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Certificate Examination in
IT SECURITY
( IIBF & Other Exams)
Compiled by
OBJECTIVE
The objective of the course is to make the bank employees aware of the IT security requirements and proper
implementation thereof for protecting organizational interest. This course has been developed on the basis of
discussions that a committee of IBA had on IT security based on Goplakrishnan Committee Report.
DIPLOMA IN INFORMATION SYSTEM AUDIT (DISA)
Candidates who clear all the following three Certificate examinations under the revised syllabus will be
given a "DIPLOMA IN INFORMATION SYSTEM AUDIT (DISA)" from May 2017 :
a) Certificate Examination in IT Security (Revised Syllabus)
b) Certificate Examination in Prevention of Cyber Crimes and Fraud Management (Revised Syllabus)
Candidates who clear all the above three Certificates under revised syllabus will however have to apply for
DISA certificate by paying Rs.500/- plus taxes as applicable.
For candidates who have already cleared any or all the above three examinations under the old syllabus, i.e.
prior to May 2017 need to apply and clear the examination under revised syllabus to become eligible for DISA
Certificate.
ELIGIBILITY
i) Employees of a Bank or Financial Institutions.
SUBJECT OF EXAMINATION
IT Security
PASSING CRITERIA:
Minimum marks for pass in the subject is 50 out of 100.
EXAMINATION For Members For Non-Members
FEES* :
Particulars
First attempt Rs.1,000/- * Rs.1,500/- *
Subsequent each Rs.1,000/- * Rs.1,500/- *
attempt
MEDIUM OF EXAMINATION :
Examination will be conducted in English only.
PATTERN OF EXAMINATION:
(i) Question Paper will contain 120 objective type multiple choice questions for 100 marks.
DURATION OF EXAMINATION:
The duration of the examination will be of 2 hours.
b) List of Examination centers will be available on the website. (Institute will conduct examination in those
centers where there are 20 or more candidates.)
Application for examination should be registered online from the Institute’s website www.iibf.org.in. The
schedule of examination and dates for registration will be published on IIBF website.
PROOF OF IDENTITY
Non-members applying for Institute’s examinations / courses are required to attach / submit a copy of any one of
the following documents containing Name, Photo and Signature at the time of registration of Examination
Application. Application without the same shall be liable to be rejected.
1) Photo I / Card issued by Employer or 2) PAN Card or 3) Driving Licencse or
going through other books & publications covering the subject / exam concerned etc. Questions based on current
developments relating to the subject / exam may also be asked.
Cut-off Date of Guidelines / Important Developments for Examinations
The Institute has a practice of asking questions in each exam about the recent developments / guidelines issued
by the regulator(s) in order to test if the candidates keep themselves abreast of the current developments.
However, there could be changes in the developments / guidelines from the date the question papers are
prepared and the dates of the actual examinations.
In order to address these issues effectively, it has been decided that:
(i) In respect of the examinations to be conducted by the Institute for the period February to July of a calendar
year, instructions / guidelines issued by the regulator(s) and important developments in banking and finance up
to 31st December will only be considered for the purpose of inclusion in the question papers".
(ii) In respect of the examinations to be conducted by the Institute for the period August to January of a calendar
year, instructions / guidelines issued by the regulator(s) and important developments in banking and finance up
to 30th June will only be considered for the purpose of inclusion in the question papers.
f. Monitoring
7. Operational Security
8. Security Standards
• Databases
• Logical
• Cryptography
• In-house development
• Outsourcing
• Network related
• Internet / Application
• Social Engineering
• Overview
• Policy
20. IS Audit
a. Framework
b. Policies
c. Charter
d. Planning
e. Methodology
a. Overview
c. Review of Compliances
INDEX
Information security is a set of strategies for managing the processes, tools and policies
necessary to prevent, detect, document and counter threats to digital and non-digital
information. Information security responsibilities include establishing a set of business
processes that will protect information assets regardless of how the information is formatted
or whether it is in transit, is being processed or is at rest in storage.
Information security programs are built around the core objectives of the CIA triad:
maintaining the confidentiality, integrity and availability of IT systems and business data.
These objectives ensure that sensitive information is only disclosed to authorized parties
(confidentiality), prevent unauthorized modification of data (integrity) and guarantee the data
can be accessed by authorized parties when requested (availability).
Many large enterprises employ a dedicated security group to implement and maintain the
organization's information security program. Typically, this group is led by a chief
information security officer. The security group is generally responsible for conducting risk
management, a process through which vulnerabilities and threats to information assets are
continuously assessed, and the appropriate protective controls are decided on and applied.
The value of an organization lies within its information -- its security is critical for business
operations, as well as retaining credibility and earning the trust of clients.
Threats to sensitive and private information come in many different forms, such
as malwareand phishing attacks, identity theft and ransomware. To deter attackers and
mitigate vulnerabilities at various points, multiple security controls are implemented and
coordinated as part of a layered defense in depth strategy. This should minimize the impact of
an attack. To be prepared for a security breach, security groups should have an incident
response plan (IRP) in place. This should allow them to contain and limit the damage, remove
the cause and apply updated defense controls.
Information Assurance (IA) refers to the steps involved in protecting information systems,
like computer systems and networks. There are commonly five terms associated with the
definition of information assurance:
Integrity
Availability
Authentication
Confidentiality
Nonrepudiation
Confidentiality is one of the five pillars of Information Assurance (IA). The other four are
authentication, availability, integrity and nonrepudiation.
An authentication process, which ensures that authorized users are assigned confidential
user identification and passwords. Another type of authentication is biometrics.
Role-based security methods may be employed to ensure user or viewer authorization.
For example, data access levels may be assigned to specified department staff.
Access controls ensure that user actions remain within their roles. For example, if a
user is authorized to read but not write data, defined system controls may be integrated.
1. Integrity, in the context of computer systems, refers to methods of ensuring that data is
real, accurate and safeguarded from unauthorized user modification. Integrity is one of the
five pillars of Information Assurance (IA). The other four are authentication, availability,
confidentiality and nonrepudiation.
Events like storage erosion, error and intentional data or system damage can create data
changes. For example, hackers may cause damage by infiltrating systems with malware,
including Trojan horses, which overtake computer systems, as well as worms and viruses. An
employee may create company damage through intentionally false data entry.
Data integrity verification measures include checksums and the use of data comparison
3.Availability, in the context of a computer system, refers to the ability of a user to access
information or resources in a specified location and in the correct format. Availability is one
of the five pillars of Information Assurance (IA). The other four are integrity, authentication,
confidentiality and nonrepudiation.
Nonrepudiation is often used for digital contracts, signatures and email messages.
By using a data hash, proof of authentic identifying data and data origination can be
obtained. Along with digital signatures, public keys can be a problem when it comes
to nonrepudiation if the message recipient has exposed, either knowingly or
unknowingly, their encrypted or secret key..
5. In the context of computer systems, authentication is a process that ensures and confirms a
user’s identity. Authentication is one of the five pillars of information assurance (IA). The
other four are integrity, availability, confidentiality and nonrepudiation.
Authentication begins when a user tries to access information. First, the user must prove his
access rights and identity. When logging into a computer, users commonly enter usernames
and passwords for authentication purposes. This login combination, which must be assigned
to each user, authenticates access. However, this type of authentication can be circumvented
by hackers.
A better form of authentication, biometrics, depends on the user’s presence and biological
makeup (i.e., retina or fingerprints). This technology makes it more difficult for hackers to
break into computer systems.
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
The Public Key Infrastructure (PKI) authentication method uses digital certificates to prove a
user’s identity. There are other authentication tools, too, such as key cards and USB tokens.
One of the greatest authentication threats occurs with email, where authenticity is often
difficult to verify. For example, unsecured emails often appear legitimate.
Physical Security
Physical security describes measures designed to ensure the physical protection of IT assets
like facilities, equipment, personnel, resources and other properties from damage and
unauthorized physical access. Physical security measures are taken in order to protect these
assets from physical threats including theft, vandalism, fire and natural disasters
Physical security is often the first concern in facilities with high asset concentration,
especially that used in critical systems for business processes. Physical security is especially
important for IT resources, as their proper operation demands that the hardware assets and
infrastructure they are running on be kept away from anything that could hinder their function.
This includes tampering by unauthorized personnel and unforeseen events like accidents and
natural disasters.
Deterrence: Methods and measures that are meant to deter attackers and intruders or
prevent natural events and accidents from affecting protected assets. The simple method for
this is through the use of physical barriers and signs. The signs serve as a warning to any
intruder that their actions will bring physical harm or prosecution. The physical barriers are
meant to prevent access entirely or simply to provide protection from external factors like
storms or vehicular accidents.
Detection: Allows security personnel to detect and locate potential intruders using
surveillance equipment like cameras, motion sensors, security lights and personnel like
security guards and watch dog
Physical security pertains to preventative measures used to halt intruders from physically
accessing the location. Denoting physical or electronic equipment that protects tangible
aspects of the site, physical security is effective in stopping unwanted trespassers or
unauthorized visitors. Physical security solutions like visitor management protect
unauthorized visitors. You can never be too safe in ensuring that those who enter are granted
the proper permissions to do so. Unauthorized visitors could be looking to extract company
data, do harm to employees, or even steal equipment such as computers and monitors.
Physical security allows for established barriers wherever needed to ensure only those with
clearance can enter. Additional physical security measures include:
Logical Security
On the internet alone there are an estimated 1.2 million terabytes of data. With so much
information available to anyone with internet access, our expansion digitally has caused the
world to shrink due to our interconnectedness. The resulting small world, however, doesn’t
denote that everything needs sharing. Logical Security refers to the safeguards in place to
protect access to the data storage system itself. It is used once inside the work site and makes
it difficult for those without certain permissions to gain access to systems in which they do
not belong. If someone were to make it past the physical security, logical security ensures that
they cannot get into computer systems without credentials to keep your network safe from
intrusion.
Examples of effective logical security solutions include:
User Profiles – Providing authorized individuals with accounts access to the system
makes it easier to keep track of individuals accessing what and when. Shared networks
monitor who modifies documents and records users logging in for reference later if fraud is
suspected.
Passwords – While employees have access to the premises, you still want to ensure
security within your system. Passwords are the ideal way to prevent unwanted parties from
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
getting in. Strong passwords prevent hackers from entering and disturbing the integrity of
your data.
Biometrics – Including retina scans, fingerprint analysis, and vocal recognition,
biometrics uses physiology as a means of identification.
Significant technological advances have changed the way we do business. That is, the internet,
email, and text messages have virtually replaced faxes, letters and telexes in the corporate
world. The internet to used to obtain information and efficiently communicate with clients,
business associates, and partners.
While internet usage comes with numerous advantages such as the speed of communication
and an increase in the bottom line, it also contains several drawbacks that can seriously
hinder business productivity and growth. For example, personnel can use the internet as a
distraction to peruse their Facebook, Twitter, and Instagram accounts, shop on Amazon or
eBay, check the latest sports statistics, exchange personal emails with colleagues, friends, and
so on. These activities not only heighten the risk of incoming malware, but also lower
employee productivity and revenue.
Therefore, devising a corporate IT security policy will help to mitigate the negative
consequences associated with internet use – and email specifically.
An IT security policy is essentially a written strategy (plan) that covers the implementation of
Information Security methods, technologies, and concepts. This policy offers overarching
guidelines for company security procedures without precisely stating how the data will be
protected. Some freedom is provided for IT managers to decide which electronic devices,
software, and methods would be best to implement policy guidelines. An IT security policy
shouldn’t explicitly state which vendors and technologies should be utilized. The basic
purpose is to establish ground rules and parameters used to then work out more specific data
security practices.
The policy should encompass all of its mission-critical data and electronic systems –
including the internet, email, computer networks, and so forth. Further, three vital points need
to be considered when devising a corporate IT security policy:
the protection of information from destruction (think viruses, worms, Trojans), internal
misuse and abuse.
An IT security policy provides a launching pad for further IT security procedures, a basis for
consistent application, and a stable reference guide for IT security breaches when they do
occur. Rather than throwing this policy on the shelf to collect dust, use it to ensure that your
corporate data remains secure and exact appropriate penalties when it’s not. Below are three
additional ways that an IT security policy may prove beneficial:
how and when to use email, the internet, electronic devices, and computer networks
your threat of exposure to malware and confidential data leaks will decrease markedly.
Emails – personal and corporate – will inevitably make an organization vulnerable to (spear)
phishing attacks, viruses, and other malicious software. Employees who exchange emails
within or outside of the company may include racial and sexist jokes, sexually explicit
content, and other material that may be deemed offensive by the recipients of these emails.
This activity opens the company to massive legal liabilities if employees file lawsuits because
they feel harassed or offended by these emails.
An IT security policy (and its enforcement) will weed out offenders and hold up as a tight
defense in a court of law as the company can show that it did everything in its power to
discourage offensive emails and resolve all related issues.
2. Third parties – When individuals and businesses (i.e. vendors, auditors, clients, investors,
etc.) partner with you, they will probably want to know if you have an established IT security
policy before they share their confidential information, such as bank statements, social
security numbers, names, addresses, and other identity-specific information.
For example, a clearing corporation offers all manner of finance processing and programming
services for insurance companies, banks, and even government agencies. Naturally they have
a stringent IT security policy to ensure none of those financial records were ever subject to
phishing attacks.
3. Compliance with Govt & local legislation – Finally, companies create IT security
policies to meet the standards and regulations of government laws on the protection of
electronic information.
To protect the company against this type of litigation, make them aware of your IT security
and email policies through informational sessions and training. Doing so will place the
responsibility of compliance on their shoulders and reduce the risk of unethical activity.
Most full IT security plans would include the following nine policy topics:
The scope of this policy includes any and all use of corporate IT resources,
including but not limited to, computer systems, email, the corporate network,
and the corporate Internet connection.
For example, Annese's Acceptable Use policy outlines things like email use,
confidentiality, social media and web browsing, personal use, and how to
report security incidents. Your Acceptable Use Policy should be the one policy
everyone in your organization acknowledges via signature that they have read
and understand.
Confidential data is typically the data that holds the most value to a company. Often,
confidential data is valuable to others as well, and thus can carry greater risk than general
company data. For these reasons, it is good practice to dictate security standards that relate
specifically to confidential data.
This policy would detail how confidential data should be handled, and examples of what your
organization deems confidential.
3. Email Policy
This policy will help the company reduce risk of an email-related security
incident, foster good business communications both internally and externally,
and provide for consistent and professional application of the company's email
principles.
The scope of this policy includes the company's email system in its entirety,
including desktop and/or web-based email applications, server-side
applications, email relays, and associated hardware. It covers all electronic
mail sent from the system, as well as any external email accounts accessed
from the company network.
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Compiled by Srinivas Kante Email: [email protected]
This policy covers any mobile device capable of coming into contact with
your companies' data.
A security incident can come take many forms: a malicious attacker gaining access to the
network, a virus or other malware infecting computers, or even a stolen laptop containing
confidential data. A well thought-out Incident Response Policy is critical to successful
recovery from a data incident.
This policy covers all incidents that may affect the security and integrity of your company's
information assets, and outlines steps to take in the event such an incident occurs.
Everyone needs a secure network infrastructure to protect the integrity of their corporate data
and mitigate risk of a security incident. The purpose of a specific network infrastructure
security policy is to establish the technical guidelines for IT security, and to communicate the
controls necessary for a secure network infrastructure.
This policy might include specific procedures around device passwords, logs, firewalls,
networked hardware, and/or security testing.
7. Password Policy
The easiest entry point to building your security policy, a password policy is the first step in
enabling employees to safeguard your company from cyberattack. (Annese is sharing our
own password policy as part of the template to get you started here.)
Passwords are the front line of protection for user accounts. A poorly chosen password may
result in the compromise of your organization's entire corporate network. This policy would
apply to any person who is provided an account connected to your corporate network or
systems, including: employees, guests, contractors, partners, vendors, etc.
The purpose of this policy is to protect your company’s physical information systems by
setting standards for secure operations. In order to secure your company data, thought must
be given to the security of the company's physical Information Technology (IT) resources to
ensure that they are protected from standard risks.
Every organization should have a wireless policy that would likely need to include your guest
access requirements. Wireless access can be done securely if certain steps are taken to
mitigate known risks.
Guest access to the company's network is often necessary for customers, consultants, or
vendors who are visiting company offices. This may simply take the form of outbound
Internet access, or the guest may require access to specific resources on the company's
network. Therefore, guest access to the company's network must be tightly controlled.
This policy would outline steps the company wishes to take to secure its
wireless infrastructure. These policies would cover anyone who accesses the
network via a wireless connection, guest included.
The role of the Information Security committee is to devise strategies and policies for the
protection of all assets of the bank (including information, applications, infrastructure and
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
people). The committee will also provide guidance and direction on the Security Implications
of the business continuity and disaster recovery plans. Develop and facilitate implementation
of information security policies, standards and procedures to ensure that all identified risks
are managed within the bank's risk appetite.
Create an information security and risk management structure covering the entire bank, with
clearly defined roles and responsibilities. Create and follow a risk assessment process that is
consistent across the bank to identify, evaluate key risks and approve control measures and
mitigation strategies. Regularly monitor the information security and risk management
processes and corrective actions to ensure compliance with regulatory requirements. Ensure
that the Information Security Team is appropriately skilled and adequately staffed. Regularly
present reports to the Board and invite feedback on the information security management
processes.
The Head of Integrated Risk Management will be a senior level official of the rank of
CGM/GM/DGM. The HIRM is responsible for all Risk Management functions in the Bank,
like Credit Risk, Market Risk, and Operational Risk. Information Security will be one of the
most critical components of Operational Risk that has to be looked after by the HIRM. He is
the senior-most executive in the Information Security function in the bank and provides the
required leadership and support for this across the bank, with the full backing and
commitment from the Board.
Depending upon the size of the bank and its scale of operations, a sufficiently senior level
official of the rank of GM/DGM/AGM needs to be designated as the Chief Information
Security Officer (CISO) responsible for articulating and enforcing the policies that a bank
uses to protect its information assets apart from coordinating the information security related
issues / implementation within the organization as well as relevant external agencies.
The CISO needs to report directly to the Head of Integrated Risk Management (HIRM)
function and should not have a direct reporting relationship with the CIO. The CISO's role
spans across both strategic and operational dimensions and is responsible for all the
administrative tasks and control related to Information Security and reports to the Owner of
this function, the HIRM.
Responsibilities:
The ISRM owns the Risk Management Life Cycle as far as Information Security is concerned.
He assists the CISO by discharging the following.
Information Security Risk Assessment
Information Security Risk Analysis and Evaluation
Information Security Risk Mitigation
Identification and assignment of controls.
Information Security Risk Management
Compliance with Information Security Risk Management Guidelines – External and Internal
Monitoring Information Security Policy Implementation
The ISAM is responsible for enhancing the Information Security Awareness levels and for
striving to create a conducive environment and compliance culture across the bank. He is
expected to keep himself abreast of the latest developments in the field of Information
Security Standards and Best Practices so that proactive steps can be taken for adopting them,
wherever possible and applicable in the bank, at the earliest. He is a friend, philosopher and
guide to the entire bank, as far as education and awareness-building in Information Security is
concerned. Information Security Policy – Inputs and Enhancements
Measurement and Monitoring of Effectiveness of Information Security Policy
implementation.
Education, Awareness and Promotion of Information Security initiatives across the bank.
Intensive Training of various types and for different levels on Information Security
Promoting customer education and awareness on Information Security through appropriate
channels, tools and interventions.
Proactive dissemination of Information Security Policy initiatives, mechanisms and best
practices
– a Resource Base of online tutorials, demos, quizzes and FAQ's on the Intranet for easy
access within the bank.
Security Operations Centre and Incident Management (SOCIM)
The SOCIM executive is responsible for effective oversight of the Security Operations Centre
and Incident Management capabilities for the bank as a whole. The Security Posture and
Status is demonstrated by this functionary.
Responsibilities:
Owner of the Bank-wide Security Operations Centre(SOC)
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
Organizational Security
Organisational Policy
A security policy is expected to do many things. Primarily it should protect people and
information, as well as set the rules for expected behaviour by users, system administrators,
management and security personnel. It should also authorise relevant personnel to monitor,
probe, investigate, define and authorise the consequences of violations, in addition to defining
the company’s baseline stance on security. This can help minimise risk and help track
compliance with appropriate regulations.
This is fine in theory, but as recent high profile cases have demonstrated, having written
policies does not always mean that people follow them
Information Security Policy (ISP) is a set of rules enacted by an organization to ensure that
all users or networks of the IT structure within the organization’s domain abide by the
prescriptions regarding the security of data stored digitally within the boundaries the
organization stretches its authority.
An ISP is governing the protection of information, which is one of the many assets a
corporation needs to protect. The present writing will discuss some of the most important
aspects a person should take into account when contemplates developing an ISP. Putting to
work the logical arguments of rationalization, one could say that a policy can be as broad as
the creators want it to be: Basically, everything from A to Z in terms of IT security, and even
more. For that reason, the emphasis here is placed on a few key elements, but you should
make a mental note of the liberty of thought organizations have when they forge their own
guidelines.
2.1 Purpose
Institutions create ISPs for a variety of reasons:
2.2 Scope
ISP should address all data, programs, systems, facilities, other tech infrastructure, users of
technology and third parties in a given organization, without exception.
Simplification of policy language is one thing that may smooth away the differences and
guarantee consensus among management staff. Consequently, ambiguous expressions are to
be avoided. Beware also of the correct meaning of terms or common words. For instance,
“musts” express negotiability, whereas “shoulds” denote certain level of discretion. Ideally,
the policy should be briefly formulated to the point. Redundancy of the policy’s wording (e.g.,
pointless repetition in writing) should be avoided as well as it would make documents
long-winded and out of sync, with illegibility that encumbers evolution. In the end, tons of
details may impede the complete compliance at the policy level.
So how management views IT security seems to be one of the first steps when a person
intends to enforce new rules in this department. Furthermore, a security professional should
make sure that the ISP has an equal institutional gravity as other policies enacted within the
corporation. In cases where an organization has sizeable structure, policies may differ and
therefore be segregated in order to define the dealings in the intended subset of this
organization.
Typically, a security policy has a hierarchical pattern. It means that inferior staff is usually
bound not to share the little amount of information they have unless explicitly authorized.
Conversely, a senior manager may have enough authority to make a decision what data can be
shared and with whom, which means that they are not tied down by the same information
security policy terms. So the logic demands that ISP should address every basic position in
the organization with specifications that will clarify their authoritative status.
Policy refinement takes place simultaneously with defining the administrative control, or
authority in other words, people in the organization have. In essence, it is hierarchy-based
delegation of control in which one may have authority over his own work, project manager
has authority over project files belonging to a group he is appointed to, and the system
administrator has authority solely over system files – a structure reminiscent of the separation
of powers doctrine. Obviously, a user may have the “need-to-know” for a particular type of
information. Therefore, data must have enough granularity attribute in order to allow the
appropriate authorized access. This is the thin line of finding the delicate balance between
permitting access to those who need to use the data as part of their job and denying such to
unauthorized entities.
Access to company’s network and servers, whether or not in the physical sense of the word,
should be via unique logins that require authentication in the form of either passwords,
biometrics, ID cards, or tokens etc. Monitoring on all systems must be implemented to record
logon attempts (both successful ones and failures) and exact date and time of logon and
logoff.
Speaking of evolution in the previous point – as the IT security program matures, the policy
may need updating. While doing so will not necessarily be tantamount to improvement in
security, it is nevertheless a sensible recommendation.
organization’s resources. Data classification policy may arrange the entire set of information
as follows:
1. High Risk Class– data protected by state and federal legislation (the Data
Protection Act, HIPAA, FERPA) as well as financial, payroll, and personnel (privacy
requirements) are included here.
1. Confidential Class – the data in this class does not enjoy the privilege of being
under the wing of law, but the data owner judges that it should be protected against
unauthorized disclosure.
2. Class Public – This information can be freely distributed.
Data owners should determine both the data classification and the exact measures a data
custodian needs to take to preserve the integrity in accordance to that leve
Sharing IT security policies with staff is a critical step. Making them read and sign to
acknowledge a document does not necessarily mean that they are familiar with and
understand the new policies. A training session would engage employees in positive attitude
to information security, which will ensure that they get a notion of the procedures and
mechanisms in place to protect the data, for instance, levels of confidentiality and data
sensitivity issues. Such an awareness training should touch on a broad scope of vital topics:
how to collect/use/delete data, maintain data quality, records management, confidentiality,
privacy, appropriate utilization of IT systems, correct usage social networking, etc. A small
test at the end is perhaps a good idea.
Prevention of theft, information know-how and industrial secrets that could benefit
competitors are among the most cited reasons why a business may want to employ an ISP to
defend its digital assets and intellectual rights.
BANKING SECTOR
The Reserve Bank of India issued new guidance in April 2011 for banks to mitigate the
risks of use of information technology in banking operations. RBI guidelines are result of the
Working Group's recommendations on information security, electronic banking, technology
risk management and cyber fraud. The Working Group was formed under the chairmanship of
G. Gopalakrishna, the executive director of RBI in April 2010.
The guidance is largely driven by the need for mitigating cyber threats emerging from
increasing adoption of IT by commercial banks in India.
Security Governance
Security governance is the means by which you control and direct your organisation’s
approach to security. When done well, security governance will effectively coordinate the
security activities of your organisation. It enables the flow of security information and
decisions around your organisation.
Just as security is the responsibility of everyone within an organisation, security decision
making can happen at all levels. To achieve this, an organisation’s senior leadership should
use security governance to set out the kinds of security risks they are prepared for staff to take,
and those they are not.
The IT security and governance function includes ensuring, establishing and enforcing
security policies, standards and procedures. IT Security Managers continuously monitor all
components of the IT infrastructure for compliance and security threats and take appropriate
remedial action. They also conduct IT risk analysis and assessments and then make sure there
are solutions in place to mitigate the risks. An established governance framework to manage
all IT Governance, Risk, and Compliance (IT-GRC) related activities enable IT security
professionals to manage IT governance, IT policy, IT risk, IT compliance, IT audit and
incidents in an integrated manner.
Enterprise security governance is a company's strategy for reducing the risk of
unauthorized access to information technology systems and data.
