banking, credit and debit cards, payment
gateway for ecommerce, etc. further, IT is also used for efficient processing of internal activities
and back office operations.
Moreover, IT is using big way of keeping data/ information of internal resources such as man
power resources. This information is also be safeguarded.
3.4 Dependency on IT
In view of such extensive usage of IT, the dependency of the bank on IT will be fairly high. The
entire business process cycle will be enabled through the use of IT. Moreover, IT will be central
to all transaction processing. This dependency on IT is only expected to increase with time as
newer technology comes into being and keeps on creating better prospects for banking
business.
3.5 Vulnerability
The use of IT has resulted in the need for a completely different set of controls and processes to
maintain and monitor security controls. The gap between the traditional security and controls
and demand put forth by newer technologies has resulted in business, public service and
individuals relying on newer technologies that are not yet sufficient secure.
Any IT usage or implementation is vulnerable to external or internal attack, which may result in
failure of underlying information systems. There is risk of data loss due to mollified or
accidental unauthorized access, use, misappropriation, modification or destruction of
information, information system and IT. While the number of users accessing information,
systems is increasing the control exercised by system owners or provider is being dissipated.
Increased technology usage and inherent security and controls weaknesses has led the bank to
draft a guiding cyber security policy to ensure that that it’s information assets are secured and
controlled.
4 STATEMENT OF INTENT
The bank’s endeavor has been making optimum use of technology in carrying out our business,
not sidelining under any circumstances, the important and pivotal aspect of information and
data security.
The Bank is committed to ensuring that business conducts its activities in such a way that it
makes right use of IT and at the same time its information assets are optimally secured.
Implementation of latest technology will change the way we do our business from branch focus
to a bank focus. In wake such changes to our business, certain risks are foreseen in the area of
security of bank information security assets.
Embracing new technology exposes the bank to the risk of possible unauthorized access to
bank’s data. Also, there could be over dependency on IT leading to breakdowns in business due
to unavailability of technology support.
Despite highest level of IT usage in business, the bank’s users and customers must have
confidence that information systems will operate as intended and without unanticipated
failures or problems. Though all these cannot be guaranteed, the bank will like to minimize such
exposure. This will ensure that technology is optimally utilized and IT enhances future growth.
The bank wants to put in place information security and control environment to minimize the
risk of security incidents involving IT usage.
5 SCOPE
Information technology Cyber security policy covers all information used/ generated by the
bank, which is stored, processed, transmitted or printed by a computer system or network and
communication lines, and on any storage, medium including printed output. It applies to all the
Bank employees and all others who directly or indirectly use or support the bank’s computing
services or information.
The scope of the cyber security policy can be enhanced to cover any other organization, which
may be created to fulfill our legal or operational requirements.
An indicative but not exhaustive list of requirements to be put in place by banks to achieve
baseline cyber-security/resilience is given. This may be evaluated periodically to integrate risks
that arise due to newer threats, products or processes. Important security controls for effective
cyber security as may be articulated by CERT-In also may be referred. Some of the key points to
be kept in mind are:
a. In view of the growing technology adoption and potential threats, the role of IT
Sub-committee may be reviewed; Board level involvement and guidance would set the
right tone at the top.
c. Cyber Security Operations Centre should have the capacity to monitor various logs /
incidents in real time / near real time.
d. It is important to keep the vigil and to constantly remain alert.
e. While hardware devices and software applications may provide security, it is important
to configure them appropriately.
f. Human resources are the key and ensure that they are provided with appropriate
training. Communicate the security policy of the bank periodically.
Baseline Controls
3. Environmental Controls
3.1. Bank has appropriate environmental controls for securing location of critical assets
providing protection from natural and man-made threats.
3.2. Bank has pre-defined mechanisms for monitoring of breaches / compromises of
environmental controls relating to temperature, water, smoke, access alarms,
service availability alerts (power supply, telecommunication, servers), access logs,
etc. Appropriate physical security measures are taken to protect the critical assets
of the bank.