Enterprise security governance is a company's strategy for reducing the chance that physical
assets owned by the company can be stolen or damaged. In this context, governance of
enterprise security includes physical barriers, locks, fencing and fire response systems as well
as lighting, intrusion detection systems, alarms and cameras.
Little has changed over the centuries when it comes to protecting property, with locked
doors/chests, armed security guards, booby-traps, etc.
Physical security considerations (at all levels from corporate to personal) should include
protection from burglary, theft, vandalism, view and, potentially, terrorism, depending upon
your location and what you are into! The very best in software security isn't worth very much
if somebody walks off with your computer under their arm!
Additionally, environmental threats include fire, flood, natural disasters and contamination
from spilled food/drink.
The following gives a brief overview of some of the options available for physically securing
and protecting your equipment and data.
You can always buy new kit and probably with significantly enhanced performance than the
one you had before – OK, the insurance no-claims discount might take a bit of a hit – but loss
of a high-performance machine is but little compared to loss of the valued data upon it, or
worse, compounded by loss of confidentiality of that data.
Loss of information, especially client information perhaps, can also lead to reputational
damage, litigation, data recovery/re-creation costs … you name it.
So, in your risk analysis (if you have one) for protecting information, stack the impact
assessment against the data, not the machine.
Having said all that, there are sensible physical protection precautions you can take:
· Keep non-portable devices (PCs, printers) in lockable premises
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Compiled by Srinivas Kante Email: [email protected]
· Keep portable devices (laptops, smart phones, tablets) always within your
protective reach when on the move
· If you have precious information on the device, regularly back it up and store the
backup media securely
· If possible, remove the hard drive and keep it separate from the device
· Definitely don’t leave USB keys inserted for too long – they’re so small
nowadays you may forget they are there
· Use some form of endpoint encryption on your device that prevents data being
exported
· If using a token authentication, keep the PC/device and token separately - don’t
write the token PIN down and keep it with the token
· Don’t leave computing equipment in a car, locked or not – even if out of sight,
this would be a major bonus to what would otherwise be a common car thief!
Some of the controls, like taking data backups, removing hard drives, encrypting data, etc.
mentioned in the previous item, are also relevant here, but the following is worth mentioning:
· Always transport a laptop in a padded laptop bag or a smaller device (e.g. tablet
or smart phone) in its protective casing - both will fare better if they get dropped.
· When travelling in a taxi, especially at night when the back of the cab is dark, or
if having a snooze on a train, keep your arm or leg through the strap of your (preferably
locked) laptop bag. That way, if it gets snatched, at least you’ll be snatched with it … and
you’re less likely to leave it on the taxi by mistake. (It does happen!)
· If you use a server room, ensure the most appropriate fire prevention/detection
systems are deployed – water-based sprinklers may save the building but will do no favours
to computing equipment or associated media.
The downside to these is that, in the writer’s view, they can sound off spontaneously as false
alarms, which can result at best in irritation or at worst ignoring it and taking no action.
Associated with this, you should keep a separate record of the equipment manufacturer’s
serial number.
Although not a physical control, closely associated with this concept is the use of screen
saver passwords – always, even when at home, use a timeout based upon a short period of
keyboard inactivity – and be sure to position your monitor in such a way as to prevent casual
viewing or “shoulder surfing”.
When leaving your desk for a short period, allow yourself time to exit from and/or lock down
any sensitive work you may be doing in case “unauthorised” people approach your work area
during your absence.
Remember, also, when leaving meeting rooms, to clear white boards of any information that
should not be disclosed to unauthorised viewers.
· Visitors to be hosted, accompanied at all times … well, nearly all times … and
checked in and out of the premises
· Keep a visitor’s book with details of name, date, who is being visited (or who is
hosting), time in/out and, if appropriate, vehicle registration. (NB. A visitor’s book can also
be critical in the event of an emergency evacuation to ensure all people on the premises are
accounted for)
More sophisticated (which usually means more expensive) premises protection can also be
achieved with:
· Electronic badge recognition systems which open doors and record who has been
where … but be sure not to set the badge reader sensitivity so high that it activates simply
when a badge wearer walks past!
· “Data lock” devices requiring input of a PIN code – but codes do need to be
periodically changed to remain effective
Hardware security
Hardware security is vulnerability protection that comes in the form of a physical device
rather than software that is installed on the hardware of a computer system.
Hardware security can pertain to a device used to scan a system or monitor network traffic.
Common examples include hardware firewalls and proxy servers. Less common examples
include hardware security modules (HSM), which provision cryptographic keys for critical
functions such as encryption, decryption and authentication for various systems. Hardware
systems can provide more robust security than software is capable of and can also add an
additional layer of security for important systems.
The term hardware security also refers to the protection of physical systems from
harm. Equipment destruction attacks, for example, focus on computing devices and
networked non-computing devices such as the ever-increasing number of connected devices
in M2M or IoT (Internet of Things) environments. These environments are bringing
connectivity and communications to large numbers of hardware devices that must be
protected through either hardware- or software-based security.
To assess the security of a hardware device, it’s necessary to consider vulnerabilities existing
from its manufacture as well as other potential sources such as running code and the device’s
data I/O on a network. Although any device should be protected if it connects even indirectly
to the internet, the stringency of that protection should be in accordance with need. A system
controlling the color and intensity of lights in Wi-Fi LED for a dwelling, for example, may
not require much security.
Web server:
A web server is a system that delivers content or services to end users over the internet. A
web server consists of a physical server, server operating system (OS) and software used to
facilitate HTTP communication.
Mail Server:
A mail server (sometimes also referred to an e-mail server) is a server that handles and
delivers e-mail over a network, usually over the Internet. A mail server can receive e-mails
from client computers and deliver them to other mail servers. A mail server can also deliver
e-mails to client computers. A client computer is normally the computer where you read your
e-mails, for example your computer at home or in your office. Also an advanced mobile
phone or Smartphone, with e-mail capabilities, can be regarded as a client computer in these
circumstances.
File Server: File server (or fileserver) is a computer attached to a network that provides a
location for shared disk access, i.e. shared storage of computer files (such as text, image,
sound, video) that can be accessed by the workstations that are able to reach the computer
that shares the access through a computer network. The term server highlights the role of the
machine in the client–server scheme, where the clients are the workstations using the storage.
It is common that a file server does not perform computational tasks, and does not run
programs on behalf of its clients. It is designed primarily to enable the storage and retrieval of
data while the computation is carried out by the workstations.
File servers are commonly found in schools and offices, where users use a LAN to connect
their client computers.
Print Server:
A print server is a computer that can process print-related jobs on a network of computers.
Print servers are connected to a computer network in order to serve the need for printing jobs
in a network that may contain more than one printer. A print server usually allows users in a
computer network to perform a printing job without having to move files to the computer
connected directly to the printer.Also known as printer server or network printer, (although
the latter is actually one of the properties of the print server).
Network server
A network server is a computer designed to act as central repository and help in providing
various resources like hardware access, disk space, printer access, etc,. to other computers in
the network.
A network server might not differ from a workstation in hardware, but the functionality it
performs clearly differentiates it from other workstations. Network servers helps in
simplifying the different tasks for system administrators including those centering around
management.
Any configuration or security updates can be applied to a network server instead of
individually passing to different computers connected to the network.
Factors influencing the choice of utilizing a network server:
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Computers are provided with more memory and storage capacity and also are configured
to do additional processing to handle the different client requests.
Machines are usually high performing personal computers with reliable and fast hard
disks, powerful processors and high amounts of available RAM.
Can also act as a central file storage unit. This can prevent data being stored in different
workstations in the network.
Authentication and user control can be set on another workstation using a network
server.
Security control measures can be more convenient to manage using a network server.
Network server is also capable of running an intranet.
Some of the common examples of network servers are FTP servers and web servers.
Database Server
The term database server may refer to both hardware and software used to run a database,
according to the context. As software, a database server is the back-end portion of a database
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application, following the traditional client-server model. This back-end portion is sometimes
called the instance. It may also refer to the physical computer used to host the database. When
mentioned in this context, the database server is typically a dedicated higher-end computer
that hosts the database.
Note that the database server is independent of the database architecture. Relational databases,
flat files, non-relational databases: all these architectures can be accommodated on database
servers.
Modem
A modem is a network device that both modulates and demodulates analog carrier signals
(called sine waves) for encoding and decoding digital information for processing. Modems
accomplish both of these tasks simultaneously and, for this reason, the term modem is a
combination of "modulate" and "demodulate."
Repeater
A repeater is a network device that retransmits a received signal with more power and to an
extended geographical or topological network boundary than what would be capable with the
original signal.
Switch
A switch, in the context of networking is a high-speed device that receives incoming data
packets and redirects them to their destination on a local area network (LAN). A LAN switch
operates at the data link layer (Layer 2) or the network layer of the OSI Model and, as such it
can support all types of packet protocols.
Gateway
In computer networking and telecommunications, a gateway is a component that is part of
two networks, which use different protocols. The gateway will translate one protocol into the
other. A router is a special case of a gateway.
Gateways, also called protocol converters, can operate at any network layer. The activities of
a gateway are more complex than that of the router or switch as it communicates using more
than one protocol.
Both the computers of internet users and the computers that serve pages to users are host
nodes. The nodes that connect the networks in between are gateways. These are gateway
nodes:
the computers that control traffic between company networks
the computers used by internet service providers (ISPs) to connect users to the
internet
VSAT (Very Small Aperture Terminal) is a satellite communications system that serves home
and business users. A VSAT end user needs a box that interfaces between the user's computer
and an outside antenna with a transceiver. The tranceiver receives or sends a signal to a
satellite transponder in the sky. The satellite sends and receives signals from an earth station
computer that acts as a hub for the system. Each end user is interconnected with the hub
station via the satellite in a star topology. For one end user to communicate with another, each
transmission has to first go to the hub station which retransmits it via the satellite to the other
end user's VSAT. VSAT handles data, voice, and video signals.
VSAT is used both by home users who sign up with a large service such as DirecPC and by
private companies that operate or lease their own VSAT systems. VSAT offers a number of
advantages over terrestrial alternatives. For private applications, companies can have total
OPERATIONAL SECURITY
Operational security (OPSEC), also known as procedural security, is a risk management
process that encourages managers to view operations from the perspective of an adversary in
order to protect sensitive information from falling into the wrong hands.
Though originally used by the military, OPSEC is becoming popular in the private sector as
well. Things that fall under the OPSEC umbrella include monitoring behaviors and habits
on social media sites as well as discouraging employees from sharing login credentials via
email or text message.
THE FIVE STEPS OF OPERATIONAL SECURITY
The processes involved in operational security can be neatly categorized into five steps:
1. Identify your sensitive data, including your product research, intellectual property,
financial statements, customer information, and employee information. This will be the data
you will need to focus your resources on protecting.
1. Identify possible threats. For each category of information that you deem sensitive, you
should identify what kinds of threats are present. While you should be wary of third parties
trying to steal your information, you should also watch out for insider threats, such as
negligent employees and disgruntled workers.
2. Analyze security holes and other vulnerabilities. Assess your current safeguards and
determine what, if any, loopholes or weaknesses exist that may be exploited to gain access to
your sensitive data.
3. Appraise the level of risk associated with each vulnerability. Rank your
vulnerabilities using factors such as the likelihood of an attack happening, the extent of
damage that you would suffer, and the amount of work and time you would need to recover.
The more likely and damaging an attack is, the more you should prioritize mitigating the
associated risk.
4. Get countermeasures in place. The last step of operational security is to create and
implement a plan to eliminate threats and mitigate risks. This could include updating your
hardware, creating new policies regarding sensitive data, or training employees on sound
security practices and company policies. Countermeasures should be straightforward and
simple. Employees should be able to implement the measures required on their part with or
without additional training.
BEST PRACTICES FOR OPERATIONAL SECURITY
Implement precise change management processes that your employees should follow
when network changes are performed. All changes should be logged and controlled so they
can be monitored and audited.
Restrict access to network devices using AAA authentication. In the military and other
government entities, a “need-to-know” basis is often used as a rule of thumb regarding access
and sharing of information.
Give your employees the minimum access necessary to perform their jobs. Practice
the principle of least privilege.
Implement dual control. Make sure that those who work on your network are not the
same people in charge of security.
Software Security
Software security is an idea implemented to protect software against malicious attack and
other hacker risks so that the software continues to function correctly under such potential
risks. Security is necessary to provide integrity, authentication and availability.
Any compromise to integrity, authentication and availability makes a software unsecure.
Software systems can be attacked to steal information, monitor content, introduce
vulnerabilities and damage the behavior of software. Malware can cause DoS (denial of
service) or crash the system itself.
Buffer overflow, stack overflow, command injection and SQL injections are the most
common attacks on the software.
Buffer and stack overflow attacks overwrite the contents of the heap or stack respectively by
writing extra bytes.
Command injection can be achieved on the software code when system commands are used
predominantly. New system commands are appended to existing commands by the malicious
attack. Sometimes system command may stop services and cause DoS.
SQL injections use malicious SQL code to retrieve or modify important information from
database servers. SQL injections can be used to bypass login credentials. Sometimes SQL
injections fetch important information from a database or delete all important data from a
database.
The only way to avoid such attacks is to practice good programming techniques.
System-level security can be provided using better firewalls. Using intrusion detection and
prevention can also aid in stopping attackers from easy access to the system
1.System Software
System software is a platform comprised of Operating System (OS) programs and services,
including settings and preferences, file libraries and functions used for system applications.
System software also includes device drivers that run basic computer hardware and
peripherals.
System software is run by the OS, versus end users. Because system software runs in the
background at a basic level, it is considered low-level software.
Utility software
System servers
Device drivers
Operating system (OS)
Windows/graphical user interface (GUI) systems
2.Application Software
Application software is a program or group of programs designed for end users. These
programs are divided into two classes: system software and application software. While
system software consists of low-level programs that interact with computers at a basic level,
application software resides above system software and includes applications such as
database programs, word processors and spreadsheets. Application software may be bundled
with system software or published alone.
Software Testing
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Compiled by Srinivas Kante Email: [email protected]
• is sufficiently usable,
As the number of possible tests for even simple software components is practically infinite,
all software testing uses some strategy to select tests that are feasible for the available time
and resources. As a result, software testing typically (but not exclusively) attempts to execute
a program or application with the intent of finding software bugs (errors or other defects).
The job of testing is an iterative process as when one bug is fixed, it can illuminate other,
deeper bugs, or can even create new ones.
Software testing can provide objective, independent information about the quality of software
and risk of its failure to users or sponsors.
Software testing can be conducted as soon as executable software (even if partially complete)
exists. The overall approach to software development often determines when and how testing
is conducted. For example, in a phased process, most testing occurs after system requirements
have been defined and then implemented in testable programs. In contrast, under an agile
approach, requirements, programming, and testing are often done concurrently.
White-box testing
White-box testing (also known as clear box testing, glass box testing, transparent box testing
and structural testing, by seeing the source code) tests internal structures or workings of a
program, as opposed to the functionality exposed to the end-user. In white-box testing, an
internal perspective of the system, as well as programming skills, are used to design test cases.
The tester chooses inputs to exercise paths through the code and determine the appropriate
outputs. This is analogous to testing nodes in a circuit, e.g. in-circuit testing (ICT).
While white-box testing can be applied at the unit, integration and system levels of the
software testing process, it is usually done at the unit level. It can test paths within a unit,
paths between units during integration, and between subsystems during a system–level test.
Though this method of test design can uncover many errors or problems, it might not detect
unimplemented parts of the specification or missing requirements.
Techniques used in white-box testing include:
API testing – testing of the application using public and private APIs (application
programming interfaces)
Code coverage – creating tests to satisfy some criteria of code coverage (e.g., the test
designer can create tests to cause all statements in the program to be executed at least
once)
Fault injection methods – intentionally introducing faults to gauge the efficacy of
testing strategies
Mutation testing methods
Static testing methods
Code coverage tools can evaluate the completeness of a test suite that was created with any
method, including black-box testing. This allows the software team to examine parts of a
system that are rarely tested and ensures that the most important function points have been
tested. Code coverage as a software metric can be reported as a percentage for:
Function coverage, which reports on functions executed
Statement coverage, which reports on the number of lines executed to complete
the test
Decision coverage, which reports on whether both the True and the False branch
of a given test has been executed
100% statement coverage ensures that all code paths or branches (in terms of control flow)
are executed at least once. This is helpful in ensuring correct functionality, but not
sufficient since the same code may process different inputs correctly or incorrectly.
Black-box testing
testing, state transition tables, decision table testing, fuzz testing, model-based testing, use
case testing, exploratory testing, and specification-based testing.
Specification-based testing aims to test the functionality of software according to the
applicable requirements.[16] This level of testing usually requires thorough test cases to be
provided to the tester, who then can simply verify that for a given input, the output value
(or behavior), either "is" or "is not" the same as the expected value specified in the test
case. Test cases are built around specifications and requirements, i.e., what the application
is supposed to do. It uses external descriptions of the software, including specifications,
requirements, and designs to derive test cases. These tests can
be functional or non-functional, though usually functional.
Specification-based testing may be necessary to assure correct functionality, but it is
insufficient to guard against complex or high-risk situations.
One advantage of the black box technique is that no programming knowledge is required.
Whatever biases the programmers may have had, the tester likely has a different set and
may emphasize different areas of functionality. On the other hand, black-box testing has
been said to be "like a walk in a dark labyrinth without a flashlight." Because they do not
examine the source code, there are situations when a tester writes many test cases to
check something that could have been tested by only one test case or leaves some parts of
the program untested.
This method of test can be applied to all levels of software
testing: unit, integration, system and acceptance. It typically comprises most if not all
testing at higher levels, but can also dominate unit testing as well.
Visual testing
The aim of visual testing is to provide developers with the ability to examine what was
happening at the point of software failure by presenting the data in such a way that the
developer can easily find the information she or he requires, and the information is
expressed clearly.
At the core of visual testing is the idea that showing someone a problem (or a test failure),
rather than just describing it, greatly increases clarity and understanding. Visual testing,
therefore, requires the recording of the entire test process – capturing everything that
occurs on the test system in video format. Output videos are supplemented by real-time
tester input via picture-in-a-picture webcam and audio commentary from microphones.
Visual testing provides a number of advantages. The quality of communication is
increased drastically because testers can show the problem (and the events leading up to it)
to the developer as opposed to just describing it and the need to replicate test failures will
cease to exist in many cases. The developer will have all the evidence he or she requires
of a test failure and can instead focus on the cause of the fault and how it should be fixed.
Visual testing is particularly well-suited for environments that deploy agile methods in
their development of software since agile methods require greater communication
between testers and developers and collaboration within small teams.
Ad hoc testing and exploratory testing are important methodologies for checking software
integrity, because they require less preparation time to implement, while the important
bugs can be found quickly. In ad-hoc testing, where testing takes place in an improvised,
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Compiled by Srinivas Kante Email: [email protected]
impromptu way, the ability of a test tool to visually record everything that occurs on a
system becomes very important in order to document the steps taken to uncover the bug.
Visual testing is gathering recognition in customer acceptance and usability testing,
because the test can be used by many individuals involved in the development
process. For the customer, it becomes easy to provide detailed bug reports and feedback,
and for program users, visual testing can record user actions on screen, as well as their
voice and image, to provide a complete picture at the time of software failure for the
developers.
Grey-box testing
Grey-box testing (American spelling: gray-box testing) involves having knowledge of
internal data structures and algorithms for purposes of designing tests while executing
those tests at the user, or black-box level. The tester is not required to have full access to
the software's source code. Manipulating input data and formatting output do not qualify
as grey-box, as the input and output are clearly outside of the "black box" that we are
calling the system under test. This distinction is particularly important when
conducting integration testing between two modules of code written by two different
developers, where only the interfaces are exposed for the test.
However, tests that require modifying a back-end data repository such as a database or a
log file does qualify as grey-box, as the user would not normally be able to change the
data repository in normal production operations.Grey-box testing may also
include reverse engineering to determine, for instance, boundary values or error
messages.
By knowing the underlying concepts of how the software works, the tester makes
better-informed testing choices while testing the software from outside. Typically, a
grey-box tester will be permitted to set up an isolated testing environment with activities
such as seeding a database. The tester can observe the state of the product being tested
after performing certain actions such as executing SQL statements against the database
and then executing queries to ensure that the expected changes have been reflected.
Grey-box testing implements intelligent test scenarios, based on limited information. This
will particularly apply to data type handling, exception handling, and so on.
Testing levels
There are generally four recognized levels of tests: unit testing, integration testing,
component interface testing, and system testing. Tests are frequently grouped by where
they are added in the software development process, or by the level of specificity of the
test. The main levels during the development process as defined by the SWEBOKguide
are unit-, integration-, and system testing that is distinguished by the test target without
implying a specific process model. Other test levels are classified by the testing objective.
There are two different levels of tests from the perspective of customers: low-level testing
(LLT) and high-level testing (HLT). LLT is a group of tests for different level components
of software application or product. HLT is a group of tests for the whole software
application or product.
Unit testing
Unit testing refers to tests that verify the functionality of a specific section of code,
usually at the function level. In an object-oriented environment, this is usually at the class
level, and the minimal unit tests include the constructors and destructors.[23]
These types of tests are usually written by developers as they work on code (white-box
style), to ensure that the specific function is working as expected. One function might
have multiple tests, to catch corner cases or other branches in the code. Unit testing alone
cannot verify the functionality of a piece of software, but rather is used to ensure that the
building blocks of the software work independently from each other.
Unit testing is a software development process that involves a synchronized application
of a broad spectrum of defect prevention and detection strategies in order to reduce
software development risks, time, and costs. It is performed by the software developer or
engineer during the construction phase of the software development lifecycle. Unit testing
aims to eliminate construction errors before code is promoted to additional testing; this
strategy is intended to increase the quality of the resulting software as well as the
efficiency of the overall development process.
Depending on the organization's expectations for software development, unit testing
might include static code analysis, data-flow analysis, metrics analysis, peer code
reviews, code coverage analysis and other software testing practices.
Integration testing
Integration testing is any type of software testing that seeks to verify the interfaces
between components against a software design. Software components may be integrated
in an iterative way or all together ("big bang"). Normally the former is considered a better
practice since it allows interface issues to be located more quickly and fixed.
Integration testing works to expose defects in the interfaces and interaction between
integrated components (modules). Progressively larger groups of tested software
components corresponding to elements of the architectural design are integrated and
tested until the software works as a system.
Component interface testing
The practice of component interface testing can be used to check the handling of data
passed between various units, or subsystem components, beyond full integration testing
between those units.[ The data being passed can be considered as "message packets" and
the range or data types can be checked, for data generated from one unit, and tested for
validity before being passed into another unit. One option for interface testing is to keep a
separate log file of data items being passed, often with a timestamp logged to allow
analysis of thousands of cases of data passed between units for days or weeks. Tests can
include checking the handling of some extreme data values while other interface variables
are passed as normal values.[ Unusual data values in an interface can help explain
unexpected performance in the next unit. Component interface testing is a variation
of black-box testing,[with the focus on the data values beyond just the related actions of a
subsystem component.
System testing
System testing tests a completely integrated system to verify that the system meets its
requirements.For example, a system test might involve testing a logon interface, then
creating and editing an entry, plus sending or printing results, followed by summary
processing or deletion (or archiving) of entries, then logoff.
Operational acceptance testing
Operational acceptance is used to conduct operational readiness (pre-release) of a product,
service or system as part of a quality management system. OAT is a common type of
non-functional software testing, used mainly in software development and software
maintenance projects. This type of testing focuses on the operational readiness of the
system to be supported, or to become part of the production environment. Hence, it is also
known as operational readiness testing (ORT) or Operations readiness and
assurance (OR&A) testing. Functional testing within OAT is limited to those tests that are
required to verify the non-functional aspects of the system.
In addition, the software testing should ensure that the portability of the system, as well
as working as expected, does not also damage or partially corrupt its operating
environment or cause other processes within that environment to become inoperative.
Acceptance testing
Acceptance testing can mean one of two things:
1. A smoke test is used as a build acceptance test prior to further testing, e.g.,
before integration or regression.
1. Acceptance testing performed by the customer, often in their lab environment on
their own hardware, is known as user acceptance testing (UAT). Acceptance testing
may be performed as part of the hand-off process between any two phases of
development.
Alpha testing
Alpha testing is simulated or actual operational testing by potential users/customers or an
independent test team at the developers' site. Alpha testing is often employed for off-the-shelf
software as a form of internal acceptance testing before the software goes to beta testing.[
Beta testing
Beta testing comes after alpha testing and can be considered a form of external user
acceptance testing. Versions of the software, known as beta versions, are released to a limited
audience outside of the programming team known as beta testers. The software is released to
groups of people so that further testing can ensure the product has few faults or bugs. Beta
versions can be made available to the open public to increase the feedback field to a maximal
number of future users and to deliver value earlier, for an extended or even indefinite period
of time
Development testing
Development Testing is a software development process that involves the synchronized
application of a broad spectrum of defect prevention and detection strategies in order to
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Compiled by Srinivas Kante Email: [email protected]
reduce software development risks, time, and costs. It is performed by the software developer
or engineer during the construction phase of the software development lifecycle.
Development Testing aims to eliminate construction errors before code is promoted to other
testing; this strategy is intended to increase the quality of the resulting software as well as the
efficiency of the overall development process.
Depending on the organization's expectations for software development, Development
Testing might include static code analysis, data flow analysis, metrics analysis, peer code
reviews, unit testing, code coverage analysis, traceability, and other software testing practices.
A/B testing
A/B testing is a method of running a controlled experiment to determine if a proposed change
is more effective than the current approach. Customers are routed to either a current version
(control) of a feature, or to a modified version (treatment) and data is collected to determine
which version is better at achieving the desired outcome.
Concurrent testing
In concurrent testing, the focus is on the performance while continuously running with
normal input and under normal operational conditions, as opposed to stress testing, or fuzz
testing. Memory leak, as well as basic faults are easier to find with this method.
Conformance testing or type testing
In software testing, conformance testing verifies that a product performs according to its
specified standards. Compilers, for instance, are extensively tested to determine whether they
meet the recognized standard for that language.
Cloud Computing
Cloud computing is the the use of various services, such as software development platforms,
servers, storage and software, over the internet, often referred to as the "cloud."
In general, there are three cloud computing characteristics that are common among all
cloud-computing vendors:
their data, such as an email provider that stores data in multiple locations around the world. A
large regulated company, like a bank, might be required to store data in the United States.
While this is not an insurmountable issue, it demonstrates the type of issue that some
companies may have with cloud computing.
Cloud computing proponents point to it being a new paradigm in software development,
where smaller organizations have access to processing power storage and business processes
that were once only available to large enterprises.
The name cloud computing comes from the traditional usage of the cloud to represent the
internet – or a wide area network (WAN) – in network diagrams or flowcharts.
Cloud computing security refers to the set of procedures, processes and standards designed to
provide information security assurance in a cloud computing environment.
Cloud computing security addresses both physical and logical security issues across all the
different service models of software, platform and infrastructure. It also addresses how these
services are delivered (public, private or hybrid delivery model).
Cloud security encompasses a broad range of security constraints from an end-user and cloud
provider's perspective, where the end-user will primarily will be concerned with the
provider's security policy, how and where their data is stored and who has access to that data.
For a cloud provider, on the other hand, cloud computer security issues can range from the
physical security of the infrastructure and the access control mechanism of cloud assets, to
the execution and maintenance of security policy. Cloud security is important because it is
probably the biggest reason why organizations fear the cloud.
The Cloud Security Alliance (CSA), a nonprofit organization of industry specialists, has
developed a pool of guidelines and frameworks for implementing and enforcing security
within a cloud operating environment.
Public cloud: In Public cloud the computing infrastructure is hosted by the cloud vendor at
the vendor’s premises. The customer has no visibility and control over where the computing
infrastructure is hosted. The computing infrastructure is shared between any organizations.
Private cloud: The computing infrastructure is dedicated to a particular organization and not
shared with other organizations. Some experts consider that private clouds are not real
examples of cloud computing. Private clouds are more expensive and more secure when
compared to public clouds.
Private clouds are of two types: On-premise private clouds and externally hosted private
clouds. Externally hosted private clouds are also exclusively used by one organization, but
are hosted by a third party specializing in cloud infrastructure. Externally hosted private
clouds are cheaper than On-premise private clouds.
Hybrid cloud: Organizations may host critical applications on private clouds and
applications with relatively less security concerns on the public cloud. The usage of both
private and public clouds together is called hybrid cloud.
Based upon the services offered, clouds are classified in the following ways:
Infrastructure as a service (IaaS) involves offering hardware related services using the
principles of cloud computing. These could include some kind of storage services (database
or disk storage) or virtual servers. Leading vendors that provide Infrastructure as a service are
Amazon EC2, Amazon S3, Rackspace Cloud Servers and Flexiscale.
Software as a service (SaaS) includes a complete software offering on the cloud. Users can
access
Cloud computing challenges have always been there. Companies are increasingly aware of
the business value that cloud computing brings and are taking steps towards transition to the
cloud. Some of the most important challenges are as follows.
Security and Privacy: The main challenge to cloud computing is how it addresses the
security and privacy concerns of businesses thinking of adopting it. The fact that the valuable
enterprise data will reside outside the corporate firewall raises serious concerns. Hacking and
various attacks to cloud infrastructure would affect multiple clients even if only one site is
attacked. These risks can be mitigated by using security applications, encrypted file systems,
data loss software, and buying security hardware to track unusual behavior across servers.
Availability & Scalability: It is difficult to assess the costs involved due to the on-demand
nature of the services. Budgeting and assessment of the cost will be very difficult unless the
provider has some good and comparable benchmarks to offer. The service-level agreements
(SLAs) of the provider are not adequate to guarantee the availability and scalability.
Businesses will be reluctant to switch to cloud without a strong service quality guarantee.
Interoperability and Portability: Businesses should have the leverage of migrating in and
out of the cloud and switching providers whenever they want, and there should be no lock-in
period. Cloud computing services should have the capability to integrate smoothly with the
on-premise IT.
Reliability and Availability: Cloud providers still lack round-the-clock service; this results
in frequent outages. It is important to monitor the service being provided using internal or
third-party tools. It is vital to have plans to supervise usage, SLAs, performance, robustness,
and business dependency of these services.
Performance and Bandwidth Cost: Businesses can save money on hardware but they have
to spend more for the bandwidth. This can be a low cost for smaller applications but can be
significantly high for the data-intensive applications. Delivering intensive and complex data
over the network requires sufficient bandwidth. Because of this, many businesses are waiting
for a reduced cost before switching to the cloud.
All these challenges should not be considered as road blocks in the pursuit of cloud
computing. It is rather important to give serious consideration to these issues and the possible
ways out before adopting the technology.
In February 2017, US tech giant Oracle predicted that as enterprise cloud is expected to
become the most secure place for IT processing with nearly 60 per cent IT organisations to
move their systems management to the cloud in 2017, India will be among top beneficiaries
from cloud computing.
India Inc has pledged R4.5 lakh crore for Digital India, which can create employment for
some 18 lakh people. A good number of them will be in cloud computing. With the launch of
100 Smart Cities, 500 rejuvenated cities and numerous projects to create industrial hubs, a
strong virtual backbone, which is possible with cloud technology, is a critical necessity to
take the development process to the next level.
The 2011 Standard is the most significant update of the standard for four years. It includes
information security 'hot topics' such as consumer devices, critical infrastructure, cybercrime
attacks, office equipment, spreadsheets and databases and cloud computing.
The 2011 Standard is aligned with the requirements for an Information Security Management
System (ISMS) set out in ISO/IEC 27000-seriesstandards, and provides wider and deeper
coverage of ISO/IEC 27002 control topics, as well as cloud computing, information leakage,
consumer devices and security governance.
In addition to providing a tool to enable ISO 27001 certification, the 2011 Standard provides
full coverage of COBIT v4 topics, and offers substantial alignment with other relevant
standards and legislation such as PCI DSS and the Sarbanes Oxley Act, to enable compliance
with these standards too.
The Standard is used by Chief Information Security Officers (CISOs), information security
managers, business managers, IT managers, internal and external auditors, IT service
providers in organizations of all sizes.
The 2011 Standard is available free of charge to members of the ISF. Non-members are able
to purchase a copy of the standard directly from the ISF.
ISO 27001 - This document provides the ISO standards of the requirements for
establishing, implementing, maintaining and continually improving an information security
management system within the context of the organization.
ISO 27002 - This document introduces the code of practice for information security
controls.
British Standard 7799 Part 3 - This set of guidelines is published by BSI Group for the
information security risk management.
COBIT - The Control Objectives for Information and related Technology (COBIT) is
published by the Standards Board of Information Systems Audit and Control Association
(ISACA) providing a control framework for the governance and management of enterprise
IT.
Common Criteria (also known as ISO/IEC 15408) - This set of evaluation criterias is
developed by and aligned with national security standards organisations of Australia, Canada,
France, Germany, Japan, Netherlands, New Zealand, Spain, UK and US.
ITIL (or ISO/IEC 20000 series) - This document introduces a collection of best practices
in IT service management (ITSM), and focuses on the service processes of IT and considers
the central role of the user.
Owner—The owner of the information is responsible for its protection. The owner
plays the role of determining the classification level, periodical review, and delegation.
Custodian—A custodian is the one delegated by the owner to maintain the information.
A custodian's role includes backup and restoration of the information and maintaining the
records.
User—A user is the person who uses the information. A user may be an employee, an
operator, or any third...
Control of hardware equipment by
1.identifying
2.Recording
3classifying
4.Inventory control
5.Monitoring
Barcode
A barcode (also bar code) is an optical, machine-readable, representation of data; the data
usually describes something about the object that carries the barcode. Traditional barcodes
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Compiled by Srinivas Kante Email: [email protected]
systematically represent data by varying the widths and spacings of parallel lines, and may be
referred to as linear or one-dimensional (1D). Later, two-dimensional (2D) variants were
developed, using rectangles, dots, hexagons and other geometric patterns, called matrix
codes or 2D barcodes, although they do not use bars as such. Initially, barcodes were only
scanned by special optical scanners called barcode readers. Later application software became
available for devices that could read images, such as smartphones with cameras.
An early use of one type of barcode in an industrial context was sponsored by the Association
of American Railroads in the late 1960s. Developed by General Telephone and
Electronics (GTE) and called KarTrak ACI (Automatic Car Identification), this scheme
involved placing colored stripes in various combinations on steel plates which were affixed to
the sides of railroad rolling stock. Two plates were used per car, one on each side, with the
arrangement of the colored stripes encoding information such as ownership, type of
equipment, and identification number. The plates were read by a trackside scanner, located for
instance, at the entrance to a classification yard, while the car was moving past. The project
was abandoned after about ten years because the system proved unreliable after long-term use
RFID circuit
IT Asset Management
IT Asset Management (ITAM) is “a set of business practices that incorporates IT assets
across the business units within the organization. It joins the financial, inventory, contractual
and risk management responsibilities to manage the overall life cycle of these assets
including tactical and strategic decision making”. Assets include all elements of software and
hardware that are found in the business environment.
IT asset management is sometimes referred to as IT inventory management because it
typically involves gathering detailed hardware and software inventory information which is
then used to make decisions about purchases and how assets are used. Having an accurate IT
asset inventory helps companies use their assets more effectively and avoid unnecessary asset
purchases by re-using existing resources. IT asset management also enables organizations to
lower the risks costs of unknowingly building new IT projects on outdated (or unknown)
infrastructure foundations.
IT Asset management is made effective using metadata and electronic records to track and
categorize the organization’s assets. Metadata is the description of the physical or digital asset
and any supporting information that is needed to inform asset management decisions. The
metadata depth can vary depending on the needs of the organization.
Network Controls
Network security is an over-arching term that describes that the policies and procedures
implemented by a network administrator to avoid and keep track of unauthorized access,
exploitation, modification, or denial of the network and network resources.
This means that a well-implemented network security blocks viruses, malware, hackers, etc.
from accessing or altering secure information.
The first layer of network security is enforced through a username/password mechanism,
which only allows access to authenticated users with customized privileges. When a user is
authenticated and granted specific system access, the configured firewall enforces network
policies, that is, accessible user services.
However, firewalls do not always detect and stop viruses or harmful malware, which may
lead to data loss. An anti-virus software or an intrusion prevention system (IPS) is
implemented to prevent the virus and/or harmful malware from entering the network.
Network security is sometimes confused with information security, which has a different
scope and relates to data integrity of all forms, print or electronic
Modem
A modem is a network device that both modulates and demodulates analog carrier signals
(called sine waves) for encoding and decoding digital information for processing. Modems
accomplish both of these tasks simultaneously and, for this reason, the term modem is a
combination of "modulate" and "demodulate."
Repeater
A repeater is a network device that retransmits a received signal with more power and to an
extended geographical or topological network boundary than what would be capable with the
original signal.
Switch
A switch, in the context of networking is a high-speed device that receives incoming data
packets and redirects them to their destination on a local area network (LAN). A LAN switch
operates at the data link layer (Layer 2) or the network layer of the OSI Model and, as such it
can support all types of packet protocols.
Hub
A hub, also called a network hub, is a common connection point for devices in a network.
Hubs are devices commonly used to connect segments of a LAN. The hub contains
multiple ports. When a packetarrives at one port, it is copied to the other ports so that all
segments of the LAN can see all packets
Gateway
In computer networking and telecommunications, a gateway is a component that is part of
two networks, which use different protocols. The gateway will translate one protocol into the
other. A router is a special case of a gateway.
Gateways, also called protocol converters, can operate at any network layer. The activities of
a gateway are more complex than that of the router or switch as it communicates using more
than one protocol.
Both the computers of internet users and the computers that serve pages to users are host
nodes. The nodes that connect the networks in between are gateways. These are gateway
nodes:
the computers that control traffic between company networks
the computers used by internet service providers (ISPs) to connect users to the
internet
Computer Network | Layers of OSI Model
OSI stands for Open Systems Interconnection. It has been developed by ISO –
‘International Organization of Standardization‘, in the year 1974. It is a 7 layer
architecture with each layer having specific functionality to performed. All these 7 layers
work collaboratively to transmit the data from one person to another across the globe.
the form of bits.It is responsible for the actual physical connection between the devices.
When receiving data, this layer will get the signal received and convert it into 0s and 1s and
send them to the Data Link layer, which will put the frame back together.
1. Bit synchronization: The physical layer provides the synchronization of the bits
by providing a clock. This clock controls both sender and receiver thus providing
synchronization at bit level.
1. Bit rate control: The Physical layer also defines the transmission rate i.e. the
number of bits sent per second.
2. Physical topologies: Physical layer specifies the way in which the different,
devices/nodes are arranged in a network i.e. bus, star or mesh topolgy.
3. Transmission mode: Physical layer also defines the way in which the data flows
between the two connected devices. The various transmission modes possible are:
Simplex, half-duplex and full-duplex.
* Hub, Repeater, Modem, Cables are Physical Layer devices.
** Network Layer, Data Link Layer and Physical Layer are also known as Lower
Layers or Hardware Layers.
3. Flow Control: The data rate must be constant on both sides else the data may
get corrupted thus , flow control coordinates that amount of data that can be sent
before receiving acknowledgement.
4. Access control: When a single communication channel is shared by multiple
devices, MAC sub-layer of data link layer helps to determine which device has
control over the channel at a given time.
* Packet in Data Link layer is referred as Frame.
** Data Link layer is handled by the NIC (Network Interface Card) and device drivers of host
machines.
*** Switch & Bridge are Data Link Layer devices.
Internet protocol security (IPsec) is a set of protocols that provides security for Internet
Protocol. It can use cryptography to provide security. IPsec can be used for the setting up of
virtual private networks (VPNs) in a secure manner.
Authentication Header (AH): This authenticates the sender and it discovers any changes
in data during transmission.
Encapsulating Security Payload (ESP): This not only performs authentication for the
sender but also encrypts the data being sent.
There are two modes of IPsec:
Tunnel Mode: This will take the whole IP packet to form secure communication between
two places, or gateways.
Transport Mode: This only encapsulates the IP payload (not the entire IP packet as in
tunnel mode) to ensure a secure channel of communication.
IDS
Stands for "Intrusion Detection System." An IDS monitors network traffic for suspicious
activity. It may be comprised of hardware, software, or a combination of the two. IDSes are
similar to firewalls, but are designed to monitor traffic that has entered a network, rather than
preventing access to a network entirely. This allows IDSes to detect attacks that originate
from within a network.
An intruder detection systems can be configured for either a network or a specific device. A
network intrusion detection system (NIDS) monitors inbound and outbound traffic, as well as
data transfers between systems within a network. NIDSes are often spread out across several
different points in a network to make sure there a no loopholes where traffic may be
unmonitored.
An IDS configured for a single device is called a host intrusion detection system, or HIDS. It
monitors a single host for abnormal traffic patterns. For example, it may look for
known viruses or malware in both inbound and outbound traffic. Some HIDSes even
check packets for important system files to make sure they are not modified or deleted.
Both network and host IDSes are designed to detect intrusions and sound an alert. This alert
may be sent to a network administrator or may be processed by an automated system. A
system that automatically handles intrusion alerts is called a reactive IDS or an intrusion
prevention system (IPS).
Firewall
A firewall is software used to maintain the security of a private network. Firewalls block
unauthorized access to or from private networks and are often employed to prevent
unauthorized Web users or illicit software from gaining access to private networks connected
to the Internet. A firewall may be implemented using hardware, software, or a combination of
both.
A firewall is recognized as the first line of defense in securing sensitive information. For
better safety, the data can be encrypted.
Packet Filtering: Firewalls filter packets that attempt to enter or leave a network and
either accept or reject them depending on the predefined set of filter rules.
Application Gateway: The application gateway technique employs security methods
applied to certain applications such as Telnet and File Transfer Protocol servers.
Threat
A threat, in the context of computer security, refers to anything that has the potential to cause
serious harm to a computer system. A threat is something that may or may not happen, but
has the potential to cause serious damage. Threats can lead to attacks on computer systems,
networks and more.
Threats are potentials for vulnerabilities to turn into attacks on computer systems, networks,
and more. They can put individuals’ computer systems and business computers at risk, so
vulnerabilities have to be fixed so that attackers cannot infiltrate the system and cause
damage.
Threats can include everything from viruses, trojans, back doors to outright attacks from
hackers. Often, the term blended threat is more accurate, as the majority of threats involve
multiple exploits. For example, a hacker might use a phishing attack to gain information
about a network and break into a network.
A threat and a vulnerability are not one and the same. A threat is a person or event that has the
potential for impacting a valuable resource in a negative manner. A vulnerability is that
quality of a resource or its environment that allows the threat to be realized. An armed bank
robber is an example of a threat. A bank teller is an example of a valuable resource that may
be vulnerable during a bank robbery. Bullet-proof glass between the robber and the teller
denies the robber the opportunity to shoot the teller. The threat remains present, but one of its
harmful effects (a gun shot) has been mitigated by a protection mechanism (the glass).
In system and network security, the threats remain present but are mitigated through the
proper use of security features and procedures. Mitigation is any effort to prevent the threat
from having a negative impact, or to limit the damage where total prevention is not possible,
or to improve the speed or effectiveness of the recovery effort.
Hardware and software systems and the data they process can be vulnerable to a wide variety
of threats. The selection of security features and procedures must be based not only on
general security objectives but also on the specific vulnerabilities of the system in question in
light of the threats to which the system is exposed. It is possible to over-protect, which only
wastes resources and inconveniences users.
As you can see, there is a relationship between threats and vulnerabilities. Sometimes it is
easier to examine each potential threat and determine the extent to which you are vulnerable
(e.g. fire, flood, earthquake). In other cases it is easier to look for potential vulnerabilities
with no particular threat in mind (e.g. improper mounting of equipment, media failure, data
entry error). In order to arrive at a complete risk assessment, both perspectives must be
examined. Threats and vulnerabilities are intermixed in the following list and can be referred
to collectively as potential "security concerns."
For ease of discussion and use, concerns can be divided into four
categories. Environmental concerns include undesirable site-specific chance occurrences such
as lightning, dust and sprinkler activation. Physical concerns include undesirable site-specific
personnel actions, either intentional or unintentional, such as theft, vandalism and trip
hazards. Site-Supportconcerns include foundational site aspects such as electrical power,
telephone service and climate control. These three categories of concerns are generally not
resolvable as part of system design and administration - they are more appropriately
addressed as part of facility design and maintenance, thereby encompassing all systems
present.
The final category, Technical concerns, includes insidious system-specific situations such as
improper system operation, malicious software and line tapping. The actual threats are few:
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
untrained and nefarious users and system calamities. It is far more useful to explore the many
avenues (vulnerabilities) open to these users and events, and to consider ways to prevent
these occurrences and/or provide for rapid recovery.
The following list is meant to be used as a starting point in any IT risk assessment. Each
potential concern must be evaluated for a particular site or system to determine the extent to
which it applies. The probability of its occurrence, coupled with the projected impact of the
event and the cost of the appropriate mitigation yields a prioritized list of security concerns
that should be addressed.
Environmental (undesirable site-specific chance occurrences)
Fire
Flood
Tsunami
Earthquake
Volcanic Eruptions
Lightning
Severe Weather
Smoke
Dust
Insects
Rodents
Chemical Fumes
Sprinkler Activation
Water Leakage - pipe breakage, hole in roof, condensation
Explosion - nearby gas line, chemical plant, tank farm, munitions depot
Vibration - nearby railroad track, jet traffic, construction site
Electromagnetic Interference - suggested by poor radio reception or jittery workstation
displays
Electrostatic Discharge - suggested by "sparking" to grounded objects
Physical (undesirable site-specific personnel actions)
Unauthorized Facility Access
Theft
Vandalism
Sabotage
Extortion
Terrorism / Bomb Threat
Labor Unrest - employees and support contractors
War / Civil Unrest
Improper Transportation - equipment dropped, submerged, exposed to weather or
X-rayed in transit
Improper Mounting/Storage - equipment exposed to bumps, kicks or weather
Spillage / Droppage - hazardous materials permitted near equipment (e.g. food, liquids)
Magnets / Magnetic Tools - can erase data or damage sensitive equipment
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Compiled by Srinivas Kante Email: [email protected]
Hardware Error / Failure [functionality] - hardware that stops providing the desired user
services/resources
Hardware Error / Failure [security] - hardware that stops providing the desired security
services/resources
Software Error / Failure [functionality] - software that stops providing the desired user
services/resources
Software Error / Failure [security] - software that stops providing the desired security
services/resources
Media Failure - storage media that stops retaining stored information in a
retrievable/intact manner
Data Remanence - storage media that retains stored information in a retrievable/intact
manner longer than desired (failure to totally erase)
Object Reuse - a system providing the user with a storage object (e.g. memory or disk
space) that contains useful information belonging to another user
Communications Failure / Overload - a communications facility that stops providing
service or is unable to provide service at the requested capacity
Communications Error - a communications facility that provides inaccurate service
Data Entry Error - a system accepting erroneous data as legitimate
Accidental Software Modification / Deletion - deleting or otherwise making unavailable
necessary software
Accidental Data Modification / Deletion - deleting or otherwise making unavailable
necessary data
Accidental Data Disclosure - inadvertently revealing sensitive data to an unauthorized
user
Repudiation - participating in a process or transaction but then denying having done so
Masquerading - participating in a process or transaction but posing as another user
Message Playback - recording a legitimate transmission for retransmission at a later time
in an attempt to gain unauthorized privileges
Message Flooding - generating an inordinately large quantity of transmissions in an
attempt to make a system or service unavailable due to overload
Line Tapping - connecting to a communications facility in an unauthorized manner in an
attempt to glean useful information
Electronic Emanations - information-bearing spurious emissions associated with all
electronic equipment (prevented by TEMPEST equipment or shielding)
Geo-location - a system inadvertently revealing the current physical location of a user
CYBER THREATS
Cyber stalking:
in conjunction with the more traditional form of stalking, where the offender harasses the
victim offline. There is no unified legal approach to cyberstalking, but many governments
have moved toward making these practices punishable by law.
DOMAIN NAMES:
IP address :
The Internet is a network of computers. Each computer on the said network has its own
distinct entity and presence. That is the reason why every computer is given a distinct
Electronic Address called the Internet Protocol address or in short IP address. This IP address
is given by numerical values like 202.54.15.75. The IP address is just like any telephone
number which identifies a particular computer on the Internet.
Domain Name :
Since it is not possible to remember each and every numerical value of an IP address, the
system of domain names evolved. Internet domain names, in a common man's language, are
used as an easy-to-remember alias which point to a specific IP address. The dominant purpose
of the domain name is simply to provide an easy method for remembering another's
electronic address. It's a unique name used to identify, among other things, a specific Web site.
Thus a typical domain name would be http:// www.iibf.org
Any domain name consist of two components, namely the top level domain name(TLD) and a
second level domain name. Thus in the said example, http://www.iibf.org, ".org" would be the
top level domain name while "iibf" would be second level domain name.
As on date, there are two categories of top level domain names. In the first category comes
the domain names .com, .net, .org, .edu. When the system of registering domain names began,
the norms were that the .com name is to be given to commercial organizations, while others
such as .org, .net, .gov and .edu are to be assigned to non-commercial organizations, network
providers, government agencies and educational institutions respectively. However, as time
has passed, due to the enhanced volumes of domain name registrations, the said norms have
been abandoned and today anyone can, without any restriction of any kind whatsoever, can
register any domain name.
The second category of top level domain names is the country code TLDs denoted by a two
letter country code. For instance, the top level domain name for India is .in. The
responsibility for assigning the same is given in each country to a specified country domain
name registrar. In India, the TLD.in is registered by NCST at Bombay.
The domain names were initially registered by Network Solutions only, who had the sole
monopoly to register the said TLDs. This monopoly of Network Solutions continued for
many years and only in 1999, the Internet Corporation Assigned Names and Numbers
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Compiled by Srinivas Kante Email: [email protected]
(ICANN) allowed other accredited registrars to register domain names. Today there are more
than 100 registrars with whom one can register a TLD.
The unique feature of domain names is that the said domain names are given on "first come,
first served" basis. This feature of domain names gives rise to numerous legal issues and
disputes. Thus the important thing in domain names registration is speed. To take an example,
the domain name www.microsoft.org was available and was registered by Amit Mehrotra
much before Microsoft Corporation could think of it. This led to numerous ticklish legal
issues. Microsoft Corporation, despite having the trademark Microsoft, could not get the
domain name www.microsoft.org because of the "first come, first served" criteria of domain
name registration.
To put it simply, Domain names are indeed different from trademarks. While it is possible
that the same trademark may be registered by different persons in different categories and
different lines of businesses, it may be possible to only register one domain name
corresponding to such trademark. This aspect of domain names has led to numerous legal
problems.
Cyber Squatting:
The Internet history has shown that while some corporate players have been willing to and
have indeed coughed up money to get back their legitmate domain names, the recent trend is
more towards taking the cybersquatters by the horns and fighting them out by legal processes.
Courts throughout the world, including in India, have been proactive and have been granting
injunctions to stop cybersquatters from operating their web sites.
The latest breath of fresh air in the fight against Cybersquatting has been the Uniform
Domain Name Dispute Resolution Policy which has been duly approved by ICANN. Under
the said Domain Names Dispute Resolution Policy, a summary procedure is adopted to
adjudicate the complaint of any complainant relating to any domain name on payment of
processing fees. This policy has been in operation since the end of last year.
Under the said policy, Indian companies are also beginning to get back their legitimate
domain names. The domain name www.theeconomictimes.com and www.timesofindia.com
have been won back under the said policy. Two recent success for Indian Companies under
the said policy include winning back the domain names www.tata.org and
www.philipsindia.com by TATA and Philips India respectively.
Cyber Extortion
Cyberextortion is a crime involving an attack or threat of an attack coupled with a demand for
money or some other response in return for stopping or remediating the attack.
Cyber-extortion can come in many different forms, but at its simplest, it is when someone
online threatens some sort of harm unless you meet their demands.
For example, the cybercriminal may use "ransomware" to encrypt your data, which means
you can't read your data without the encryption key – and the cybercriminal will withhold this
key until payment is made.