4. Network Management and Security
4.1. Bank has an up-to-date network architecture diagram at the organization level
including wired/wireless networks;
4.2. Bank has up-to-date/centralized inventory of authorized devices connected to
bank’s network (within/outside bank’s premises) and authorized devices enabling
the bank’s network. The bank has central monitoring system to monitor the devices
connected to banks network including branches.
4.3. All the network devices are configured appropriately and periodically assess
whether the configurations are appropriate to the desired level of network security;
4.4. Bank has appropriate controls to secure wireless local area networks, wireless
access points, wireless client access systems.
4.5. Has mechanism to identify authorized hardware / mobile devices like Laptops,
mobile phones, tablets, etc. and ensure that they are provided connectivity only
when they meet the security requirements prescribed by the bank.
4.6. Has strong mechanism to automatically identify unauthorized device connections to
the bank’s network and block such connections.
4.7. Has strong mechanism to detect and remedy any unusual activities in systems,
servers, network devices and endpoints.
4.8. Established Standard Operating Procedures (SOP) for all major IT activities including
for connecting devices to the network.
4.9. Security Operation Centre to monitor the logs of various network activities and
should have the capability to escalate any abnormal / undesirable activities.
4.10. Boundary defenses of the bank is multi-layered with properly configured firewalls,
proxies, DMZ perimeter networks, and network--‐based IPS and IDS. Mechanism to
filter both inbound and outbound traffic is in place.
5. Secure Configuration
7.2. appropriate systems and processes are in place to identify, track, manage and
monitor the status of patches to operating system and application software running
at end-user devices directly connected to the internet and in respect of Server
operating Systems/Databases/Applications/ Middleware, etc.
7.3. Changes to business applications, supporting technology, service components and
facilities are managing using robust configuration management processes,
configuration baseline that ensures integrity of any changes thereto.
7.4. Periodically conduct VA/PT of internet facing web/mobile applications, servers &
network components throughout their lifecycle (pre-implementation, post
implementation, after changes etc.)
7.5. Periodically conduct Application security testing of web/mobile applications
throughout their lifecycle (pre-implementation, post implementation, after
changes) in environment closely resembling or replica of production environment.
7.6. As a threat mitigation strategy, identification of the root cause of incident and apply
necessary patches to plug the vulnerabilities.
7.7. Periodically evaluate the access device configurations and patch levels to ensure
that all access points, nodes between (i) different VLANs in the Data Centre (ii)
LAN/WAN interfaces (iii) bank’s network to external network and interconnections
with partner, vendor and service provider networks are securely configured.
8. User Access Control / Management
8.1. Bank provides secure VPN access to the bank’s assets/services from within/outside
bank’s network by protecting data/information at rest and in-transit.
8.2. Bank Sensibly protect customer access credentials such as logon user ID,
authentication information and tokens, access profiles, etc. against leakage/attacks
8.3. Disallow administrative rights on end-user workstations/PCs/laptops and provide
access rights on a need to know basis and for specific duration when it is required
following an established process.
8.4. Implemented centralized authentication and authorization system like active
directory authentication for accessing and administering applications, operating
systems, databases, network and security devices/systems, point of connectivity
(local/remote, etc.) including enforcement of strong password policy, also exploring
two-factor/multi-factor authentication depending on risk assessment and following
the principle of least privileges and separation of duties.
8.5. Implemented centralized systems and controls to allow, manage, log and monitor
privileged/super user/administrative access to critical systems (Servers/OS/DB,
applications, network devices etc.).
8.6. Implemented policy level controls to minimize invalid logon counts, deactivate
dormant accounts.
8.7. Monitor any abnormal change in pattern of logon.
8.8. Implemented measures to control installation of software on PCs/laptops, etc.
8.9. Implemented appropriate controls for remote management/wiping/locking of
mobile devices including laptops, etc.
12.2. Limited media types and information that could be transferred/copied to/from such
devices.