Today, distributed denial-of-service (DDoS) attacks are the bread and butter of cyber
extortionists. This is an attack where…
A hacker overwhelms a target’s server with malicious traffic. Typically, the attacker will use a
botnet (i.e., a network of infected computers) to generate a flood of traffic on the server.
The traffic sends more connection requests than a server can handle. Or, the botnet sends the
target huge amounts of data to use up its bandwidth
.
The target’s site is shut down. Believe it or not, some people pay extortionists to silence
websites they don’t like. Shutting down a small site or keeping a small organization offline
for a week can cost as little as 10000/-
If a business doesn’t meet the extortionist’s demands, the hacker could keep the site offline
long enough to run the business into the ground. Or, the hacker may be able to remotely
access control panels and start deleting files necessary to keep the site or business running.
Any of your…
Websites.
Computer systems.
Severs.
The attackers will only cease and desist when their demands have been met. Because most
small businesses operate with the help of computers, cyber extortion is a growing problem.
Cyber warfare
Cyber Terrorism
A premeditated attack against a computer system, computer data, programs and other
information with the sole aim of violence against clandestine agents and subnational groups.
The main aim behind cyber terrorism is to cause harm and destruction.
Cyber terrorism can be explained as internet terrorism. With the advent of the internet,
individuals and groups are misusing the anonymity to threaten individuals, certain groups,
religions, ethnicities or beliefs. Cyber terrorism can be broadly categorized under three major
categories:
Simple: This consists of basic attacks including the hacking of an individual system.
Advanced: These are more sophisticated attacks and can involve hacking multiple
systems and/or networks.
Complex: These are coordinated attacks that can have a large-scale impact and make use
of sophisticated tools
SOFTWARE ATTACKS by
Virus
A virus is a type of malicious software (malware) comprised of small pieces of code attached
to legitimate programs. When that program runs, the virus runs.
Viruses are malicious programs that spread throughout computer files without user
knowledge. Most widespread virus infections spread through email message attachments that
activate when opened. The vicious cycle of a virus perpetuates as infected emails are
forwarded to multiple users. Viruses also spread through shared media, such as Universal
Serial Bus (USB) drives.
Initially created as pranks, viruses are responsible for widespread and significant computer
system and file destruction. Installing anti-virus software helps prevent, block or remove
previously installed viruses
Worm
A worm is a type of malicious software (malware) that replicates while moving across
computers, leaving copies of itself in the memory of each computer in its path.
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
A worm locates a computer’s vulnerability and spreads within its connected network like an
infection, while continually seeking new vulnerabilities. Like viruses, worms often originate
from e-mail attachments that appear to be from trusted senders. Worms then spread to a user’s
contacts via his e-mail account and address book.
Some worms spread and then do nothing while tthers cause harm. In such cases, the worm’s
code is known as payload.
Malicious software, commonly known as malware, is any software that brings harm to a
computer system. Malware can be in the form of worms, viruses, trojans, spyware, adware
and rootkits, etc., which steal protected data, delete documents or add software not approved
by a user.
Malware is software designed to cause harm to a computer and user. Some forms of malware
“spy” on user Internet traffic. Examples include spyware and adware. Spyware monitors a
user’s location and if enabled, it can capture sensitive information, e.g., credit card numbers,
promoting identity theft. Adware also acquires user information, which is shared with
advertisers and then integrated with unwanted, triggered pop-up ads.
Worms and viruses behave differently, as they can quickly proliferate and undermine an
entire computer system. They also may perform unsavory activities from a user’s computer
without the user’s knowledge. In the wake of a virus or worm, a computer system can
experience significant damage.
Anti-malware should determine if there are threats by scanning a computer and removing
them, if found. Prevention is better than corrective action after infection. Although anti-virus
programs should be continually enabled and updated, certain types of threats, like spyware,
often make their way into a computer system.
At all times, a firewall should be in place for additional security. Multiple, compatible
protective sources are encouraged as additional insurance against malware.
Adware
Adware is free computer software that contains commercial advertisements. Adware
programs include games, desktop toolbars or utilities. Commonly, adware is Web-based and
collects Web browser data to target advertisements, especially pop-ups.
Uninstalling adware generally requires anti-adware software. A variety of free and paid
versions are available, but licensed adware is the most reliable, aggressive and recommended.
Anti-adware software is also included in virus scanning packages.
Trojan Horse
A Trojan horse is a seemingly benign program that when activated, causes harm to a
computer system.
Backdoor Trojan: opens a back door for a user to access a victim’s system at a later time
Downloader: This Trojan downloads malicious software and causes harm to the victim’s
computer system.
Infostealer: This Trojan attempts to steal information from the victim’s computer.
Remote Access Trojan (RAT): This can be hidden in games or other programs of a
smaller variety and give the attacker control of the victim’s computer.
Data Sending Trojan: This gives the perpetrator sensitive information like passwords or
other information programmed to be hijacked.
Destructive Trojan: This destroys the victim’s files.
Proxy Trojan: As a proxy server, this allows the attacker to hijack a victim’s computer
and conduct illegal activities from the victim’s computer.
Spyware
Spyware is infiltration software that secretly monitors unsuspecting users. It can enable a
hacker to obtain sensitive information, such as passwords, from the user's computer. Spyware
exploits user and application vulnerabilities and is often attached to free online software
downloads or to links that are clicked by users.
Peer-to-peer (P2P) file sharing has increased the proliferation of spyware and its
ramifications.
Anti-spyware applications locate and remove spyware and are recommended as a
preventative line of defense against infiltration and damage.
Anti-virus software removes PC viruses, but anti-virus scans do not always detect spyware.
Spyware and cookies are similar, but spyware conducts infiltration activity continuously until
it is removed by specific anti-spyware tools.
Internet Bot
An Internet bot, in its most generic sense, is software that performs an automated task over
the Internet. More specifically, a bot is an automated application used to perform simple and
repetitive tasks that would be time-consuming, mundane or impossible for a human to
perform.
Bots can be used for productive tasks, but they are also frequently used for malicious
purposes.
The term "bot" comes from robot. An Internet bot may also be known as a Web robot or
WWW robot.
One of the best examples of a good bot is a search engine spider. Such bots troll the Web and
index new pages for a search engine. Other examples include the original Internet relay chat
bots and chatterbots.
Malicious bots are typically blended threats that come as part virus/worm, part bot and are
used in a identity theft or to launch denial of service attacks. This is especially prevalent in a
botnet, which is a grouping of computers that are all infected with a malicious bot. Other
illegal, or at least questionable uses, involve bots that harvest email addresses for spam,
scrape content or manipulate comments/votes on sites that allow user feedback.
Rootkit
Rootkits primarily aim at user-mode applications, but they also focus on a computer’s
hypervisor, the kernel, or even firmware. Rootkits can completely deactivate or destroy the
anti-malware software installed in an infected computer, thus making a rootkit attack difficult
to track and eliminate. When done well, the intrusion can be carefully concealed so that even
system administrators are unaware of it.
Rootkits may be also presented as a Trojan or even as a hidden file along with a seemingly
harmless file. This can be a graphic or even a silly application distributed via email. When the
victim clicks the program or graphic, the rootkits are installed on their system without their
knowledge.
Provide the attacker with complete backdoor access, permitting them to falsify or steal
documents.
Hide other malware, especially keyloggers. The keyloggers may then be used to access
and steal the victim's sensitive data.
Enable the attacker to use the infected machine as a zombie computer to trigger attacks
on others
Spoofing
The attacker (or spoofer) knows that if the recipient receives a spoofed email that appears to
be from a known source, it is likely to be opened and acted upon. So a spoofed email may
also contain additional threats like Trojans or other viruses. These programs can cause
significant computer damage by triggering unexpected activities, remote access, deletion of
files and more.
Incident management
An incident is an event that could lead to loss of, or disruption to, an organization's operations,
services or functions. Incident management (IcM) is a term describing the activities of an
organization to identify, analyze, and correct hazards to prevent a future re-occurrence. These
incidents within a structured organization are normally dealt with by either an incident
response team (IRT), an incident management team (IMT), or Incident Command System
(ICS). Without effective incident management, an incident can disrupt business operations,
information security, IT systems, employees, customers, or other vital business functions.
An incident is an event that could lead to loss of, or disruption to, an organization's operations,
services or functions. Incident management (IcM) is a term describing the activities of an
organization to identify, analyze, and correct hazards to prevent a future re-occurrence. If not
managed, an incident can escalate into an emergency, crisis or a disaster. Incident
management is therefore the process of limiting the potential disruption caused by such an
event, followed by a return to business as usual. Without effective incident management, an
incident can disrupt business operations, information security, IT systems, employees,
customers, or other vital business functions.[1]
Physical incident management
Incident management is considered to be much more than just the analysis of perceived
threats and hazards towards and organization in order to work out the risk of that event
occurring, and therefore the ability of that organization to conduct business as usual activities
during the incident. An important part of risk management process and business resilience
planning that Incident management is a real time physical activity.
The planning that has happened to formulate the response to an incident—be that a disaster,
emergency, crisis or accident—has been done so that effective business resilience can take
place to ensure minimal loss or damage whether that is to tangible or non tangible assets of
that organization. Efficient physical management of the incident—making best use of both
time and resources that are available and understanding how to get more resources from
outside the organization when needed by clear and timely liaison—ensure the plan is
implmented.
National Fire Protection Association states that incident management can be described as,
'[a]n IMS [incident management system] is "the combination of facilities, equipment,
personnel, procedures and communications operating within a common organizational
structure, designed to aid in the management of resources during incidents".
The physical incident management is the real time response that may last for hours, days, or
longer. The United Kingdom Cabinet Office have produced the National Recovery Guidance
(NRG), which is aimed at local responders as part of the implementation of the Civil
Contingencies Act 2004 (CCA). It describes the response as the following: "Response
encompasses the actions taken to deal with the immediate effects of an emergency. In many
scenarios, it is likely to be relatively short and to last for a matter of hours or days – rapid
implementation of arrangements for collaboration, co-ordination and communication are,
therefore, vital. Response encompasses the effort to deal not only with the direct effects of the
emergency itself (eg fighting fires, rescuing individuals) but also the indirect effects (eg
disruption, media interest)".
International Organization for Standardization (ISO), which is the world's largest developer
of international standards also makes a point in the description of its risk management,
principles and guidelines document ISO 31000:2009 that, "Using ISO 31000 can help
organizations increase the likelihood of achieving objectives, improve the identification of
opportunities and threats and effectively allocate and use resources for risk treatment".[7] This
again shows the importance of not just good planning but effective allocation of resources to
treat the risk.
Computer security incident management
Today, an important role is played by a Computer Security Incident Response Team (CSIRT),
due to the rise of internet crime, and is a common example of incident faced by companies in
developed nations all across the world. For example, if an organization discovers that an
intruder has gained unauthorized access to a computer system, the CSIRT would analyze the
situation, determine the breadth of the compromise, and take corrective action. Computer
forensics is one task included in this process. Currently, over half of the world’s hacking
attempts on Trans National Corporations (TNCs) take place in North America (57%). 23% of
attempts take place in Europe. Having a well-rounded Computer Security Incident Response
team is integral to providing a secure environment for any organization, and is becoming a
critical part of the overall design of many modern networking teams.
Business continuity and disaster recovery (BCDR) are closely related practices that describe
an organization's preparation for unforeseen risks to continued operations
The trend of combining business continuity and disaster recovery into a single term has
resulted from a growing recognition that business and technology executives need to
collaborate closely instead of developing plans in isolation.
Business continuity is more proactive and generally refers to the processes and procedures an
organization must implement to ensure that mission-critical functions can continue during
and after a disaster. BC involves more comprehensive planning geared toward long-term
challenges to an organization's success.
Disaster recovery is more reactive and comprises specific steps an organization must take to
resume operations following an incident. Disaster recovery actions take place after the
incident, and response times can range from seconds to days.
There are similarities between business continuity and disaster recovery. They both consider
various unplanned events, from cyberattacks to human error to a natural disaster. They also
have the goal of getting the business running as close to normal as possible, especially
concerning mission-critical applications. In many cases, the same team will be involved with
both BC and DR within an organization.
Importance of BCDR
As cyberthreats increase and the tolerance for downtime decreases, business continuity and
disaster recovery gain importance. These practices enable an organization to get back on its
feet after problems occur, reduce the risk of data loss and reputational harm, and improve
operations while decreasing the chance of emergencies.
BCDR professionals can help an organization and its employees achieve resiliency.
Developing a strategy is a complex process that requires research and analysis, including
conducting a business impact analysis (BIA) and a risk analysis, and developing BCDR plans,
tests, exercises and training.
Plans also provide information such as employee contact lists, emergency contact lists,
vendor lists, instructions for performing tests, equipment lists, and technical diagrams of
systems and networks.
BCDR expert Paul Kirvan notes several other reasons for the importance of business
continuity and disaster recovery planning:
Results of the BIA identify opportunities for process improvement and ways the
organization can use technology better;
The plan serves as a reference document for use in product planning and design,
service design and delivery, and other activities.
An organization should strive for continual improvement, driven by the BCDR process.
BC and DR plans have updated contact lists, of both employees and external stakeholders,
and specific procedures for how to respond to particular situations.
Good business continuity and disaster recovery plans are clear about the varying levels of
risks to the organization; provide well-defined and actionable steps for resilience and
recovery; protect the organization's employees, facilities and brand; include a
communications plan; and are comprehensive in detailing actions from beginning to end.
A BCDR policy is an important initial step. The policy sets the foundation for the process and
typically covers the scope of the business continuity management system, which employees
are responsible for it, and the activities performed such as plan development and business
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
impact analysis. The policy aspect is often overlooked, but it is an important business
continuity auditing item.
Developing the BCP and disaster recovery plan typically starts by gathering BCDR team
members and performing a risk analysis and BIA. The organization identifies the most critical
aspects of the business, and how quickly and to what extent they need to be running after an
incident. After the organization writes the step-by-step procedures, the documents should be
consistently tested, reviewed and updated.
While certain aspects of the process will involve select members of the organization, it's
important that everyone understand the plan and is included at some point. A test of the
BCDR plan, for example, is a good way to incorporate the entire organization.
The role of risk analysis, business impact analysis and BCDR strategies
Determining internal and external risks is important to the business continuity and disaster
recovery process. The risk analysis identifies risks and the likelihood they will occur, as well
as the potential damage they could cause. This data is used in conjunction with results of the
business impact analysis.
The BIA identifies the mission-critical functions an organization must maintain or restore
following an incident and the resources needed to support those functions. It's important to
gain management support in the undertaking of a BIA, given the intensity of the process. The
BIA is a way for an organization to learn about itself and details opportunities for
improvement.
An organization uses risk analysis and business impact analysis data to determine business
continuity and disaster recovery strategies and the appropriate responses. Each strategy is
turned into a series of actions that will help achieve operational recovery, such as data
replication, failing over to a cloud-based service, activating alternate network routes and
working remotely.
The change management process contains six major activities, according to Kirvan:
However, testing requires time, funding, management support and employee participation.
The testing process also includes pretest planning, training test participants and reporting on
the test.
Tests can range from simple to complex. A plan review involves a detailed discussion and
examination of the document, with an eye on what's missing or problematic. A tabletop test
brings together participants to walk through the plan steps, also looking for missing
information and errors. A simulation test marks a full run-through of the plan, using backup
systems and recovery sites.
Business continuity and disaster recovery planning trends, standards and vendors
BCDR is not just for enterprises anymore. Using the cloud -- disaster recovery as a service
(DRaaS) -- makes DR more accessible for smaller organizations. A strong DRaaS vendor can
provide infrastructure and expertise on BCDR planning. An organization must be careful
when selecting its DRaaS provider to ensure it meets its needs.
Standards continue to be an emerging trend, with many developed in recent years from such
organizations as the International Organization for Standardization (ISO) and the
International Electrotechnical Commission (IEC):
Financial Industry Regulatory Authority 4370: Business continuity for banking and
finance
BCDR software also helps an organization build its business continuity and disaster recovery plans, by
facilitating business impact analyses or providing plan templates. Some products have an automated emergency
Key vendors in the market include eBRP Solutions Network, Everbridge, IBM, Strategic BCP and Sungard
Availability Services. Prices range from hundreds of dollars to hundreds of thousands of dollars.
Another option is to outsource the organization's BCDR needs to a consulting firm that can provide assessments,
plan development and maintenance, and training. It's incumbent upon the business to analyze its needs before
selecting a BCDR firm, nailing down such information as what it wants to outsource, what services it expects of
the vendor, the risks of an outsourcing agreement and how much it plans to spend.
1. Will the organization's computerized systems be available for the business at all
times when required? (Availability)
1. Will the information in the systems be disclosed only to authorized users?
(Confidentiality)
2. Will the information provided by the system always be accurate, reliable, and
timely? (Integrity).
The performance of an IS Audit covers several facets of the financial and organizational
functions of our Clients. The diagram to the right gives you an overview of the Information
Systems Audit flow: From Financial Statements to the Control Environment and Information
Systems Platforms.
1. Responsibility: The Audit Charter should define the mission, aims, goals and
objectives of the Information System Audit. At this stage we also define the Key
Performance Indicators and an Audit Evaluation process;
1. Authority: The Audit Charter should clearly specify the Authority assigned to
the Information Systems Auditors with relation to the Risk Assessment work that will
be carried out, right to access the Client’s information, the scope and/or limitations to
the scope, the Client’s functions to be audited and the auditee expectations; and
2. Accountability: The Audit Charter should clearly define reporting lines,
appraisals, assessment of compliance and agreed actions.
The Audit Charter should be approved and agreed upon by an appropriate level within the
Client’s Organization.
See Template for an Audit Charter/ Engagement Letter here.
In addition to the Audit Charter, we should be able to obtain a written representation (“Letter
of Representation”) from the Client’s Management acknowledging:
1. Their responsibility for the design and implementation of the Internal Control
Systems affecting the IT Systems and processes
1. Their willingness to disclose to the Information Systems Auditor their
knowledge of irregularities and/or illegal acts affecting their organisation pertaining
to management and employees with significant roles within the internal audit
department.
2. Their willingness to disclose to the IS Auditor the results of any risk assessment
that a material misstatement may have occurred
See a Template for a Letter of Representation here.
PHASE 2 – Risk Assessment and Business Process Analysis
Risk is the possibility of an act or event occurring that would have an adverse effect on the
organisation and its information systems. Risk can also be the potential that a given threat
will exploit vulnerabilities of an asset or group of assets to cause loss of, or damage to, the
assets. It is ordinarily measured by a combination of effect and likelihood of occurrence.
More and more organisations are moving to a risk-based audit approach that can be adapted
to develop and improve the continuous audit process. This approach is used to assess risk and
to assist an IS auditor’s decision to do either compliance testing or substantive testing. In a
risk based audit approach, IS auditors are not just relying on risk. They are also relying on
internal and operational controls as well as knowledge of the organisation. This type of risk
assessment decision can help relate the cost/benefit analysis of the control to the known risk,
allowing practical choices.
The process of quantifying risk is called Risk Assessment. Risk Assessment is useful in
making decisions such as:
Control Risk: Control risk is the risk that an error which could occur in an audit area, and
which could be material, individually or in combination with other errors, will not be
prevented or detected and corrected on a timely basis by the internal control system. For
example, the control risk associated with manual reviews of computer logs can be high
because activities requiring investigation are often easily missed owing to the volume of
logged information. The control risk associated with computerised data validation procedures
is ordinarily low because the processes are consistently applied. The IS auditor should assess
the control risk as high unless relevant internal controls are:
Identified
Evaluated as effective
Tested and proved to be operating appropriately
Detection Risk: Detection risk is the risk that the IS auditor’s substantive procedures will not
detect an error which could be material, individually or in combination with other errors. In
determining the level of substantive testing required, the IS auditor should consider both:
A risk based approach to an Information Systems Audit will enable us to develop an overall
and effective IS Audit plan which will consider all the potential weaknesses and /or absence
of Controls and determine whether this could lead to a significant deficiency or material
weakness.
In order to perform an effective Risk Assessment, we will need to understand the Client’s
Business Environment and Operations. Usually the first phase in carrying out a Risk Based IS
Audit is to obtain an understanding of the Audit Universe. In understanding the Audit
Universe we perform the following:
In the performance of Audit Work the Information Systems Audit Standards require us t o
provide supervision, gather audit evidence and document our audit work. We achieve this
objective through:
Establishing an Internal Review Process where the work of one person is reviewed
by another, preferably a more senior person.
We obtain sufficient, reliable and relevant evidence to be obtained through
Inspection, Observation, Inquiry, Confirmation and recomputation of calculations
We document our work by describing audit work done and audit evidence gathered
to support the auditors’ findings.
Based on our risk assessment and upon the identification of the risky areas, we move ahead to
develop an Audit Plan and Audit Program. The Audit Plan will detail the nature, objectives,
timing and the extent of the resources required in the audit.
See Template for a Sample Audit Plan.
Based on the compliance testing carried out in the prior phase, we develop an audit program
detailing the nature, timing and extent of the audit procedures. In the Audit Plan various
Control Tests and Reviews can be done. They are sub-divided into:
COBIT helps meet the multiple needs of management by bridging the gaps between business
risks, control needs and technical issues. It provides a best practices framework for managing
IT resources and presents management control activities in a manageable and logical structure.
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
This framework will help optimise technology information investments and will provide a
suitable benchmark measure.
The Framework comprises a set of 34 high-level Control Objectives, one for each of the IT
processes listed in the framework. These are then grouped into four domains: planning and
organisation, acquisition and implementation, delivery and support, and monitoring. This
structure covers all aspects of information processing and storage and the technology that
supports it. By addressing these 34 high-level control objectives, we will ensure that an
adequate control system is provided for the IT environment. A diagrammatic representation of
the framework is shown below.
We shall apply the COBIT framework in planning, executing and reporting the results of the
audit. This will enable us to review the General Controls Associated with IT Governance
Issues. Our review shall cover the following domains;
1. Data Origination controls are controls established to prepare and authorize data
to be entered into an application. The evaluation will involve a review of source
document design and storage, User procedures and manuals, Special purpose forms,
Transaction ID codes, Cross reference indices and Alternate documents where
The Information Systems (IS) audit group assesses the University's critical systems,
technology architecture and processes to assure information assets are protected, reliable,
available and compliant with University policies and procedures, as well as applicable laws
and regulations. We emphasize the importance of mitigating security risks during our audit
coverage of the University’s application, operating and networking systems. Through our
integrated and IT governance audits, we evaluate information technology’s impact on the
University’s processes and its abilities to achieve its goals and objectives. Our evaluations are
objective and professional, utilizing COBIT (Control Objectives for Information and related
Technology) framework, an international standard for good IT control practices.
In India, the financial system is regulated with the help of independent regulators, associated
with the field of insurance, banking, commodity market, and capital market and also the field
of pension funds. On the other hand, the Indian Government is also known for playing a
significant role in controlling the field of financial security and also influencing the roles of
such mentioned regulators. You must be aware of the regulatory bodies and their functions,
before a final say. The most prominent of all is RBI or Reserve Bank of India. Let us look in
detail about various Financial Regulatory Bodies in India.
Reserve Bank of India : Reserve Bank of India is the apex monetary Institution of India. It is
also called as the central bank of the country.
The Central Office is where the Governor sits and is where policies are formulated. Though
originally privately owned, since nationalization in 1949, the Reserve Bank is fully owned by
the Government of India.
Apart from RBI, SEBI also forms a major part under the financial
body of India. This is a regulator associated with the security markets in Indian Territory.
Established in the year 1988, the SEBI Act came into power in the year 1992, 12th April. The
board comprises of a Chairman, Whole time members, Joint secretary, member appointed,
Deputy Governor of RBI, secretary of corporate affair ministry and also part time member.
There are three groups, which fall under this category, and those are the investors, the security
issuers and market intermediaries.
Other than the financial bodies mentioned above, FMC also plays a
major role. It is the chief regulator of the commodity(MCX, NCDEX, NMCE, UCX etc) of
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
the Indian futures market. As per the latest news feed, it has regulated the amount of Rs. 17
trillion, under the commodity trades. Headquarter is located in Mumbai, and the financial
regulatory agency is working in collaboration with the Finance Ministry. The chairman of
FMC works together with the Members of the same organization to meet the required ends.
The main aim of this body is to advise the Central Government on matters of the Forwards
Contracts Act, 1952.
The Reserve Bank of India issued new guidance in April 2011 for banks to mitigate the risks
of use of information technology in banking operations. RBI guidelines are result of the
Working Group's recommendations on information security, electronic banking, technology
risk management and cyber fraud. The Working Group was formed under the chairmanship of
G. Gopalakrishna, the executive director of RBI in April 2010.
The guidance is largely driven by the need for mitigating cyber threats emerging from
increasing adoption of IT by commercial banks in India.
to reputation risks to the banks. Inadequate technology implementation can also induce
strategic risk in terms of strategic decision making based on inaccurate data/information.
Compliance risk is also an outcome in the event of non-adherence to any regulatory or legal
requirements arising out of the use of IT. These issues ultimately have the potential to impact
the safety and soundness of a bank and in extreme cases may lead to systemic crisis.
Keeping in view the changing threat milieu and the latest international standards, it was felt
that there was a need to enhance RBI guidelines relating to the governance of IT, information
security measures to tackle cyber fraud apart from enhancing independent assurance about
the effectiveness of IT controls. To consider these and related issues, RBI announced the
creation of a Working Group on Information Security, Electronic Banking, Technology Risk
Management and Tackling Cyber Fraud in April, 2010. The Group was set up under the
Chairmanship of the Executive Director Shri.G.Gopalakrishna.
The Group delved into various issues arising out of the use of Information Technology in
banks and made its recommendations in nine broad areas. These areas are IT Governance,
Information Security, IS Audit, IT Operations, IT Services Outsourcing, Cyber Fraud,
Business Continuity Planning, Customer Awareness programmes and Legal issues.
Major Recommendations of the Working Group
The Group felt that the recommendations are not “one-size-fits-all” and the implementation
of these recommendations need to be based on the nature and scope of activities engaged by
banks and the technology environment prevalent in the bank and the support rendered by
technology to the business processes.
On IT Governance:
Banks need to formulate a Board approved IT strategy/plan document. An IT policy
needs to be framed for regular management of IT functions and ensure that detailed
documentation in terms of procedures and guidelines exists and are implemented. The
strategic plan and policy need to be reviewed annually.
A need was felt to create an exclusive Board level IT Strategy Committee with a
minimum of two directors as members, one of whom should be an independent director. All
members of the IT Strategy Committee would need to be technically competent while at least
one member would need to have substantial expertise in managing/guiding technology
initiatives.
A need was felt for the position of CIO in banks, to be the key business player and play a
part in the executive decision-making function. The key role of the CIO would be to act as an
owner of the IT function and enable the alignment of business and technology.
IT Steering Committee needs to be created with representations from various IT
functions, HR, Legal and business functions as appropriate. The role of the IT Steering
Committee would be to assist the Executive Management in the implementation of the IT
strategy approved by the Board.
The IT Steering Committee should assess whether the IT Governance structure fosters
accountability, is effective and transparent, has well defined objectives and actions and
unambiguous responsibilities for each level in the organization.
The organizational structure for IT should be commensurate with the size, scale and
nature of business activities carried out by the bank and the underlying support provided by
information systems for business functions.
Key focus areas of IT Governance that need to be considered include strategic alignment,
value delivery, risk management, resource management and performance management.
Requirements for trained resources with requisite skill sets for the IT function need to be
understood and assessed appropriately. A periodic assessment of the training requirements for
human resources should be made to ensure that sufficient, competent and capable human
resources are available.
The Board needs to be adequately aware of IT resources and infrastructure available to
meet required strategic business objectives and ensure that a process is in place to record the
resources available/ potentially available to the bank.
Performance of IT function should be monitored to ensure delivery on time and within
budget, with appropriate functionality and with intended benefits.
Banks need to establish and maintain an enterprise information model to enable
applications development and decision-supporting activities, consistent with IT strategy. The
model should facilitate optimal creation, use and sharing of information by a business, in a
way that it maintains integrity, and is flexible, functional, cost-effective, timely, secure and
resilient to failure
There is also a need to maintain an “enterprise data dictionary” that incorporates the
organization’s data syntax rules. This should enable the sharing of data among applications
and systems, promote a common understanding of data among IT and business users and
preventing incompatible data elements from being created
Procedures to assess the integration and interoperability of complex IT processes such as
problem, change and configuration management need to exist, depending upon the extent of
technology leverage in a bank.
An appropriate programme and project management framework needs to
be implemented for the management of all IT projects, which ensures correct prioritization
and co-ordination
For managing project risks, a consistent and formally defined programme and project
management approach should be applied to IT projects that enable appropriate stakeholder
participation and monitoring of project risks and progress
For major projects, formal project risk assessment needs to be carried out and managed
on an ongoing basis
The bank-wide risk management policy or operational risk policy needs to include IT
related risks and the Risk Management Committee should periodically review and update the
same (at least annually).
IT function needs to support a robust and comprehensive Management Information
System with respect to various business functions as per business needs and in coordination
with business personnel so as to provide inputs for effective decision making by management
Components of well-known IT control frameworks such as COBIT as applicable to each
bank’s technology environment may be considered for implementation in a phased manner
providing a standardized set of terms and definitions that are commonly interpreted by all
stakeholders.
Effective IT control practices and their monitoring are required to avoid breakdowns in
internal control and oversight, increase efficiency, use resources optimally and increase the
effectiveness of IT processes.
Information on major IT projects that have a significant impact on the bank’s risk profile
and strategy needs to be reported to appropriate levels of management and undergo
appropriate strategic and cost/ reward analysis on a periodic basis.
Project level steering committees needs to be created to take responsibility for execution
of the project plan, achievement of outcomes and project completion.
An IT balanced scorecard may be considered for implementation, with approval from key
stakeholders, to measure IT performance along different dimensions such as financial aspects,
Banks need to grant authorisation for access to information assets only where a valid
business need exists and only for a definite time period for which the access is required.
Personnel with elevated system access privileges should be closely supervised.
Information security needs to be considered at all stages of an information asset’s (like
hardware, software) life-cycle which typically includes: planning and design; acquisition and
implementation; maintenance and support; and disposal so as to minimise exposure to
vulnerabilities.
Banks should have a process in place to verify job application information on all new
employees. The sensitivity of a particular job or access level may warrant additional
background and credit checks.
Banks should implement suitable physical and environment controls taking into
consideration threats, and based on the entity’s unique geographical location, building
configuration, neighboring entities, etc.
There is a vital need for initial, and ongoing, training/awareness programmes on
information security for employees and vendor personnel. There should also be a mechanism
to track the effectiveness of the training programmes periodically through an assessment
process designed for testing the understanding of relevant policies.
A robust incident management process needs to be in place to maintain the capability to
manage incidents within an enterprise, to enable containment of exposures and to achieve
recovery within a specified time period. Incidents could include aspects relating to misuse of
computing assets, information disclosure or events that threaten the continuance of business
processes.
A bank needs to have clear accountability mechanisms and communication plans (for
escalation and reporting to the Board and senior management and customer communication
where appropriate) to limit the impact of information security incidents. Institutions would
also need to pro-actively notify CERT-In/IDRBT/RBI regarding major cyber security
incidents.
There should be documented standards/procedures for administering an application
system, which are approved by the application owner and kept up-to-date. Access to the
application should be based on the principle of least privilege and “need to know”
commensurate with the job responsibilities. Adequate segregation of duties needs to be
enforced.
Every application affecting critical/sensitive information, for eg. impacting financial,
customer, control, risk management, regulatory and statutory aspects, must provide for
detailed audit trails/ logging capability with details like transaction id, date, time, originator
id , authorizer id, actions undertaken by a given user id, etc. Other details like logging IP
address of client machine, terminal identity or location also need to be available. Alerts
regarding use of the same machine for both maker and checker transactions need to be
considered. The logs/alerts/exception reports with regard to systems should be analyzed and
any issues need to be remedied at the earliest.
The audit trails should satisfy a bank’s business requirements apart from regulatory and
legal requirements. It should also be facilitating the conduct of audit, serving as forensic
evidence when required and assisting in dispute resolution including for non-repudiation
purposes. Audit trails should be secured to ensure the integrity of the information captured
and preservation of evidence.
Banks may obtain application integrity statements in writing from the application system
vendors providing for reasonable level of assurance about the application being free of
malware at the time of sale, free of any obvious bugs, and free of any covert channels in the
code (of the version of the application being delivered as well as any subsequent
versions/modifications done).
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
Data security measures need to be in place. Banks need to define and implement
procedures to ensure the integrity and consistency of all critical data stored in electronic form,
such as databases, data warehouses and data archives.
Direct back-end updates to database should not be allowed except during exigencies, in
the event of a genuine business need and after due authorization as per relevant policy
Any changes to an application system/data need to be justified by genuine business need
and approvals supported by documentation and subjected to a robust change management
process.
For all critical applications, either source code must be received from the vendor or a
software escrow agreement needs to be in place with a third party to ensure source code
availability in case the vendor goes out of business. It needs to be ensured that product
updates and programme fixes are also included in the escrow agreement.
Data transfer from one process to another or from one application to another, particularly
in respect of critical or financial applications, should not have any manual intervention in
order to prevent any unauthorized modification. The process needs to be automated and
properly integrated through “Straight Through Processing” methodology with an appropriate
authentication mechanism and audit trails.
In the event of data pertaining to Indian operations being stored and/or processed abroad,
for example, by foreign banks, there needs to be suitable controls like segregation of data and
strict access controls based on ‘need to know’ and robust change controls. The bank should be
in a position to adequately prove the same to the regulator. Regulator’s access to such
data/records and other relevant information should not be impeded in any manner and RBI
would have the right to cause an inspection to be made of the processing centre/data centre
and its books and accounts by one or more of its officers or employees or other persons.
Robust system security testing needs to be carried out.
Multi-tier application architecture needs to be implemented for critical e-banking systems
like internet banking which differentiate session control, presentation logic, server side input
validation, business logic and database access.
A bank needs to have a documented migration policy specifying a systematic process for
data migration and for ensuring data integrity, completeness and consistency. Explicit sign
offs from users/application owners need to be obtained after each stage of migration and also
after the migration process has been completed. Audit trails need to be available to document
the conversion, including data mappings and transformations.
Banks need to carry out due diligence with regard to new technologies/systems since
they can potentially introduce additional risk exposures
Any new business products introduced, along with the underlying information systems,
need to be assessed as part of a formal product approval process which incorporates, inter-alia,
security related aspects and fulfilment of relevant legal and regulatory prescriptions.
Cryptographic techniques need to be used to control access to critical and sensitive
data/information in transit and storage. Banks should only select encryption algorithms which
are well established international standards and which have been subjected to rigorous
scrutiny by an international community of cryptographers or approved by authoritative
professional bodies, reputable security vendors or government agencies.
Normally, a minimum of 128-bit SSL encryption is expected. Constant advances in
computer hardware, cryptanalysis and distributed brute force techniques may induce use of
larger key lengths periodically. It is expected that banks will properly evaluate security
requirements associated with their internet banking systems and other relevant systems and
adopt an encryption solution that is commensurate with the degree of confidentiality and
integrity required.
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
Banks need to scan frequently for vulnerabilities and address discovered flaws
proactively to avoid the likelihood of having their computer systems compromised.
Automated vulnerability scanning tools need to be used against all systems in their networks
on a periodic basis.
Banks need to have monitoring processes in place to identify suspicious events and
unusual behavioural patterns that could impact the security of IT assets. The strength of the
monitoring controls should be based on the criticality of an IT asset. A bank would need to
establish a clear allocation of responsibility for regular monitoring mechanism, and the tools
and processes in this regard need to be commensurate with the level of monitoring required.
Critical functions , for example relating to financial, regulatory and legal, MIS and risk
management, need to be done through proper application systems and not manually or in a
semi-automated manner through spreadsheets which pose risks relating to data integrity and
reliability. Use of spreadsheets in this regard should be restricted and should be replaced by
appropriate IT applications in a phased manner within a definite timeframe.
A robust process needs to be in place for “effective malware control”. Typical controls to
protect against malicious code use layered combinations of technology, policies and
procedures and training. The controls are of the preventive and detective/corrective in nature.
Establishing a robust network protection strategy and layered security based on the
principle of defence-in-depth is an absolute necessity for banks.
There should be arrangements for monitoring and reporting of the information security
condition of the organization, which are documented, agreed with top management and
performed regularly. Security related metrics can be used to measure security policy
implementation.
Given the multiplicity of devices and systems, banks should deploy suitable automated
tools for log aggregation and consolidation from multiple machines/systems and for log
correlation and analysis.
Security and Audit Processes of Critical service providers/vendors need to be assessed
regularly since ineffective third-party controls can weaken the ability of a bank to achieve its
control objectives.
Commercial banks should implement ISO 27001 based Information Security
Management System (ISMS) best practices for their critical functions. Additionally, other
reputed security/IT control frameworks may also be considered by banks.
Strong controls need to be initiated against any remote access facility. The management
should establish policies restricting remote access and be aware of all remote-access devices
attached to the bank’s systems. These devices should be strictly controlled.
Events that trigger the implementation of a business continuity plan may have security
implications. Risk assessments should consider the changing risks that appear in business
continuity scenarios and different security postures that may need to be established.
Information security assurance needs to be obtained through periodic penetration testing
exercises, audits and vulnerability assessments. The assurance work needs to be performed by
appropriately trained and independent information security experts/auditors. The strengths
and weaknesses of critical internet-based applications, other critical systems and networks
needs to be carried out before each initial implementation, and at least annually thereafter.
Any findings needs to be reported and monitored using a systematic audit remediation or
compliance tracking methodology.
Provision of various electronic banking channels like ATM/debit cards/internet
banking/phone banking should be issued only at the option of the customers based on specific
written or authenticated electronic requisition along with a positive acknowledgement of the
terms and conditions from the customer. A customer should not be forced to opt for services
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
in this regard. Banks should provide clear information to their customers about the risks and
benefits of using e-banking delivery services to enable customers to decide on choosing such
services.
In view of the proliferation of cyber attacks and their potential consequences, banks
should implement two-factor authentication for critical activities like fund transfers and
changing customer related details through internet banking facility.
The implementation of appropriate authentication methodologies should be based on an
assessment of the risk posed by the institution’s internet banking systems. The risk should be
evaluated in light of the type of customer (e.g., retail or corporate/commercial); customer
transactional capabilities (e.g., bill payment, fund transfer), the sensitivity of customer
information being communicated to the bank and the volume of transactions involved.
While not using the asymmetric cryptosystem and hash function is a source of legal risk,
the banks, at the least, need to implement dynamic two-factor authentication through user
id/password combination and second factor like (a) OTP/dynamic access code through
various modes like SMS over mobile phones or hardware token or (b) a digital signature,
through a card/token containing a digital certificate and associated private key (preferably for
corporate customers).
To enhance online processing security, confirmatory second channel procedures(like
telephony, SMS, email etc.) should be applied with regard to transactions above pre-set
values, creation of new account linkages, registration of third party payee details, changing
account details or revision to funds transfer limits. In devising these security features, the
bank should take into account their efficacy and differing customer preferences for additional
online protection.
Based on mutual authentication protocols, customers could also authenticate the bank’s
web site through security mechanisms such as personal assurance messages/images, exchange
of challenge response security codes and/or the secure sockets layer (SSL) server certificate
verification. In recent times, Extended Validation Secure Sockets Layer (EV-SSL)
Certificates are increasingly being used. It should, however, be noted that SSL does not
provide end-to-end encryption security at the application layer but is only designed to encrypt
data in transit at the network transport layer.
A risk based transaction monitoring or surveillance process needs to be put in place. The
banks may consider dynamic scoring models and related processes to trigger or alert
transactions which are not normal to improve preventive/detective capability. Study of
customer transaction behavioral patterns and stopping irregular transactions or obtaining prior
confirmation from customers for outlier transactions may be incorporated as part of the
process.
Chip based cards house data on microchips instead of magnetic stripes, making data
more difficult to steal and cards more difficult to reproduce. It is recommended that RBI may
consider moving over to chip based cards along with requiring upgradation of necessary
infrastructure like ATMs/POS terminals in this regard in a phased manner.
For debit / credit card transactions at the POS terminals, PIN based authorization system
needs to be put in place (without any looping) in place of the existing signature based system
and the non-PIN based POS terminals need to be withdrawn in a phased manner.
Given that control, security and legal issues on cloud computing are still evolving, a bank
needs to be cautious and carry out due diligence to assess the risks comprehensively before
considering cloud computing.
There needs to be forum of CISOs who can periodically interact and share experiences
regarding any information security threats. It is reported that a CISO forum is already
functional under IDRBT. The forum may, among other functions, endeavour to share good
practices, identify any specific information security issues and flag them to appropriate
stakeholders like the regulator, IBA etc.
There is a need for a system of information sharing akin to the functions performed by
FS-ISAC (Financial Services Information Sharing Agency) in the US. IDRBT as a sub-CERT
to the banking system can function as a nodal point for information sharing.
Accreditation and empanelment of security audit qualifications/certifications and security
audit vendors can be considered at a wider level by the Government of India/CERT-In or by
IDRBT for the banking sector.
In order to reduce the time, cost, and complexity of software assurance and to ensure its
security, sustainability and resilience and increase the effectiveness of the methods used by
the banking industry for software assurance, an initiative similar to FSTC Software Assurance
Initiative (SAI) in the US can be considered in India, possibly under the aegis of IDRBT
along with various stakeholders.
There is a need for IBA, IDRBT and reputed institutions like DSCI to collaborate and
develop security frameworks and detailed implementation methodologies and procedures for
the benefit of the banking sector, based on the information security related aspects covered in
this report.
There is an increasing need for specific detailed research in security of banking
technology and bringing out innovative and secure banking products in collaboration with
reputed academic bodies like the IITs. IDRBT can expand its activities/initiatives in this
regard.
Given the nature of the problem of cyber security, there needs to be engagement at a
wider level nationally and internationally, with the government, law enforcement agencies,
various industrial associations and academic institutions.
RBI can consider having a multi-disciplinary Standing Committee on Information
Security with representation from various stakeholders to consider new security related
developments and also legal developments, and based on the same, provide recommendations
for suitable updation of guidelines on periodic basis.
Collaborative efforts may also be made by reputed bodies like IDRBT, IIBF and DSCI
coordinated by IBA to create customized indigenous certification courses to certify specific
knowledge and skillsets in IT/information security areas for various categories of bank
personnel at operational and managerial levels so as to create a large and diverse pool of
requisite talent within the banking system.
On IT operations:
The Board of Directors and Senior Management should oversee the implementation of a
safe and sound IT operations environment. The policies and procedures defined as part of IT
operations should support a bank’s goals and objectives as well as follow statutory and
regulatory requirements.
IT operations include business services which are available to the internal or external
customers of the organization using IT as a service delivery component. Instances include
Mobile Banking and Internet Banking. IT Operations also include IT components which are
used to support IT Operations, which can be service desk application, ticketing tools, event
management tools etc. Banks may consider including test environment, quality assurance
environment and any other such environment besides production environment within the
scope of IT Operations.
Banks should analyze their IT operation environment, including technology, human
resources and implemented processes to identify threats and vulnerabilities and conduct a
periodic risk assessment. As part of risk identification and assessment, banks should identify
events or activities that could disrupt operations or negatively affect reputation or earnings
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
and assess compliance to regulatory requirements. Banks should define various attributes for
each risk component like probability of occurrence, financial impact etc. These attributes
along with the business process involved should be used to prioritize risk mitigation actions
and control framework.
IT Strategy as framework should provide feedback to IT operations on the services to be
supported, their underlying business processes, prioritization of these services etc. A
well-defined IT strategy framework will assist IT operations in supporting IT services as
required by the business and defined in SLAs.
Service Valuation is the mechanism that can be considered by banks to quantify the
services which are available to its customers (internal / external) and supported by IT
operations in financial terms. Service Valuation will assist the IT Operation Function to
showcase the involvement of the function in supporting the core business of the banks.
Demand Management process provides guidelines which may be used by banks to
understand the business processes IT operations support to identify, analyze and codify
Patterns of Business Activities (PBA) to provide sufficient basis for capacity requirement.
The components which should be considered when designing a new IT service or making
a change to the existing IT service include business processes, service level agreements, IT
infrastructure, IT environment etc.
Over the years, the IT infrastructure in banks has grown and developed, and there may
not be a clear picture of all the IT services currently being provided, and the consumers for
each service. In order to establish an accurate IT landscape it is recommended that an IT
Service Catalogue is defined, produced and maintained. The Service Catalogue can be
considered a repository that provides information on all the IT services supported by the IT
Operations framework.
Banks need to institute a Service Level Management process for planning, coordinating,
and drafting, agreeing, monitoring and reporting of service attributes used to measure the
quality of service. The framework needs to include guidelines for ongoing reviews of
service achievements to ensure that the required and cost-justifiable service quality is
maintained and gradually improved. The Service Level Management framework defined by
the banks should also have guidelines defined for logging and management including
escalation of complaints and compliments.
A Capacity Management process is required to ensure that cost-justifiable IT capacity for
IT services exists and matches the current and future business requirements as identified in
the Service Level Agreement. Banks adopting the capacity management process should
ensure that the framework encompasses all areas pertaining to technology i.e. hardware,
software, human resources, facilities etc.
The availability and reliability of IT services can directly influence customer satisfaction
and the reputation of banks. Availability Management is essential in ensuring IT delivers the
right level of service required by the business to satisfy its business objectives. When
defining Availability targets for a business service, banks should consider identifying Vital
Business Function (VBF).
Attributes that can be used by banks to report availability of IT services include
availability (in percentage), Mean Time between service incidents, Mean Time between
Failures and Mean Time to Repair.
Implementation of Service Asset and Configuration Management framework has cost and
resource implications and therefore there need to be strategic discussions about the priorities
to be addressed.
Banks need to implement a ‘change management’ process for handling any changes in
technology and processes to ensure that the changes are recorded, assessed, authorized,
remains responsible for understanding and monitoring the control environment of all service
providers that have access to the bank’s systems, records or resources.
Banks should establish a structure for management and control of outsourcing, based on
the nature, scope, complexity and inherent risk of the outsourced activity.
Management should include SLAs in the outsourcing contracts to agree and establish
accountability for performance expectations. SLAs must clearly formalize performance
criteria to measure the quality and quantity of service levels. For outsourced technology
operations, specific metrics may be defined around service availability, business continuity
and transaction security, in order to measure services rendered by the external vendor
organization.
Banks should evaluate the adequacy of the internal controls environment offered by the
service provider. Due consideration should be given to implementation by the service
provider of various aspects like information security policies and employee awareness of the
same, logical access controls, physical and environmental security and controls, controls for
handling data etc.
Outsourcing should not impede or interfere with the ability of the bank or the regulator in
performing its supervisory functions and objectives. As a practice, institutions should conduct
pre- and post- outsourcing implementation reviews. An institution should also review its
outsourcing arrangements periodically (atleast annually) to ensure that its outsourcing risk
management policies and procedures, and these guidelines, are effectively complied with.
An institution should, at least on an annual basis, review the financial and operational
condition of the service provider to assess its ability to continue to meet outsourcing
obligations.
Banks should also periodically commission independent audit and expert assessments on
the security and control environment of the service provider.
Banks should ensure that their business continuity preparedness is not compromised on
account of outsourcing.
Banks need to take effective steps to ensure that risks with respect to confidentiality and
security of data are adequately mitigated.
In the event of outsourcing of technology operations, the banks should subject the same
to enhanced and rigorous change management and monitoring controls since ultimate
responsibility and accountability rests with the bank.
Banks, while framing the viable contingency plan, need to consider the availability of
alternative service providers or the possibility of bringing the outsourced activity
back-in-house in an emergency (for example, where number of vendors for a particular
service is extremely limited) and the costs, time and resources that would be involved and be
prepared to take quick action, if warranted.
The engagement of service providers across multiple geographies exposes the
organization to country risk – economic, social and political reasons in the country that may
adversely affect the bank’s business and operations. Banks should proactively evaluate such
risk as part of the due diligence process and develop appropriate mitigating controls and as
required, an effective exit strategy.
Emerging technologies such as data center hosting, applications as a service and cloud
computing have given rise to unique legal jurisdictions for data and cross border regulations.
Banks should clarify the jurisdiction for their data and applicable regulations at the outset of
an outsourcing arrangement. This information should be reviewed periodically and in case of
significant changes performed by the service provider.
Banks should ensure that quality and availability of banking services to customers are not
adversely affected due to the outsourcing arrangements entered into by the bank. Banks need
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
to institute a robust grievance redressal mechanism, which should not be compromised in any
way due to outsourcing.
IBA may facilitate requisite data sharing between banks to maintain scoring information
for existing / new service providers which may include any fraud or major operational lapses
committed by the service providers.
Detailed service provider assessment and monitoring frameworks and best practices from
a banking context can be explored by IBA in collaboration with institutions like DSCI and
IDRBT.
On IS Audit:
To meet the responsibility to provide an independent audit function with sufficient
resources to ensure adequate IT coverage, the board of directors or its audit committee should
provide an internal audit function which is capable of evaluating IT controls adequately.
Banks should enable an adequately skilled composition of the Audit Committee to
manage the complexity of the IS Audit oversight. A designated member of the Audit
Committee needs to possess the relevant knowledge of Information Systems, IS Controls and
audit issues. The designated member should also have relevant competencies to understand
the ultimate impact of deficiencies identified in IT Internal Control framework by the IS
Audit function. The Board or its Audit Committee members should seek training to fill any
gaps in the knowledge related to IT risks and controls.
The Audit Committee should devote appropriate and sufficient time to IS audit findings
identified during IS Audits and members of the Audit Committee would need to review
critical issues highlighted and provide appropriate guidance to the bank’s management.
Banks should have a separate IS Audit function within the Internal Audit department led
by an IS Audit Head, assuming responsibility and accountability of the IS audit function,
reporting to the Chief Audit Executive (CAE) or Head of Internal Audit. Where the bank uses
external resources for conducting IS audit in areas where skills are lacking within the bank,
the responsibility and accountability for such external IS audits still remain with the IS Audit
Head and CAE.
IS Auditors should act independently of the bank's management. In all matters related to
the audit, the IS Audit should be independent of the auditee in both attitude and appearance.
IS Auditors should be professionally competent, having the skills, knowledge, training and
relevant experience to conduct an audit. IS Auditors should exercise due professional care,
which includes following professional auditing standards in conducting the audit.
Banks may decide to outsource the execution of segments of the audit plan to external
professional service providers, as per the overall audit strategy decided in co-ordination with
the CAE and the Audit Committee. The work outsourced shall be restricted to execution of
audits identified in the audit plan. Banks need to ensure that the overall ownership and
responsibility of the IS Audit including the audit planning process, risk assessment and follow
up of compliance remains within the Bank. External assistance may be obtained initially to
put in place necessary processes in this regard, if required.
An Audit Charter / Audit Policy is a document which guides and directs the activities of
the Internal Audit function. IS Audit, being an integral part of the Internal Audit function,
should also be governed by the same Audit Charter / Audit Policy. The audit policy should be
documented to contain a clear description of its mandate, purpose, authority and
accountability (of relevant members/officials in respect of the IS Audit i.e. IS Auditors, audit
management and the audit committee) and the relevant operating principles. The document
should be approved by the Board of Directors.
IS Audit policy/charter should be subjected to an annual review to ensure its continued
relevance and effectiveness.
The IS auditor should consider establishing a quality assurance process (e.g., interviews,
customer satisfaction surveys, assignment performance surveys etc.) to understand the
auditee’s needs and expectations relevant to the IS audit function. These needs should be
evaluated against the policy with a view to improving the service or changing the service
delivery or audit charter, as necessary.
Banks need to carry out IS Audit planning using the Risk Based Audit Approach. The
approach involves aspects like IT risk assessment methodology, defining the IS Audit
Universe, scoping and planning the audit, execution and follow up activities.
The IS Audit Universe can be built around the four types of IT resources and various IT
processes like application systems, information or data, infrastructure(technology and
facilities like hardware, operating systems, database management systems, networking,
multimedia, etc., and the environment that houses and supports them that enable the
processing of the applications) and people (internal or outsourced personnel required to plan,
organize, acquire, implement, support, monitor and evaluate the information systems and
services).