12.3. Get the removable media scanned for malware/anti-virus prior to providing
read/write access.
12.4. Considered and implemented centralized policies through Active Directory and
Endpoint management systems to white list/blacklist/restrict removable media
use.
12.5. As default rule, use of removable devices and media should not be permitted in the
banking environment unless specifically authorized for defined use and duration of
use.
14. Anti-Phishing
14.1. Subscribed at firewall level for Anti-phishing/anti-rouge app services from external
service providers for identifying and taking down phishing websites/rouge
applications.
18. Vulnerability assessment and Penetration Test and Red Team Exercises
18.1. Periodically conduct vulnerability assessment and penetration testing exercises for
all the critical systems, particularly those facing the internet.
18.2. The vulnerabilities detected are to be remedied promptly in terms of the bank’s risk
management/treatment framework so as to avoid exploitation of such
vulnerabilities.
18.3. Penetration testing of public facing systems as well as other critical applications are
to be carried out by professionally qualified teams.
18.4. Findings of VA/PT and the follow up actions necessitated are to be monitored
closely by the Information Security and Information Technology Audit team as well
as top Management.
18.5. Information Security teams may be used to identify the vulnerabilities and the
business risk, assess the efficacy of the defenses and check the mitigating controls
already in place by simulating the objectives and actions of an attacker.
21. Metrics
21.1. Developed a comprehensive set of metrics that provide for prospective and
retrospective measures, like key performance indicators and key risk indicators.
21.2. Few illustrative metrics included coverage of anti-malware software and their
updating percentage, patch latency, extent of user awareness training, vulnerability
related metrics, etc.
22. Forensics
22.1. Have support/ arrangement for network DDOS mitigation services on stand-by.
23.3. Conduct targeted awareness/training for key personnel (at executive, operations,
security related administration/operation and management roles, etc.). DCCB made it
part of the induction and on going training sessions to all employees.
23.4. Evaluate the awareness level periodically.
23.5. Established a mechanism for adaptive capacity building for effective Cyber security
Management. Making cyber security awareness programs mandatory for new
recruits as part of induction.
23.6. Board members are sensitized on various technological developments and cyber
security related developments periodically which is monthly basis.
23.7. Board members are provided with awareness programmes on IT Risk / Cyber security
Risk and evolving best practices in this regard so as to cover all the Board members at
least once a year.
Introduction
1. Prakasam District Cooperative Central Bank Ltdhas evolved technologically over the
years and currently delivering innovative services to its customers. These services are
delivered nonstop, round the clock and the customers access these services using
Internet and Mobile Connectivity. Security of the financial transactions is of paramount
importance and therefore the RBI has come out with guidelines from time to time
addressing the security and operational aspects for specific applications and services.
2. It is important and pertinent to look at specifically the Internet facing applications and
services that are currently delivered and proposed to be delivered in the immediate
future in the Banking Industry and come out with Cyber Security guidelines across the
applications and services.
3. Constant and Continuous monitoring of the environment using appropriate and cost-
effective technology tools, clearly defined policies and procedures based on best
practices and monitored by technically competent and capable manpower is the urgent
need for the Industry. Compliance to the Government guidelines that are put out
periodically covering the cyber security policy, protecting critical information
infrastructure and the Information Technology Act are of paramount importance. It is
important to address the governance, technology, operational, outsourcing and legal
issues while setting up the Cyber Security Operations Centre.
4. Issues that need to be kept in mind while setting up the CSOC is given below. These are
indicative but not exhaustive.
Governance Aspects:
Top Management/Board Briefing on Threat Intelligence
Dashboards and oversight
Policy, measurement and enforcement (key metrics, reporting structure, define what is
to be reported)
Informing stakeholders, stakeholder participation
Recommendation
Considering the sensitivity and significant importance of the cyber security operations center, it
is to decide that either DCCB has to be established C-SOC to monitor all security event and
report to respected stake holders on security incidents or we have to engage with professional
C-SOC service provider after detailed evaluation of the requirements of the Bank