The IS Auditor must define, adopt and follow a suitable risk assessment methodology. A
successful risk-based IS audit program can be based on an effective scoring system arrived at
by considering all relevant risk factors. Banks should develop written guidelines on the use of
risk assessment tools and risk factors and review these guidelines with the Audit Committee
or the Board of directors. Risk assessment related guidelines will vary for individual banks
depending on their size, complexity, scope of activities, geographic diversity, and various
technologies/systems used.
The IS Audit Plan (either separately or as part of the overall internal audit plan) should be
a formal document, duly approved by the Audit Committee initially and during any
subsequent major changes. The Audit plan should be prepared so that it is in compliance with
appropriate external regulatory/legal requirements, in addition to well-known IS Auditing
Standards.
The IS Audit Head is responsible for the annual IS Audit Plan which is prepared based on
the scoping document and risk assessment. The Audit plan typically covers the overall audit
strategy, scoped audit areas, details of control objectives identified in the scoping stage,
sample sizes, frequency of audit based on risk assessment, nature and extent of audit and IT
audit resources identification. A report on the status of planned versus actual IS audits, and
any changes to the annual IS audit plan, needs to be presented periodically to the Audit
Committee and Senior management.
IT governance, information security governance related aspects, critical IT general
controls like data centre controls and processes and critical business applications/systems
having financial/compliance implications including MIS and regulatory reporting systems
and customer access points (like delivery channels) need to be subjected to IS Audit(or
integrated audit) atleast once a year (or more frequently, if warranted by risk assessment).
IS Audits should also cover branches, with focus on large and medium branches, in
critical areas like password controls, control of user ids, operating system security,
anti-malware controls, maker-checker controls, segregation of duties, rotation of personnel,
physical security, review of exception reports/audit trails, BCP policy and testing etc.
Detailed pre-implementation application control audits and data migration audits with
regard to critical systems need to be subjected to an independent external audit.
Banks also need to conduct a post-implementation detailed application control
audit. Furthermore, banks should also include application control audits in a risk based
manner as part of the regular Internal Audit/IS Audit plans with focus on data integrity
(among other factors). General internal auditors with requisite functional knowledge need to
be involved along with the IS Auditors in the exercise to provide the requisite domain
expertise.
IS Auditors should periodically review the results of internal control processes and
analyze financial or operational data for any impact on risk assessment or scoring.
Accordingly, various auditee units should be required to keep auditors up to date on all major
changes in departments or functions, such as the introduction of a new product,
implementation of a new system, application conversions, significant changes in organization
or staff , new regulatory and legal requirements, security incidents etc.
IS Auditors should be reasonably conversant with various fraud risk factors and should
assess the risk of occurrence of irregularities connected with the area under audit. The IS
Auditor should also consider Fraud Vulnerability assessments undertaken by the Fraud Risk
Management group, while identifying fraud risk factors as part of IT risk assessment and
audit process.
Banks should consider using testing accelerators — tools and techniques that help
support the procedures IS Auditors will be performing — to increase the efficiency and
effectiveness of the audit.
Auditors need to enhance utilization of CAATs, which may be used effectively in areas
such as detection of revenue leakage, assessing impact of control weaknesses, monitoring
customer transactions under AML requirements and generally in areas where a large volume
and value of transactions are reported. Suitable “read-only” access rights should be provided
to auditors for enabling use of CAATs.
Banks may consider, wherever possible, a continuous auditing approach for critical
systems, which involves performing control and risk assessments on a more frequent basis by
using technology suitably.
The Board (or the Audit Committee) should be informed of Senior Management’s
decision on all significant observations and recommendations. When IS Auditors believe that
the bank has accepted a level of residual risk that is inappropriate for it, they should discuss
the matter with Internal Audit function and Senior Management. If the IS Auditors are not in
agreement with the decision regarding residual risk accepted by the bank, IS Auditors and
Senior Management should report the matter to the Board (or the Audit Committee) for
resolution.
Services provided by a third party are relevant to the scope of IS Audit of a bank when
those services, and the controls within them, form part of the bank’s information
systems. These need to be adequately assessed as part of the IS Audit process.
In order to provide assurance to management and regulators, banks are required to
conduct a quality assurance, at least once every three years, on the Banks Internal Audit
including IS Audit function to validate the approach and practices adopted by them in the
discharge of their responsibilities as laid out in the Audit Policy.
Accreditation and empanelment of IS audit qualifications/certifications and IS audit
vendors/firms can be considered by the Government of India.
On Cyber Fraud:
Most retail cyber frauds and electronic banking frauds would be of values less than Rs.1
crore and hence may not attract the necessary attention of the Special Committee of the Board.
Since these frauds are large in number and have the potential to reach large proportions, it is
recommended that the Special Committee of the Board be briefed separately on this to keep
them aware of the proportions of the fraud and the steps taken by the bank to mitigate them.
The Special Committee should specifically monitor the progress of the mitigating steps taken
by the bank in case of electronic frauds and the efficacy of the same in containing fraud
numbers and values.
support required to maintain the plan. In case of disaster, each department has to be prepared
for the recovery process aimed at protection of the critical functions. To this end, a set up like
the BCP Committee is charged with the implementation of the BCP in an eventuality and all
departments are expected to fulfill their respective roles in a co-ordinated manner. Hence, a
BCP/Crisis Management Committee consisting of senior officials from various departments
like HR, IT, Legal, Business functions and Information Security needs to be instituted.
There need to be adequate number of teams for handling various aspects of the BCP at
the Central Office level as well as individual Zonal/ Controlling Office and branch levels.
Banks should consider various BCP methodologies and standards, like BS 25999,as
inputs for their BCP framework.
The failure of critical systems or the interruption of vital business processes could
prevent timely recovery of operations. Banks must fully understand the vulnerabilities
associated with interrelationships between various systems, departments, and business
processes. These vulnerabilities should be incorporated into the business impact analysis,
which analyzes the correlation between system components and the services they provide.
People aspect should be an integral part of a BCP. Too often, plans are focused on
technical issues, therefore it is suggested that a separate section relating to people should be
incorporated, including details on staff welfare, counseling, relocation considerations, etc.
Pandemic planning needs to be incorporated as part of the BCP framework of banks.
Banks must regularly test BCP to ensure that they are up to date and effective. Testing
of BCP should include all aspects and constituents of the bank i.e. People, Processes and
Resources (including Technology).
Banks should involve their Internal Auditors (including IS Auditors) to audit the
effectiveness of BCP and its periodic testing as part of their Internal Audit work and their
findings/ recommendations in this regard should be incorporated in their report to the Board
of Directors and Senior Management.
Banks should consider having a BCP drill planned along with the critical third parties in
order to derive reasonable level of assurance in ensuring continuity in respect of
pre-identified minimal required processes during exigencies.
Banks should perform the DR/BCP test without movement of bank personnel to the DR
site. This will help in testing the readiness of alternative staff at the DR site.
Business continuity plans should be maintained by atleast annual reviews and updates to
ensure their continued effectiveness.
Banks should also consider having an unplanned BCP drill, wherein only a restricted set
of people and certain identified personnel may be aware of the drill and not the floor/business
personnel.
Various detailed requirements relating to procedural, infrastructural and HR related
aspects of BCP have been provided so that banks can improve BCP processes and generate
best outcomes.
There are many applications and services in the banking system that are highly mission
critical in nature and therefore require high availability and fault tolerance to be considered
while designing and implementing the solution. This aspect is to be taken into account
especially while designing and implementing the data centre solution and corporate network
solution.
The solution architectures of DC and DR are not identical for all applications and
services. Generally, it is observed that critical applications and services, namely the retail,
corporate, trade finance and government business solutions as well as the delivery channels
have the same DR configurations whereas surround or interfacing applications do not have
DR support. Banks will have to conduct periodic reviews with reference to the above aspect
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
and upgrade the DR solutions from time to time and ensure that all critical applications and
support services have perfect replicas in terms of performance and availability.
The configurations of servers, network devices and other products at the DC and DR
have to be identical at all times. This includes the patches that are applied at the DC
periodically and the changes made to the software from time to time by customization and
parameterization to account for regulatory requirements, system changes etc.
Periodic checks to ensure data and transaction integrity between DC and DR are
mandatory. Suitable automated tools may be leveraged in this connection.
DR drills currently conducted periodically come under the category of planned shutdown.
Banks have to evolve a suitable methodology to conduct drills which are closer to a real
disaster scenario so that the confidence levels of the technical team taking up this exercise are
built up to address requirements in the event of a real disaster.
Consideration of telecom related redundancy and alternative data and voice
communication channels in the event of exigencies should be incorporated as part of the
business continuity planning.
It is to be ensured that the support infrastructure at the DC and DR, namely the electrical
systems, air-conditioning environment and other support systems do not have a single point
of failure and have a building management and monitoring system to continuously monitor
the resources. Monitoring of uptime has to be made as per the requirements and agreements
with respective vendors. The same requirements have to be taken care of in case the DC/DR
set up is in an outsourced location or a common shared set up.
Given the need for drastically minimizing data loss during exigencies and enabling quick
recovery and continuity of critical business operations, banks need to consider near site DR
architecture. Major banks with significant customer delivery channel usage and significant
participation in financial markets/payment and settlement systems may need to consider a
plan of action for creating a near site DR architecture over the medium term (say, three
years).
An industry-wide alarm and crisis forum/organization (in which the key market
participants and the most important providers of financial infrastructure services are
represented) may be established. The heads of BCP from the participating institutions can
make up the top level of this crisis organization, with the lower levels forming a network
between those responsible for the areas of liquidity, large-value payments, retail payment
transactions and IT. Any of the institutions can invoke the alarm organization by activating
the level affected.
A website for industry-wide BCP related information for the benefit of the industry can
be considered.
There are programmes in the US like the Telecommunications Service Priority System
(TSPS), Government Emergency Telecommunications service (GETS) and Wireless Priority
Service Program (WPS) for provision of priority telecom availability and recovery services
during exigencies for critical infrastructures and institutions. Similarly, the Government of
India may declare the banking sector, including financial markets, as critical infrastructure
and consider instituting such special measures for priority infrastructural services to enable
conduct of critical banking services and financial market transactions during exigencies.
On Customer Education:
The Board of Directors/Senior Management need to be committed to the process of
consumer education initiatives by providing adequate resources, evaluating the effectiveness
of the process and fine-tuning and improving customer education measures on an ongoing
basis.
To get desired support for the programme, it is important to identify and involve key
stakeholders in decision-making, planning, implementation and evaluation. A working group
or committee can be created to establish a clear goal for the endpoint in consultation with key
stakeholders, clearly define roles, responsibilities and accountabilities, communicate in an
open, clear and timely manner, allowing for flexibility in approaches to suit different
stakeholder needs, support training and development to ensure a change in behaviour and
culture, learn from previous and ongoing experiences and celebrate achievements.
Banks need to follow a systematic process to develop an awareness programme through
the stages of planning and design, execution and management, and evaluation and course
correction.
Since awareness programmes should be customized for the specific audience, it is
important to identify and segment the target users for the programmes - like bank customers,
employees, law enforcement personnel, fraud risk professionals, media partners, etc.
Building consensus among decision makers and stakeholders for financial and
administrative support is an important step in the programme. In this respect, both fixed and
variable costs need to be identified.
Since the target groups obtain information from a variety of sources, more than one
communication channel could be used to engage them successfully.
A research group should be formed to continually update the communications team with
the latest trends and evolving modus operandi. The team would maintain a repository of
material such as case studies, sample mails, samples of fraudulent documents, international
practice/developments etc.
Evaluation of the effects of various campaigns for specific target groups can be measured
through qualitative (e.g. focus groups, interviews) and/ or quantitative (e.g. questionnaires,
omnibus surveys) research. Evaluation against metrics, performance objectives, etc. should
also be conducted to check the campaign’s effectiveness, and to establish lessons learned to
improve future initiatives.
At the industry level, each bank should have a documented policy, training mechanisms
and research units. Material can be pooled from these units to be used on a larger platform
towards a common goal.
On Legal Issues:
The Risk Management Committee at the Board level needs to put in place processes to
ensure that legal risks arising from cyber laws are identified and adequately addressed. It also
needs to ensure that the concerned functions are adequately staffed and the personnel
handling it are trained to carry out the function efficiently. The Operational Risk Group needs
to incorporate legal risks as part of the operational risk framework and take steps to mitigate
the risks assessed. The legal function within the bank needs to advise business groups on
legal issues arising out of the use of Information Technology.
There should be a robust system in banks to keep track of the transactions of the nature
referred to in statutory guidelines on AML (like PMLA and PMLR) and report the same
within the prescribed period. Apart from the risk of penalty, this involves reputational risk for
such entities.
Under the NI Act, a cheque in the electronic form has been defined as “a mirror image”
of a paper cheque. The expression ‘mirror image’ does not appear to be appropriate. The
expression, “mirror image of” may be substituted by the expression, “electronic graphic
which looks like” or any other expression that captures the intention adequately.
The definition of a cheque in electronic form contemplates a digital signature with or
without biometric signature and an asymmetric crypto system. Since the definition was
inserted in the year 2002, it is understandable that it has captured only the digital signature
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
and asymmetric crypto system dealt with under Section 3 of the IT Act, 2000. Since the IT
Act,2000 has been amended in the year 2008 to make provision for an electronic signature
also,a suitable amendment in this regard may be required in the NI Act so that the electronic
signature may also be used on cheques in electronic form.
There is uncertainty with respect to the meaning of a crucial expression like
‘intermediary” as per the IT Act 2000 and as amended by the IT Amendment Act, 2008. As
such, it is necessary that clarity is brought about by a statutory amendment with regard to the
meaning of the expression ‘intermediary’ in so far as banks and financial institutions are
concerned.
A combined reading of Section 2(p) and sub-sections (1) and (2) of Section 3 of the IT
Act makes it clear that in terms of the Act an electronic record may be authenticated by
affixing a ‘digital signature’ and if a party wants to authenticate the electronic record by
affixing a digital signature, the electronic method or procedure for affixing the digital
signature shall be an asymmetric crypto system and hash function. While authentication of an
electronic record by affixing a digital signature is optional, the procedure for affixing the
digital signature, namely, use of an asymmetric crypto system and hash function, is
mandatory.
The question that arises for consideration is whether a party may be bound by the
transactions entered into through electronic means (whether through ATMs, Internet or
otherwise) though the electronic records in question are not authenticated by using
digital/electronic signatures. On reading Section 65B (1) of the Indian Evidence Act, it is
clear that electronic records may be proved in court even though they are not authenticated by
using digital or electronic signatures if the conditions mentioned therein are satisfied. The
difficulty in proving the various conditions set forth in sub-sections (2) and (3) of section 65B
of the Indian Evidence Act is ameliorated to a great extent by sub-section (4) thereof under
which the certificate of a person occupying a responsible official position in relation to the
operation of the relevant device or the management of the relevant activities (whichever is
appropriate) shall be evidence of any matter stated in the certificate.
The Government should specify sufficient number of agencies under section 79A of the
Indian Evidence Act to assist courts to arrive at a decision on the evidentiary value of
electronic records irrespective of whether a digital or electronic signature is affixed.
Financial transactions such as operation of bank accounts and credit card operations are
being carried on by banks in a big way by using cards, pin numbers and passwords, etc.
Banks are using many security features to prevent frauds to the extent possible. The proposed
‘two factor authentication method’ (2F method) is also a step in the same direction. It may not
be ideal to mandate a particular technology (digital signatures with asymmetric crypto system
and hash function) for authenticating all electronic transactions by banks.
As a short term measure, it is recommended that Rules may be framed by the Central
Government under Section 5 of the IT Act, to the effect that, with respect to internet or e-
banking transactions, the 2F method or any other technique of authentication provided by
banks and used by the customers shall be valid and binding with respect to such transactions,
even if a ‘digital signature’ or ‘electronic signature’ is not affixed.
The ISP license restricts the level of encryption for individuals, groups or organizations
to a key length of only 40 bits in symmetric key algorithms or equivalents. RBI has stipulated
SSL/ 128 bit encryption as a minimum level of security. SEBI has stipulated 64/128 bit
encryption for Internet Based Trading and Services. Information Technology (Certifying
Authorities) Rules, 2000 require’ internationally proven encryption techniques’ to be used for
storing passwords. An Encryption Committee constituted by the Central Government under
Section 84A of the IT Act, 2000 is in the process of formulating rules with respect to
encryption. Allowance for higher encryption strength may be allowed for banks.
Section 43A of the IT Act deals with the aspect of compensation for failure to protect
data. The Central Government has not prescribed the term 'sensitive personal data,' nor has it
prescribed a “standard and reasonable security practice”. Until these prescriptions are made,
data is afforded security and protection only as may be specified in an agreement between the
parties or as may be specified in any law.
The IT Act, 2000 as amended, exposes the banks to both civil and criminal liability. The
civil liability could consist of exposure to pay damages by way of compensation upto ` 5
crore under the amended Information Technology Act before the Adjudicating Officer and
beyond ` 5 crore in a court of competent jurisdiction. The top management of banks could
also suffer exposure to criminal liability given the provisions of Chapter XI of the amended
Information Technology Act and the exposure to criminal liability could consist of
imprisonment for a term which would extend from three years to life imprisonment, as also a
fine. Further, various computer related offences are enumerated under various provisions of
the Act.
Of late there have been many instances of ‘phishing’ in the banking industry, posing a
major threat to customers availing internet banking facilities. Though Section 66D of the
amended IT Act could broadly be said to cover the offence of phishing, the attempt to commit
the act of phishing is not made punishable. It is suggested that there is a need to specifically
provide for punishment for an attempt to phish as well, in order to deter persons from
attempting it.
The issue of whether Section 43A read with Section 72 and 72A of the IT Act, 2000
address the issue of data protection adequately or whether they need to be supplemented by
long-term provisions(which can help facilitate effective and efficient protection and
preservation of data), would depend on the prescriptions of the Central Government. Various
suggestions have been offered in this report in this regard.
It is necessary to balance the interests of customers and those of banks and provide
protection to banks against any fraudulent or negligent acts by the customer. It is not
appropriate to leave such an important issue to be dealt with in documentation. Appropriate
statutory provisions need to be enacted in this regard.
Though there is no specific legislation in India which deals only with ‘electronic fund
transfer’ and which is consumer protection driven, certain concerns have been dealt with in
the Payment and Settlement Systems Act, Rules, Regulations, directions, etc. issued
thereunder as well as the provisions of general law. However, it may be apposite to have
some provisions similar to those in the EFT Act which exempts the bank from liability in the
event of fraud by the customer or a technical failure, etc. (for eg., provisions dealing with
‘unauthorized electronic fund transfers’ and the consumer’s liability for unauthorized
transfers).
Section 69A and the Blocking Rules: Allowing the Government to block content under
certain circumstances
Section 69A of the IT (Amendment) Act, 2008, allows the Central Government to block
content where it believes that this content threatens the security of the State; the sovereignty,
integrity or defence of India; friendly relations with foreign States; public order; or to prevent
incitement for the commission of a cognisable offence relating to any of the above. A set of
procedures and safeguards to which the Government has to adhere when doing so have been
laid down in what have become known as the Blocking Rules.
Freedom of expression
To balance freedom of expression with other human rights is, at times, a difficult and delicate
task. From hate speech to intermediary liability, we tease out and shed greater light on the
various challenges that make this task particularly complicated, proposing ways forward that
can further strengthen and promote the right to freedom of expression, in India and beyond,
as well.
The Information Technology (Amendment) Act, 2008 an act to amend the IT Act 2000
received the assent of the President on 5th February 2009. Several legal & security experts are
in the process of analyzing the contents and possible impacts of the amendments. The
objective of this note is to try and study the possible implications and impacts on Indian
companies. This note is not intended to be a comprehensive analysis of the amendments, but
only certain key points which could impact Indian Companies
Data Protection
The IT Act 2000 did not have any specific reference to Data Protection, the closet being a
provision to treat data vandalism as an offense. The Government introduced a separate bill
called “Personal Data Protection Act 2006” which his pending in the Parliament and is likely
to lapse. The ITA 2008 has introduced two sections which address Data Protection aspects to
an extent, which gives rise to certain key considerations for the sector.
The sections under consideration are:
Section 43A: Compensation for failure to protect data
Section 72A: Punishment for disclosure of information in breach of lawful contract
Section 43A states
Where a body corporate, possessing, dealing or handling any sensitive personal data or
information in a computer resource which it owns, controls or operates, is negligent in
implementing and maintaining reasonable security practices and procedures and thereby
causes wrongful loss or wrongful gain to any person, such body corporate shall be liable to
pay damages by way of compensation, to the person so affected.
By way of explanation: "Body corporate means Indian companies"
"Reasonable security practices mean a mutual contract between the customer and service
provider OR as per the specified law. In absence of both then as specified by the Central
Government
Hence it would be important for Indian companies to seriously look at SLA’s and agreements
which have been signed with clients to understand the data protection implications. The same
goes for understanding the applicable laws.
A major modification is that this clause doesn’t mention the compensation limit of Rs. 1
Crore which was there as part of section 43 of the ITA 2000. This implies that there is no
upper limit for damages that can be claimed. This essentially is “unlimited liability” for
Indian companies, which could cause serious business implications.
Section 72A:
Under this section disclosure without consent exposes a person including an "intermediary" to
three years imprisonment of fine upto Rs. Five lacs or both.
This section uses the term “personal information” and not “sensitive personal information” as
in section 43A. Hence it could apply to any information which is obtained in order to deliver
services. Hence in some ways broadens the definition of information.
2. Information Preservation
Across the amendments there are several references to “service providers” or
“intermediaries”, which in some form would apply to all Indian companies.
e.g. Section 67C: Preservation and Retention of information by intermediaries.
Intermediary shall preserve and retain such information as may be specified for such duration
and in such manner and format as the Central Government may prescribe”. Any intermediary
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
Overview of IT operations
Introduction:
For banks in which information technology (IT) systems are used to manage information, IT
Operations should support processing and storage of information, such that the required
information is available in a timely, reliable, secure and resilient manner.
Scope:
IT Service Management
Infrastructure Management
Bank’s Board of Directors has ultimate responsibility for oversight over effective functioning
of IT operational functions. Senior management should ensure the implementation of a safe
IT Operation environment. Policies and procedures defined as a part of IT Operations should
support bank’s goals and objectives, as well as statutory requirements.
Core IT Operations
The Board or Senior Management should take into consideration the risk associated with
existing and planned IT operations and the risk tolerance and then establish and monitor
policies for risk management.
Organisational Structure:
IT Operations include business services that are available to internal or external customers
using IT as a service delivery component–such as mobile or internet banking. IT Operations
include components that are used to support IT Operations: service desk application, ticketing
and event management tools, etc. Banks may consider including Test and Quality Assurance
Environment (besides, Production Environment) within the scope of IT Operations.
Service Desk: The service desk is the primary point of contact (Single Point of
Contact or SPOC) for internal and external customers. Besides handling incidents
Making an initial assessment of requests, attempting to resolve them via knowledge management or
escalating, based on agreed service levels
Identifying problems
A structure for the Service Desk that allows optimum resource utilization would include:
Follow the Sun i.e. in time zones such that service desk is available for assistance and recording of
incidents round the clock
IT Operations Management
IT Operations management is a function which is primarily responsible for the day-to-day management
and maintenance of an organisation’s IT infrastructure, ensuring service delivery to the agreed level as
defined by Service Level Agreement (SLA).
Operational Control: Oversee the execution and monitoring of operational activities and events in
IT infrastructure which is within the preview of IT operations. Operational control activities are
normally carried out by Network Operations Centre (NOC) or Operations Bridge. Beside
execution and monitoring of routine tasks operation control also involve the following activities :
Console Management
Job Scheduling
Operations Management Structure: For all practical reasons, application management and infrastructure
management teams should be part of IT operations. As, these functions manage and execute operational
activities, whereas others delegate these to dedicate IT operations function.
Application Management:
It involves handling and management of application as it goes through the entire life-cycle. The life-cycle
encompasses both application development and application management activities. Sub-activities that can be
defined for application management functions are:
Application Development: It is concerned with activities needed to plan, design and build an
application that ultimately is used by a part of the organisation to address a business requirement. This
also includes application acquisition, purchase, hosting and provisioning
Application Maintenance/Management: It focuses on activities that are involved with the deployment,
operation, support and optimisation of the application
It acts as a custodian of technical knowledge and expertise related to managing and supporting
applications. It ensures that the technical knowledge and expertise required to design, develop, test,
manage and improve IT services are identified, developed and refined. Therefore, it participates in IT
operation management
It ensures that appropriate resources are effectively trained and deployed to deliver, build, transit,
operate and improve the technology required to manage and support IT services
It documents skill sets available within an organisation and skills that need to be developed to manage
application management as function
It defines standards to be adapted when defining new application architecture and involvement in
design and build of new services
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
It designs and performs tests for functionality, performance and manageability of IT services
It participates in incident, problem, performance, change and release management, and in resource
fulfillment
Application Management Structure: Though activities to manage applications are generic and consistent
across applications; application management function, for all practical reasons, is not performed by a single
department or group. It consists of technical areas as per technical skill sets and expertise. Some of these
can be:
Financial application
Infrastructure applications
Function-specific applications
Infrastructure Management
It is the function primarily responsible for providing technical expertise and overall management of the IT
infrastructure. Its primary objective is to assist in plan, implement and maintenance of a stable technical
infrastructure in order to support an organisation’s business processes.
Manage IT infrastructure components for an environment, which falls within the preview of IT operations
It acts as a custodian of technical knowledge and expertise, related to the management of IT infrastructure.
It ensures that technical knowledge and expertise required to design, develop, test, manage and improve IT
services are identified, developed and refined
It ensures appropriate resources are effectively trained and deployed to deliver, build, transit, operate and
improve the technology required to deliver and support IT infrastructure
It helps document skill sets available within an organisation and skills needed to be developed to manage
infrastructure management as function
Definition of standards to be adapted when defining new IT architecture and involvement in the design and
build of new services
Designing and performing tests for functionality, performance and manageability of IT services
Participation in incident, problem, performance, change and release management and resource fulfillment
Infrastructure management function should provide information or manage for configuration Management
System
Infrastructure Management Structure: For all practical reasons, infrastructure management function is not
performed by a single department or group, it consist of technical areas as per the technical skill sets and
expertise, some of these are:
Internet team
Messaging team
Banks should analyse their IT Operation environment, including technology, human resources and
implemented processes, to identify threats and vulnerabilities. They should conduct a periodic risk assessment
which should identify:
Risks associated with individual platforms, systems, or processes, as well as automated processing
units
While identifying the risks, a risk assessment process should quantify the probability of a threat and
vulnerability, and the financial consequences of such an event. Banks should also consider the
inter-dependencies between risk elements, as threats and vulnerabilities have the potential to quickly
compromise inter-connected and inter-dependent systems and processes.
Banks should implement a cost-effective and risk-focused environment. The risk control environment should
provide guidance, accountability and enforceability, while mitigating risks.
Risk Categorisation: As a part of risk identification and assessment, banks should identify events or
activities that could disrupt operations, or negatively affect the reputation or earnings, and assess
compliance to regulatory requirements. Risks identified can be broadly categorised into following
categories:
Strategic Failures: That might include improper implementation, failure of supplier, inappropriate
definition of requirements, incompatibility with existing application infrastructure etc. It will also
include regulatory compliance
Design Failures: It might include inadequate project management, cost and time overruns,
programming errors and data migration failures among others
Risk Mitigation: Once the organisation has identified, analyzed and categorized the risks, organisation
should define following attributes for each risk component:
Probability of Occurrence;
Financial Impact;
Reputational Impact;
Legal Impact.
Lost revenues
Litigation probability
Reconstruction expenses
These, along with the business process involved, should be used to prioritise risk mitigation actions and control
framework.
IT Operations Processes
IT Strategy
Processes within IT Strategy provide guidance to identify, select and prioritise services that are aligned to
business requirements. IT strategy, as a framework, provides feedback to IT Operations on the services to be
supported and their underlying business processes and prioritisation of these services, etc.
A well-defined IT Strategy framework will assist IT Operations in supporting IT services as required by the
business and defined in OLA / SLAs.
IT Strategy processes provide guidelines that can be used by the banks to design, develop, and implement IT
Operation not only as an organisational capability but as a strategic asset.
Assists in decision-making
Speed of changes
Operational control
Service Valuation
It is the mechanism that can be considered by banks to quantify services, which are available to customers
(internal or external) and supported by IT operations in financial terms. It assists IT Operation functions to
showcase the involvement of function in supporting the bank's core business.
Financial Management uses Service Valuation to quantify financial terms, value of IT services supported by IT
Operations. It provides a blueprint from which businesses can comprehend what is actually delivered to them
from IT. Combined with Service Level Management, Service Valuation is the means to a mutual agreement
with businesses, regarding what a service is, what its components are, and its cost and worth.
Service Valuation quantifies, in financial terms, funding sought by a business and IT for services delivered,
based on the agreed value of those services. The activity involves identifying cost baseline for services and then
quantifying the perceived valued, added by the provider’s service assets in order to conclude a final service
value.
Provisioning Value: The actual underlying cost of IT, related to provisioning a service, including all
fulfillment elements–tangible and intangible. Input comes from financial systems and consists of
payment of actual resources consumed by the IT in the provisioning of services. This cost element
includes items such as:
Compliance costs
Service Value Potential: Is the value-added component based on a customer’s perception of value from the
service or expected marginal utility and warranty from using the services in comparison with what
is possible using the customer’s own assets.
Portfolio Management
It provides guidelines that can be considered by banks for governing investments in service management across
an enterprise and managing them for value. Portfolio management contains information for all existing services,
as well as every proposed service–those that are in conceptual phase.
Every service, which is a part of service portfolio, should include a business case, which is a model of what a
service is expected to achieve. It is the justification for pursuing a course of action to meet stated organisational
goals. Business case links back to service strategy and funding. It is the assessment of a service management in
terms of potential benefits and the resources and capabilities required to provision and maintain the service.
Portfolio Management framework defined by the banks should highlight controls, which are defined to develop
an IT Service from conceptual phase to go- live phase and then to transition to production environment. During
the development of IT services financial impact of the new service on IT Operation should also be ascertained
which will assist IT Operations in Service Validation.
Demand Management
Demand Management process provides guidelines which can be used by banks to understand the business
processes IT operations supports to identify, analyse, and codify Patterns of business activities (PBA) to provide
sufficient basic for capacity requirement. Analysing and tracking the activity patterns of the business process
makes it possible to predict demand for services. It is also possible to predict demand for underlying service
assets that support these services.
Demand Management guidelines should also take into consideration IT Operations involvement in development
of service from conceptual phase to go to the live phase, so that there is a transparency of demand of new
service in IT Operations.
Ii) Design
The design phase of the IT operations provides the guidelines and processes, which can be used by the banks to
manage the change in the business landscape. Components which should be considered when designing a new
IT service or making a change to the existing IT service are:
Business Processes
IT Services
Service-level Agreements
IT Infrastructure
IT Environment
Information Data
Applications
Support Services
Support Teams
Suppliers
Service design: This should not consider components in isolation, but must also consider the relationship
between each of the components and their dependencies on any other component or service.
Design phase: Provides a set of processes and guidelines that can be used by banks to design IT services,
supported by IT operations, that satisfies business objectives, compliance requirements and risk
and security requirements. The processes also provide guidelines to identify and manage risks and
to design secure and resilient IT services.
Over the years, banks' IT infrastructure has grown and developed. In order to establish an accurate IT landscape,
it is recommended that an IT Service Catalogue is defined, produced and maintained. It can be considered as a
repository that provides information on all IT services supported by IT Operations framework.
The Service Catalogue Management process provides guidelines, used by banks to define and manage service
catalogue, which provides a consistent and accurate information on all IT services available to customers
(internal or external). It also ensures that the service catalogue is available to users, who are approved to access
it. It should contain details of all services that are in production, as well as the services that are being prepared
for transition. Banks may consider following attributes to be included into the service catalogue:
Definition of Service
Service Criticality
Service Owner
Service-level Manager
Service catalogue provides details of services available to customers such as intended use,
business processes they enable and the level and quality of service the customer can expect from each service.
Banks can also consider incorporating “charge back mechanism”, as defined in financial management into the
service catalogue.
Business Service Catalogue: It contains details of all IT services delivered to a customer, together with
relationships with business units and business processes that rely on IT services. This is the customer view
of the catalogue. Business Service Catalogue facilitates development of robust Service Level Management
process.
Technical Service Catalogue: It contains details of all IT services delivered to a customer, together with his
or her relationship with supporting and shared services, relationship to configuration items (CIs). CIs can be
a service asset or component, or any other item that is under control of configuration management.
Depending on established strategy configuration, an item may vary widely in complexity, size and type. It
can range from entire services or systems to a single software module or a minor software component.
(Configuration Items are explained in details in “Service Assets and Configuration Management” section of
the guidelines.) It facilitates the development of the relationship between services, underlying CIs, SLAs
and OLAs, and the support groups, which support services throughout its life-cycle.
This process defines the framework that can be used by banks to plan, co-ordinate and draft, agree, monitor and
report service attributes used to measure the service quality. Its framework also includes guidelines for ongoing
review of service achievements to ensure that the required and cost-justifiable service quality is maintained and
improved. Beside current services and SLAs, this management provides guidelines to ensure that new
requirements are captured. That new or changed services and SLAs are developed to match the business needs
and expectations.
Service Level Management process should be able to meet the following objectives:
Define, document, agree, monitor, measure, report and review the level of IT services
Ensure that IT Operations and consumers have clear, unambiguous expectations of the level of services
to be delivered
Ensure that pro-active measures, to improve the level of service delivered, are implemented if
cost-justified
While defining SLM framework for banks, the following aspects should also be considered
Operational-level agreement to ensure that Operational Level Agreements (OLAs) with other support
groups are defined and developed; these OLAs should be in line with SLAs which it supports
Underpinning supplier contract to ensure all underpinning supplier contracts with the vendors or
suppliers are defined and developed: these contracts should be in line with SLAs, which it supports
While defining Service Level Agreement as a part of Service Level Management framework, the following
options can be considered:
Service based SLA: Its structure covers attributes for single service across an organisation. For instance,
SLA for internet banking service
Customer based SLA: The structure covers attributes for all services for a defined set of customers. For
instance, SLA for SMEs customers
can be defined as per the organizational hierarchy. For instance, SLA for corporate offices, branches and head
offices
Attributes that are included in SLAs should be ones which can effectively be monitored and measured.
Attributes which are included in the SLAs can be categorised into operational, response, availability and
security attributes. Service Level Management framework should also define guidelines for reviews of Service
Level Agreements, Operational Level Agreements, and underpinning contracts to ensure that they are aligned to
business needs and strategy. These should ensure that services covered, and targets for each, are relevant. And
that nothing significant is changed that invalidates the agreement in any way. Service Level Management
framework defined should also have guidelines defined for logging and management, including escalation of
complaints and compliments.
Capacity Management
The process provides the framework and guidelines that can be adapted by banks to ensure that cost-justifiable
IT capacity exists and matches to current- and future-agreed business requirements as identified in Service
Level Agreement.
Produce and maintain capacity plan that reflects the current and future business requirements
Manage service performance so that it meets or exceeds the agreed performance targets
Assess impact of all changes on capacity plan and performance of IT services supported by IT Operations
Ensure that pro-active measures are undertaken to improve the performance of services, whenever it is
cost-justifiable.
One of the key activities defined as a part of capacity management process is to produce and maintain, at an
ongoing basis, the capacity plan, which depicts current level of resource utilization and service performance.
Capacity plans can also include forecasting future requirements to support business activities. The process can
be subdivided into three:
Business Capacity Management: Defines guidelines for translating business-need plans into requirements
for IT services and supporting infrastructure, ensuring that the future business requirements for IT
services are quantified, designed, planned and implemented. Inputs for future IT requirements come
from the Service Portfolio and Demand Management.
Service Capacity Management: This defines guidelines for management, control and prediction of
end-to-end performance and capacity of live and operational IT service usage and workloads. It
provides guidelines to ensure that the performance of IT services is monitored and measured.
Component Capacity Management: It defines guidelines to identify and understand the performance,
capacity and utilization of each individual component within a technology used to support IT services,
including infrastructure, environment, data and applications.
A major difference between sub-processes is in the data that is being monitored and collected. For example, the
level of utilization of individual components in the infrastructure: processors, disks and network links will be
under Component Capacity Management. While transaction throughput rates and response times will be under
Service Capacity Management. Business Capacity Management will be concerned with data, specific to
business volumes. Banks adapting capacity management process should ensure that its framework encompass all
areas of technology (hardware, software, human resource, facilities, etc.)
Availability Management
Availability and reliability of IT services can directly influence customer satisfaction and reputation of banks.
Therefore Availability Management is essential in ensuring that the IT delivers the “right level” of service
required by the business to satisfy its objectives. The process provides framework and guidelines that can be
adapted by banks to ensure that the level of service availability (for all services) is matched, or exceeds the
current and future requirements, as defined in the Service Level Agreement.
Produce and maintain an appropriate up-to-date Availability Plan that reflects the current and future needs
of the business
Ensure that service availability achievements meet or exceed agreed targets, by managing services and
resources-related availability targets
Ensure that pro-active measures to improve the availability of services are implemented wherever it is cost
justifiable to do so
When implementing Availability Management processes, banks should consider including the following:
All operational services and technology, supported by IT Operations function and for which there is a
formal SLA
New services where Service Level Requirement and Agreement have been established
Aspects of IT's services and components that may impact availability, which may include training, skills,
process effectiveness, procedures and tools
Reactive activities: The reactive aspect of availability management involves monitoring, measuring,
analysis and management of events, incidents, problems and changes, involving unavailability
Proactive activities: This aspect involves planning, design and improvement of availability
Attributes that can be used by the banks for reporting availability of IT services, can be:
Availability: The ability of a service, component or CI, to perform the agreed function when required.
Downtime should only be included in the above calculation, when it occurs within the “Agreed Service
Time”.
Mean Time Between Service Incidents (MTBSI): MTBSI refers to how long a service; component or CI
can perform its agreed function without interruption.
MTBSI =-------------------------------------
Number of Breaks
Mean Time Between Failures (MTBF): MTBF refers to how long a service; component or CI can perform
its agreed function without reporting a failure.
MTBF = -----------------------------------------------------------------
Number of breaks
Mean Time Between Failures (MTBF): is the mean time between the recovery from one incident and
occurrence of the next incident, it is also known as uptime. This metric relates to the reliability of the IT
Service supported by IT Operations.
Mean Time to Repair (MTTR): MTTR refers to how quickly and effectively a service, component or CI can
be restored to normal working after failure.
MTTR = -----------------------------------
Number of breaks
Mean Time to Repair (MTTR): This is the average time between occurrence of a fault and service recovery.
It is also known as downtime. This metric relates to the recoverability and serviceability of the IT Services
supported by IT Operations.
When defining availability targets for a business service, banks should consider identifying Vital Business
Function (VBF). VBF represents critical business elements of a process supported by IT services. For example,
an ATM will have following business functions:
Cash dispensing
Statement printing.
Out of these three, cash dispensing and reconciliation should be considered as vital business functions,
influencing the availability design and associated costs.
Supplier Management
Complex business demands require extensive skills and capabilities from IT to support business processes,
therefore collaboration with service providers and value networks are an integral part of end-to -end business
solution. Supplier Management process provides framework and guidelines that can be used by banks to manage
relationships with vendors, suppliers and contractors. This framework ensures that suppliers and services they
provide are managed to support IT service targets and business expectations. The purpose of this management
process is to obtain value for money from suppliers, and to ensure that suppliers perform to the targets contained
within contracts and agreements, while conforming to all terms and conditions.
Supplier Management process provides guidelines which can be used by the banks to:
iii) Transition
The transition phase provides frameworks and processes that may be utilised by banks to:
Evaluate service capabilities and risk profile of new or changes service before it is released into production
environment
Evaluate and maintain integrity of all identified service assets and configuration items required to support
the service
Service Asset and Configuration Management process provides framework and guidelines that can be used by
the banks to manage service assets and configuration items that supports business services.
Identify, control, record, audit and verify service assets and configuration items, including service baseline
version controls their attributes and relationships.
Manage and protect integrity of service assets and configuration items through the service lifecycle by
ensuring only authorised assets are used and only authorised changes are made.
Ensure integrity of configuration items required to support business services and IT infrastructure by
establishing and maintaining an accurate and complete Configuration Management System.
Provide accurate information of configuration items to assist in change and release management process.
Service asset management manages assets across its lifecycle from acquisition through disposal. Implementation
of Service Asset and Configuration Management framework has cost and resources implications and therefore
strategic discussions needs to be made about the priorities to be addressed. For instance banks can decide on
initially focusing on the basic IT assets (hardware and software) and the services and assets that are business
critical or covered by legal regulatory compliance.
Components that can be considered as part of Service Asset and Configuration Management are:
Configuration Items: These can be a service asset or component, or any item that is under the control of
configuration management. Depending on established strategy
configuration, the item may vary widely in complexity, size and type. It can range from an entire
service or system to a single software module or a minor software component.
If desired, banks can define a hierarchical structure for configuration items. For instance banks can define
Core Banking as a configuration item which can have different application as a subset Configuration Item
of the Core Banking configuration item. Each configuration item can have modules as sub set which can
have two configuration item, these being hosting and application support. Hosting can then be further
sub-divided into configuration item that can be servers, operating systems, databases, network components.
Configuration Management System: To manage large and complex IT environment banks may consider
implementation of supporting system known as Configuration Management System. Beside holding
information about configuration items, their components and relationship between configuration items
Configuration Management System can also be used to correlate services and configuration items; this
kind of snapshot will assist in proactively identifying incidents, events etc.
Secure libraries: Secure library is a collection of software, electronic or document CIs. Access to items in a
secure library is restricted. The secure library is used for controlling and releasing components
throughout the service lifecycle.
Definitive Media Library: Definitive media library (DML) is a secure library that may be used to store
definitive authorised versions of all media CIs. It stores master copies of versions that have passed
quality assurance checks.
Configuration Baseline: This baseline is the configuration of a service, product or infrastructure that has
been formally reviewed and agreed on, that thereafter serves as the basis for further activities and that
can be changed only through formal change procedure. Configuration baseline captures and represents
a set of configuration items that are related to each other.
Change Management: This process provides guidelines which can be used by the banks for handling
changes to ensure that the changes are recorded, assessed, authorised, prioritised, planned, tested,
implemented, documented and reviewed in a controlled manner and environment. The primary
objective of the change management procedures is to ensure assessment of:
Risks
Change authorization
Business Continuity
Change impact
iv) Operations
This phase, as a part of Service Management lifecycle, is responsible for executing and performing processes
that optimise the cost of the quality of services. As a part of the organisation, it's responsible for enabling
businesses to meets objectives. As a part of technology, it's responsible for effective functioning of components
that support business services.
Event Management
Event Management process provides the guidelines which can be used by the banks to define the framework for
monitoring all the relevant events that occurs through the IT infrastructure. It provides the entry point for the
execution of many Service Operations processes and activities.
Event can be defined as any detectable or discernible occurrence that has significance for the management of the
IT infrastructure, or delivery of IT services. Event Management framework when defined will have two
mechanisms for monitoring, these are:
Active Monitoring: Active monitoring is related to polling of business significant Configuration Items to
determine their status and availability. Any diversion from normal status should be reported to appropriate
team for action.
Passive Monitoring: Passive monitoring detects and correlate operational alerts or communications
generated by Configuration Items.
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
Event Management can be applied to any aspect of Service Management that needs to be controlled. These
components can be:
Configuration Items
Environment conditions
Security breaches
Event Management portfolio can have different kind of event, some of these are:
Informational: Events signifying regular operations for instance notification that a scheduled job has
completed
Warning: Events signifying diversion from normal course of action, for instance a user attempting to login
with incorrect password. Exceptional events will require further investigation to determine an environment
which may have led to an exception
Exceptions: Events, which are unusual. Events may require closer monitoring. In some case the condition
will resolve itself. For instance, unusual combinations of workloads as they are completed, normal
operations will restore. In other cases, operations intervention will be required if the situation is repeated
Incident Management
An incident is an unplanned interruption to an IT service, or the reduction in the quality of an IT service. Failure
of a configuration item that has not yet impacted service shall also be an incident.
Incident Management process provides guidelines that can be implemented by the banks for the management of
incidents so that restoration of service operations as quickly as possible and to minimise adverse impact on
business operations. The primary objective of the Incident Management procedures is to ensure best possible
level of service quality and availability.
Problem Management
Problem Management process provides a framework, which can be implemented by banks to minimise the
adverse impact of incidents on the IT Infrastructure and the business by identifying root cause, logging known
errors, providing and communicating workarounds, finding permanent solutions, and preventing recurrence of
incidents related to these errors. Problem Management increases stability and integrity of the infrastructure.
Problem Management process includes activities required to carry out the root causes of incidents and to
determine the resolution to these underlying problems. Problem management procedures also include
implementation of the resolution through Change
Management procedures and Release Management procedures. This also includes appropriate turnaround and
resolutions to incidents that cannot be resolved due to business cases, or technical short falls. Periodic trend
analysis of the problems in respect of systems or customer facing channels may be carried out and appropriate
action taken.
Access Management
Access Management process provides the guidelines, which can be implemented by banks to limit access to IT
services only to those individuals and applications that are duly authorised based on organisational policies and
standards. Access Management enables the organisation to manage confidentiality, integrity of the
organisation’s data, IT infrastructure, and applications.
Introduction
The pivotal role that banking sector plays in the economic growth and stability, both at national and individual
level, requires continuous and reliable services. Increased contribution of 24x7 electronic banking channels has
increased the demand to formulate consolidated Business Continuity Planning (BCP) guidelines covering
critical aspects of people, process and technology.
BCP forms a part of an organisation's overall Business Continuity Management (BCM) plan, which is the
“preparedness of an organisation”, which includes policies, standards and procedures to ensure continuity,
resumption and recovery of critical business processes, at an agreed level and limit the impact of the disaster on
people, processes and infrastructure (includes IT); or to minimise the operational, financial, legal, reputational
and other material consequences arising from such a disaster.
Effective business continuity management typically incorporates business impact analyses, recovery strategies
and business continuity plans, as well as a governance programme covering a testing programme, training and
awareness programme, communication and crisis management programme.
A bank’s Board has the ultimate responsibility and oversight over BCP activity of a bank. The Board approves
the Business Continuity Policy of a bank. Senior Management is responsible for overseeing the BCP process
which includes:
Determining how the institution will manage and control identified risks
BCP
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Compiled by Srinivas Kante Email: [email protected]
Designating a BCP committee who will be responsible for the Business Continuity Management
The top management should annually review the adequacy of the institution's business recovery,
contingency plans and the test results and put up the same to the Board.
The top management should consider evaluating the adequacy of contingency planning and their periodic
testing by service providers whenever critical operations are outsourced.
Ensuring that the BCP is independently reviewed and approved at least annually;
Ensuring employees are trained and aware of their roles in the implementation of the
BCP
Reviewing the BCP testing programme and test results on a regular basis and
Ensuring the BCP is continually updated to reflect the current operating environment
Developing of an enterprise-wide BCP and prioritisation of business objectives and critical operations that
are essential for recovery
Business continuity planning to include the recovery, resumption, and maintenance of all aspects of the
23business, not just recovery of the technology components; Considering the integration of the
institution’s role in financial markets;
Regularly updating business continuity plans based on changes in business processes, audit
recommendations, and lessons learned from testing
Following a cyclical, process-oriented approach that includes a business impact analysis (BIA), a risk
assessment, management and monitoring and testing
Considering all factors and deciding upon declaring a “crisis”
Since electronic banking has functions spread across more than one department, it is necessary that each
department understands its role in the plan. It is also important that each gives its support to maintain it. In case
of a disaster, each has to be prepared for a recovery process, aimed at protection of critical functions. To this end,
it would be helpful if a set up like the BCP Committee, charged with the implementation of BCP, in an
eventuality and all departments expected to fulfill their respective roles in a coordinated manner.
Hence, a committee consisting of senior officials from departments like HR, IT, Legal, Business and Information
Security needs to be instituted with the following broad mandate:
Ensure that the Business Continuity Plan (BCP) fits with other plans and requirement of concerned
authorities
Budgetary issues
Co-ordinating the activities of other recovery, continuity, response teams and handling key decision-making
They determine the activation of the BCP
Other functions entail handling legal matters evolving from the disaster, and handling public relations and
media inquiries
There needs to be adequate teams for various aspects of BCP at central office, as well as individual controlling
offices or at a branch level, as required. Among the teams that can be considered based on need, are the incident
response team, emergency action and operations team, team from particular business functions, damage
assessment team, IT teams for hardware, software, network support, supplies team, team for organizing logistics,
relocation team, administrative support team, coordination team. Illustrative guidelines for committees or teams
for BCP are provided in Annex C.
The BCP requirements enunciated in this document should be considered. The onus lies on the Board and Senior
Management for generating detailed components of BCP in the light of an individual bank's activities, systems
and processes.
Banks should consider looking at BCP methodologies and standards–BS 25999 by BSI– which follows the
“Plan-Do-Check-Act Principle”.
Identification of critical businesses, owned and shared resources with supporting functions to come up with
the Business Impact Analysis (BIA)
Formulating Recovery Time Objectives (RTO), based on BIA. It may also be periodically fine-tuned by
benchmarking against industry best practices
Critical and tough assumptions in terms of disaster, so that the framework would be exhaustive enough to
address most stressful situations
Identification of the Recovery Point Objective (RPO), for data loss for each of the critical systems and
strategy to deal with such data loss
Alternate procedures during the time systems are not available and estimating resource requirements
Structured risk assessment based on comprehensive business impact analysis. This assessment considers all
business processes and is not limited to the information processing facilities.
Risk management by implementing appropriate strategy/ architecture to attain the bank’s agreed RTOs and
RPOs.
Impact on restoring critical business functions, including customer-facing systems and payment and
settlement systems such as cash disbursements, ATMs, internet banking, or call centres
BCP should evolve beyond the information technology realm and must also cover people, processes and
infrastructure
The methodology should prove for the safety and well-being of people in the branch / outside location at the
time of the disaster.
Define response actions based on identified classes of disaster.
To arrive at the selected process resumption plan, one must consider the risk acceptance for the bank,
industry and applicable regulations
Action plans, i.e.: defined response actions specific to the bank’s processes , practical manuals( do and
don’ts, specific paragraph’s customised to individual business units) and testing procedures
Compatibility and co-ordination of contingency plans at both the bank and its service providers
The recovery procedure should not compromise on the control environment at the recovery location
Having specific contingency plans for each outsourcing arrangement based on the degree of materiality of
the outsourced activity to the bank's business
Periodic updating to absorb changes in the institution or its service providers. Examples of situations that
might necessitate updating the plans include acquisition of new equipment, upgradation of the operational
systems and changes in:
Personnel
Probability of unplanned events, including natural or man-made disasters, earthquakes, fire, hurricanes
or bio-chemical disaster
Security threats
Banks must consider implementing a BCP process to reduce the impact of disruption, caused by disasters
and security failures to an acceptable level through a combination of preventive and recovery measures.
BCP should include measures to identify and reduce probability of risk to limit the consequences of
damaging incidents and enable the timely resumption of essential operations. BCP should amongst
others, consider reputation, operational, financial, regulatory risks.
The failure of critical systems or the interruption of vital business processes could prevent timely recovery
of operations. Therefore, financial institution management must fully understand the vulnerabilities
associated with interrelationships between various systems, departments, and business processes. These
vulnerabilities should be incorporated into the BIA, which analyses the correlation between system
components and the services they provide.
Various tools can be used to analyse these critical interdependencies, such as a work flow analysis, an
organisational chart, a network topology, and inventory records. A work flow analysis can be
performed by observing daily operations and
interviewing employees to determine what resources and services are shared among various
departments. This analysis, in conjunction with the other tools, will allow management to understand
various processing priorities, documentation requirements, and the interrelationships between various
systems. The following issues when determining critical interdependencies within the organisation:
Key personnel;
Vital records;
Shared equipment, hardware, software, data files, and workspace;
Production processes;
Customer services;
Network connectivity; and
Management information systems.
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Compiled by Srinivas Kante Email: [email protected]
Ensuring prompt and accurate processing of securities transactions, including, but not limited
to, order taking, order entry, execution, comparison, allocation, clearance and settlement of
securities transactions, the maintenance of customer accounts, access to customer accounts
and the delivery of funds and securities.
A single framework of BCP should be maintained to ensure that all plans are consistent, and to identify
priorities and dependencies for testing and maintenance.
Conditions for activating plans, which describe a process to be followed (how to assess the situation, who is
to be involved, etc.) before each plan is activated
Emergency procedures, which describe the actions to be taken following an incident which jeopardises
business operations and/ or human life. This should include arrangements for public relations
management and for effective liaison with appropriate public authorities e.g. police, fire service,
health-care services and local government
Identification of the processing resources and locations, available to replace those supporting critical
activities; fall back procedures which describe the actions to be taken to move essential business
activities or support services to alternative temporary locations and to bring business processes back
into operation in the required time-scales
Identification of information to be backed up and the location for storage, as well as the requirement for the
information to be saved for back-up purpose on a stated schedule and compliance therewith
Resumption procedures, which describe the actions to be taken to return to normal business operations
A maintenance schedule which specifies how and when the plan will be tested and the process for
maintaining the plan
Awareness and education activities, which are designed to create understanding of critical banking
operations and functions, business continuity processes and ensure
that the processes continue to be effective
The responsibilities of the individuals, describing who is responsible for executing which component of the
plan. Alternatives should be nominated as required.
Pandemics are defined as epidemics, or outbreaks in humans, of infectious diseases that have the ability to
spread rapidly over large areas, possibly worldwide. Adverse economic effects of a pandemic could be
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Compiled by Srinivas Kante Email: [email protected]
significant, both nationally and internationally. Due to their crucial financial and economic role, financial
institutions should have plans in place that describe how they will manage through a pandemic event.
Pandemic planning presents unique challenges to financial institution management. Unlike natural disasters,
technical disasters, malicious acts, or terrorist events, the impact of a pandemic is much more difficult to
determine because of the anticipated difference in scale and duration. Further, while traditional disasters and
disruptions normally have limited time durations, pandemics generally occur in multiple waves, each lasting two
to three months. Consequently, no individual or organisation is safe from the adverse effects that might result
from a pandemic event.
One of the most significant challenges likely from a severe pandemic event will be staffing shortages due to
absenteeism. These differences and challenges highlight the need for all financial institutions, no matter their
size, to plan for a pandemic event when developing their BCP.
It is important for institutions to actively keep abreast of international and national developments and health
advisories issued in this regard.
A preventive programme to reduce the likelihood that a bank’s operations will be significantly
affected by a pandemic event, including: monitoring of potential outbreaks, educating employees,
communicating and coordinating with critical service providers and suppliers, in addition to providing
appropriate hygiene training and tools to employees.
A documented strategy that provides for scaling the institution’s pandemic efforts so they are
consistent with the effects of a particular stage of a pandemic outbreak, such as first cases of humans
contracting the disease overseas or in India and first cases within the organisation itself. The strategy
will also need to outline plans that state how to recover from a pandemic wave and proper preparations
for any following wave(s).
A comprehensive framework of facilities, systems, or procedures that provide the organisation the
capability to continue its critical operations in the event that large numbers of the institution’s staff are
unavailable for prolonged periods. Such procedures could include social distancing to minimise staff
contact, telecommuting, redirecting customers from branch to electronic banking services, or
conducting operations from alternative sites.
The framework should consider the impact of customer reactions and the potential demand for, and
increased reliance on, online banking, telephone banking, ATMs, and call support services. In addition,
consideration should be given to possible actions by public health and other government authorities that
may affect critical business functions of a financial institution.
A testing programme to ensure that the institution’s pandemic planning practices and capabilities
are effective and will allow critical operations to continue.
An oversight programme to ensure ongoing review and updates to the pandemic plan so that
policies, standards, and procedures include up-to-date, relevant information provided by governmental
sources or by the institution’s monitoring programme.
Banks may also consider insurance to transfer risk to a third party, however taking due care
regarding certainty of payments in the event of disruptions.
Testing A BCP
– Banks must regularly test BCP to ensure that they are up to date and effective: Testing of BCP should include
all aspects and constituents of a bank i.e. people, processes and resources (including technology). BCP, after full
or partial testing may fail. Reasons are incorrect assumptions, oversights or changes in equipment or personnel.
BCP tests should ensure that all members of the recovery team and other relevant staff are aware of the plans.
The test schedule for BCPs should indicate how and when each component of a plan is to be tested. It is
recommended to test the individual components of the plans(s) frequently, typically at a minimum of once a
year. A variety of techniques should be used in order to provide assurance that the plan(s) will operate in real
life.
– Banks should involve their Internal Auditors (including IS Auditors) to audit the effectiveness of BCP: And its
periodic testing as part of their Internal Audit work and their findings/ recommendations in this regard should be
incorporated in their report to the Board of Directors.
– Banks should consider having a BCP drill planned along with the critical third parties: In order to provide
services and support to continue with pre-identified minimal required processes.
– Banks should also periodically moving their operations: Including people, processes and resources (IT and
non-IT) to the planned fall-over or DR site in order to test the BCP effectiveness and also gauge the recovery
time needed to bring operations to normal functioning.
– Banks should consider performing the above test without movement of bank personnel to the DR site. This will
help in testing the readiness of alternative staff at the DR site.
– Banks should consider having unplanned BCP drill: Wherein only a restricted set of people and certain
identified personnel may be aware of the drill and not the floor or business personnel. In such cases banks
should have a “Lookout Team” deployed at the location to study and assimilate the responses and needs of
different teams. Based on the outcome of this study, banks should revise their BCP Plan to suit the ground
requirements.
The below are few of the illustrative techniques that can be used for BCP testing purposes:
Table-top testing for scenarios (discussing business recovery arrangements using example interruptions)
Simulations (particularly for training people in their post-incident or crisis
management roles)
Testing recovery at an alternate site (running business processes in parallel with recovery operations
away from the main site)
Tests of supplier facilities and services (ensuring externally provided services and products will meet
the contracted commitment)
Complete rehearsals (testing that the organisation, personnel, equipment, facilities and processes can
cope with interruptions)
Simulation testing: It is when participants choose a specific scenario and simulate an on-location BCP
situation. It involves testing of all resources: people, IT and others, who are required to enable the business
continuity for a chosen scenario. The focus is on demonstration of capability, including knowledge, team
interaction and decision-making capabilities. It can also specify role playing with simulated response at alternate
locations/facilities to act out critical steps, recognise difficulties, and resolve problems.
Component testing: This is to validate the functioning of an individual part or a sub-process of a process, in
the event of BCP invocation. It focuses on concentrating on in-depth testing of the part or sub-process to
identify and prepare for any risk that may hamper its smooth running. For example, testing of ATM switch.
Each organisation must define frequency, schedule and clusters of Business Areas, selected for test after a
through Risk and Business Impact Analysis has been done.
The bank can consider broad guidelines provided below for determining the testing frequency based on critical
of a process:
BCPs should be maintained by annual reviews and updates to ensure their continued effectiveness.
Procedures should be included within the organisation’s change management programme to ensure that
business continuity matters are appropriately addressed. Responsibility should be assigned for regular
reviews of each business continuity plan. The identification of changes in business
arrangements/processes, not yet reflected in the business continuity plans, should be followed by an
appropriate update of the plan on a periodic basis, say quarterly. This would require a process of
conveying any changes to the institution’s business, structure, systems, software, hardware, personnel,
or facilities to the BCP coordinator/team. If significant
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
changes have occurred in the business environment, or if audit findings warrant changes to the BCP or
test programme, the business continuity policy guidelines and programme requirements should be
updated accordingly.
Changes should follow the bank’s formal change management process in place for its policy or
procedure documents. This formal change control process should ensure that the updated plans are
distributed and reinforced by regular reviews of the complete plan.
A copy of the BCP, approved by the Board, should be forwarded for perusal to the RBI on an annual
basis. In addition, the bank should also submit:
– An annual statement at the end of each financial year describing the critical systems, their Rots and
the bank’s strategy to achieve them, and
– A quarterly statement, reporting major failures during the period for critical systems, customer
segment or services impacted due to the failures and steps taken to avoid such failures in future.
An effective BCP should take into account the potential of wide area disasters, which impact an entire
region, and for resulting loss or inaccessibility of staff. It should also consider and address inter
dependencies, both market-based and geographic, among financial system participants as well as
infrastructure service providers.
Further, banks should also consider the need to put in place necessary backup sites for their critical
payment systems which interact with the systems at the Data centres of the Reserve Bank.
Banks may also consider running some critical processes and business operations from primary and the
secondary sites, wherein each would provide back-up to the other.
Namely prioritising process and alternative location for personnel in the following categories:
• Sales staff
• IT staff
• Comprehensive testing would help banks to further fine-tune BCP/DR processes to ensure their
robustness and also enable smooth switch-over to the DR site, as per the priority and scale of
processes identified for each process.
All critical processes should be documented to reduce dependency on personnel for scenarios where the
staff is not able to reach the designated office premises.
Backup/standby personnel should be identified for all critical roles. A call matrix should be developed
to better co-ordinate future emergency calls involving individual financial authorities, financial sector
trade associations, and other banks and stakeholders. In addition the organisation should have calling
tree with branches
across specific region/business processes. Based on the nature of the emergency a particular branch/the
entire calling tree should be activated.
The relevant portion of the BCP adopted should also be disseminated to all concerned, including the
customers, so that the awareness would enable them to react positively and in consonance with the
BCP. This would help maintain the customer’s faith on the banking institution, and the possibility of a
bank-run would be exponentially minimised. The part of the plan kept in the public domain should
normally be confined to information relating to the general readiness of the banks in this regard without
any detailed specifics, to protect the banks from becoming vulnerable to security threats
Banks should consider formulating a clear ‘Communication Strategy’ with the help of media management
personnel to control the content and form of news being percolated to their customers in times of panic.
Banks should consider having a detailed BCP plan for encountering natural calamity/ disaster situation. A
formal exception policy should be documented which will guide the affected areas Personnel to act
independently till connection to the outside world is resumed.
The above mentioned guideline should have exceptions documented for critical process which will ensure
continuation of critical process without the regular operational formalities.
After appropriate approvals or permissions are obtained internally and from RBI, banks should consider
having a guideline ready on relaxing certain rules/ requirements for customers affected by the calamity.
Like:
Banks can consider expediting cheque clearing for customers by directing all cheques to a different region
than the one affected by the calamity. In case of severe calamity banks should consider restricting
existing loans to facilitate rebuilding efforts by the Govt. for the calamity areas. The banks may also be
consider ensuring quick processing of loan applications, preferably within 48 hours of receipt of such
applications. It should consider dispatching credit bill, agreement notes, etc. due to customer by having
an arrangement to print the same at an alternative location and should consider accepting late payments
for credit card dues for customers in the calamity affected area.
Banks may also endeavor for resumption of banking services by setting up satellite offices, extension
counters or mobile banking facilities.
– Banks should consider paying special attention to availability of basic amenities such as electricity, water and
first-aid box in all offices. (e.g. evaluate the need of electricity backup not just for its systems but also for its
people and running the infrastructure like central air-conditioning.)
– Banks should consider assigning ownership for each area. Emergency procedures, manual fallback plans and
resumption plans should be within the responsibility of the owners of the appropriate business resources or
processes involved.
– In-house telecommunications systems and wireless transmitters on buildings should have backup power.
Redundant systems, such as analogue line phones and satellite phones (where appropriate), and other simple
measures, such as ensuring the availability of extra batteries for mobile phones, may prove essential to
maintaining communications in a wide-scale infrastructure failure.
– Possible fallback arrangements should be considered and alternative services should be carried out in
co-ordination with the service providers, contractors, suppliers under written agreement or contract, setting out
roles and responsibilities of each party, for meeting emergencies. Also, imposition of penalties, including legal
action, may be initiated by an organisation against service providers or contractors or suppliers, in the event of
noncompliance or non-co-operation.
– When new requirements are identified, established emergency procedures: e.g. evacuation plans or any
existing fallback arrangements, should be amended as appropriate.
– Banks may consider having backup resources (erg. stationery required for cheque printing, special printers,
stamps) at a secondary operational location.
– The plans may also suitably be aligned with those of the local government authorities
– Banks should consider not storing critical papers, files, servers in the ground floors where there is possibility
of floods or water logging. However, banks should also consider avoiding top floors in taller building to reduce
impact due to probable fire.
– Fire-proof and water-proof storage areas must be considered for critical documents.
– Banks should consider having alternative means of power source (like procurement of more diesel/ emergency
battery backup etc.) for extended period of power cuts.
– Banks should consider having an emergency helpline number or nationalised IVR message to resolve queries
of customers and ensure that panic situation is avoided. For this an alternative backup area call centre should be
identified to take over part load of the calamity affected area. Designated person/ team must be responsible for
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
enabling line diversion. A similar service can also be considered for the benefit of employee related
communication.
People are a vital component of any organisation. They should therefore be an integral part of a BCP. Generally,
plans are often too focused on the technical issues, therefore, it is suggested that a separate section relating to
people should be incorporated, including details on staff welfare, counseling, relocation considerations, etc. BCP
awareness programmer should also be implemented which serve to strengthen staff involvement in BCP. This
can be done through induction programme newsletters, staff training exercises, etc.
Banks must consider training more than one individual staff for specific critical jobs (ire. in the absence on one
employee the work must not be stalled or delayed). They must consider cross-training employees for critical
functions and document-operating procedures. Banks should consider possibility of enabling work-from--home
capabilities and resources for employees performing critical functions.
Crisis Management Team: As a core member of the CMT, HR provides guidance to team on people-related
issues, including evacuation, welfare, whether to invoke the HR incident line, alternative travel arrangements
and what to communicate to staff.
HR Incident Line: Operated from within the centralised HR function, the incident helpline is invoked in
those instances, where there are possible casualties or missing staff, as a result of an incident. Invoked by the
CMT, the line is manned by qualified HR officers trained in how to deal with distressed callers. The staff may
be provided with an emergency card, which includes the incident line number. Information on the hotline is
updated on a regular basis. The facility enables line managers to keep the central crisis team up to speed on the
whereabouts and well-being of staff. Ongoing welfare and support for staff is also provided via an employee
assistance provider.
Exceptional Travel arrangements: Transportation plans should be considered in the event of the need to
relocate. Key staff needs to be identified including details of where they are located, and vehicles are on standby
to transport them if required.
The are many applications and services in banking system that are highly mission critical in nature and therefore
requires high availability, and fault tolerance to be considered while designing and implementing the solution.
This aspect is to be taken into account especially while designing the data centre solution and the corporate
network solution.
Prior to selecting a data recovery (DR) strategy, a DR planner should refer to their organisation's BCP, which
should indicate key metrics of recovery point objective and recovery time objective for business processes:
Recovery Point Objective (RPO)–The acceptable latency of data that will be recovered
Recovery Time Objective (RTO)–The acceptable amount of time to restore the function
Recovery Point Objective must ensure that the Maximum Tolerable Data Loss for each activity is not exceeded.
The Recovery Time Objective must ensure that the Maximum Tolerable Period of Disruption (MTPD), for each
activity, is not exceeded. The metrics specified for the business processes must then be mapped to the
underlying IT systems and infrastructure that support those processes. Once, RTO and RPO metrics have been
mapped to the IT infrastructure, the DR planner can determine the most suitable recovery strategy for each
system. An important note here, however, is that the business ultimately sets the IT budget. Therefore, RTO and
RPO metrics need to fit with the available budget and the critical of the business process/function.
Backups made to tape and sent off-site at regular intervals (preferably daily)
Backups made to disk on-site and automatically copied to off-site disk, or made directly to off-site
disk
Replication of data to an off-site location, which overcomes the need to restore the data (only the
systems then need to be restored or synced). This generally makes use of storage area network
(SAN) technology
High availability systems that keep both data and system replicated, off-site, enabling continuous access to
systems and data
In many cases, an organisation may elect to use an outsourced disaster recovery provider to provide a stand-by
site and systems rather than using their own remote facilities. In addition to preparing for the need to recover
systems, organisations must also implement precautionary measures with an objective of preventing a disaster in
the first place. These may include some of the following:
Local mirrors of systems or data. Use of disk protection technology such as RAID
Surge protectors—to minimise the effect of power surges on delicate electronic equipment
Uninterrupted power supply (UPS) or backup generator to keep systems going in the event of a power
failure
A disaster recovery plan is a part of the BCP. It dictates every facet of the recovery process, including:
What people in the organisation have the authority to declare a disaster and thereby put the
plan into effect;
The sequence of events necessary to prepare the backup site once a disaster has been declared;
The roles and responsibilities of all key personnel with respect to carrying out the plan;
A schedule listing the personnel that will be staffing the backup site, including a rotation
schedule to support ongoing operations without burning out the disaster team members.
A disaster recovery plan must be a living document; as the data centre changes, the plan must be updated to
reflect those changes.
It is to be noted that the technology issues are a derivative of the Business Continuity plan and Management.
For example, BCP and Management will lead to the Business Impact Analysis, which will lead to the
Performance Impact Analysis (PIA). That will depend on the Technology Performance of the total IT Solution
Architecture.
To amplify business impact analysis is to identify the critical operations and services, key internal and external
dependencies and appropriate resilience levels. It also analysis the risks and quantify the impact of those risks
from the point of view of the business disruptions. For example, in order to provide state of the art customer
services both at the branch level and the delivery channels we need to take into account the services levels that
are committed.
If an ATM transaction has to take place in 10 seconds and cash withdrawal or deposit has to take place in 60
seconds at the counter, then based on the load one can compute the number of customers who can be serviced in
a day. The above example is to understand the fact that the business latency introduced by the system is a
combination of technology, process and people. Therefore, the technical latency is a derivative of the committed
business latency and the technology solution architecture has to deliver the same under varying loads.
Performance
Availability
Performance of the technology solution architecture for operations needs to be quantified. It should be possible
to measure, as and when required, the quantified parameters. (For example, if the latency for a complex
transaction initiated at the branch has to be completed in four seconds under peak load, it should be possible to
have adequate measuring environments to ensure that performance degradations have not taken place due to
increasing loads.)
Solution architecture has to be designed with high -availability, and no single point of failure. It is inevitable
that a complex solution architecture with point products from different sources procured and implemented at
different points in time will have some outage once in a while and the important issue is that with clearly
defined SLAs, mean time to restore, it should be possible to identify the fault and correct the same without any
degradation in performance.
Accordingly, with respect to the performance and availability aspects the following architectures have to be
designed and configured to provide high levels of up time round the clock to ensure uninterrupted functioning.
– Based on the above observation, banks are required to do the following: Take up the performance and
availability audit of the solutions deployed to ensure that the architecture is designed and implemented with no
single point of failure.
– Audit the deployed architecture for all the mission critical applications and services and resolve the concerns
that arise in a time bound manner.
– Periodically investigate the outages that are experienced from time to time, which are mini disasters that result
in non availability of services for a short span of time, systems not responding when transactions are initiated at
the branch level, delivery channels not functioning for a brief period of time to ensure that the customer service
is not affected.
– Ensure availability of appropriate technology solutions to measure and monitor the functioning of
products. And, have competent and capable technical people within the system to resolve issues
expeditiously.
The issues detailed above have to be borne in mind while finalising the data centre architecture and the
corporate network architecture which are expected to have redundancy built in the solution with no single
point of failure.
With reference to the network architecture it is recommended that the Banks built in redundancies as
under:
Backup site: Is a location where an organisation can easily relocate following a disaster, such as fire, flood,
terrorist threat or other disruptive event. This is an integral part of the disaster recovery plan and wider
business continuity planning of an organisation. A backup site can be another location operated by the
organisation, or contracted via a company that specialises in disaster recovery services. In some cases, an
organisation will have an agreement with a second organisation to operate a joint backup site.
cold sites
warm sites
hot sites
Differences between them are determined by costs and effort required to implement each.
Another term used to describe a backup site is a work area recovery site.
Cold Sites: A cold site is the most inexpensive type of backup site for an organisation to operate. It does
not include backed up copies of data and information from the original location of the organisation, nor
does it include hardware already set up. The lack of hardware contributes to the minimal start up costs of
the cold site, but requires additional time following the disaster to have the operation running at a capacity
close to that prior to the disaster.
Hot Sites: A hot site is a duplicate of the original site of the organisation, with full computer systems as
well as near-complete backups of user data. Real-time synchronisation between the two sites may be used
to mirror the data environment of the original site, using wide area network links and specialised software.
Following a disruption to the original site, the hot site exists so that the organisation can relocate with
minimal losses to normal operations. Ideally, a hot site will be up and running within a matter of hours or
even less. Personnel may still have to be moved to the hot site so it is possible that the hot site may be
operational from a data processing perspective before staff has relocated. The capacity of the hot site may
or may not match the capacity of the original site depending on the organisation's requirements. This type
of backup site is the most expensive to
operate. Hot sites are popular with organisations that operate real time processes such as financial institutions,
government agencies and ecommerce providers
Warm Sites: A warm site is, quite logically, a compromise between hot and cold. These sites will have hardware
and connectivity already established, though on a smaller scale than the original production site or even a hot
site. Warm sites will have backups on hand, but they may not be complete and may be between several days and
a week old. An example would be backup tapes sent to the warm site by courier
8.1 The following issues arise in choosing a back up site and implementing a DC/DR solution:
Solution architectures of DC and DR are not identical for all the applications and services. Critical
applications and services, namely the retail, corporate, trade finance and government business solutions as well
as the delivery channels are having the same DR configurations whereas surround or interfacing applications do
not have the DR support. Banks will have to conduct periodical review with reference to the above aspect and
upgrade the DR solutions from time to time and ensure that all the critical applications and services have a
perfect replica in terms of performance and availability.
The configurations of servers, network devices and other products at the DC and DR have to be identical at
all times. This includes the patches that are applied at the DC periodically and the changes made to the software
from time to time by customization and parameterization to account for the regulatory requirements, system
changes etc .
Periodic checks with reference to ensuring data and transaction integrity between DC and DR are mandatory.
It could be done over the week end or as a part of the EoD / BoD process.
Solutions have to have a defined Recovery Time Objective (RTO) and Recovery Point Objective (RPO)
parameter. These two parameters have a very clear bearing on the technology aspects as well as the process
defined for cut over to the DR and the competency levels required moving over in the specified time frame.
Values chosen for the RTO and RPO is more to follow the industry practice and not derived from first
principles. Therefore, the DR drills that are conducted periodically have to ensure that the above parameters are
strictly complied with.
Technology operations processes which support business operations (such as EOD/ BOD) need to formally
included into the IT Continuity Plan.
Banks may also consider Recovery Time Objective and Recovery Point Objectives (RTO/ RPO) for services
being offered and not just a specific application. For example--for internet portal and not retail banking. This is
done to avoid any inconsistency in business users understanding.
DR drills currently conducted periodically come under the category of planned shutdown. Banks have to
evolve a suitable methodology to conduct the drills which are closer to the real disaster scenario so that the
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
confidence levels of the technical team taking up this exercise is built to address the requirement in the event of
a real disaster.
It is also recommended that the support infrastructure at the DC and DR, namely the electrical systems,
air-conditioning environment and other support systems have no single point of failure and do have a building
management and monitoring system to constantly and continuously monitor the resources. If it is specified that
the solution has a high availability of
95 measured on a monthly basis and a mean time to restore of 2 hrs in the event of any failure, it has to
include the support system also.
Data replication mechanism followed between DC and DR is the asynchronous replication mechanism and
implemented across the industry either using database replication techniques or the storage based replication
techniques. They do have relative merits and demerits. The RTO and RPO discussed earlier, along with the
replication mechanism used and the data transfer required to be accomplished during the peak load will decide
the bandwidth required between the DC and the DR. The RPO is directly related to the latency permissible for
the transaction data from the DC to update the database at the DR. Therefore, the process implemented for the
data replication requirement has to conform to the above and with no compromise to data and transaction
integrity.
Given the need for drastically minimizing the data loss during exigencies and enable quick recovery and
continuity of critical business operations, banks may need to consider near site DR architecture. Major banks
with significant customer delivery channel usage and significant participation in financial markets/payment and
settlement systems may need to have a plan of action for creating a near site DR architecture over the medium
term (say, within three years).
Despite considerable advances in equipment and telecommunications design and recovery services, IT
disaster recovery is becoming challenging. Continuity and recovery aspects are impacting IT strategy
and cost implications are challenging IT budgets.
The time window for recovery is shrinking in face of the demand for 24 / 365 operations. Some studies
claim that around 30 percent of high-availability applications have to be recovered in less than three
hours. A further 45 percent within 24 hours, before losses become unsustainable; others claim that 60
percent of Enterprise Resource Planning (ERP) Systems have to be restored in under 24 hours. This
means that traditional off-site backup and restore methods are often no longer adequate. It simply takes
too long to recover incremental and full image backups of various inter-related applications (backed up
at different times), synchronise them and re-create the position as at disaster. Continuous
operation–data mirroring to off-site locations and standby computing and telecommunications–may be
the only solution.
A risk assessment and business impact analysis should establish the justification for continuity for specific
IT and telecommunication services and applications.
Achieving robust security (security assurance) is not a onetime activity. It cannot be obtained just by
purchasing and installing suitable software and hardware. It is a continuous process that requires
regular assessment of the security health of the organisation and proactive steps to detect and fix any
vulnerability. Every bank should have in place quick and reliable access to expertise for tracking
suspicious behavior, monitoring users and performing forensics. Adequate reporting to the authorities
concerned – such as the RBI/ IDRBT/CERT-In and other institutions should be an automatic sub
process whenever such events occur.
Random Security Preparedness. It is proposed that a sufficiently large ``question bank'' related to
security health of the organization be prepared and given to RBI's inspection teams who go for
inspection of banks. A random subset of these queries could then be given to a bank’s IT team for
which answers need to be
provided in near real time. Sample checks related to user accounts could be the number of new
accounts, terminated accounts, most active accounts. There could also be demonstrations of data
recovery from archives.
Telecommunications issues may also arise: It is important to ensure that relevant links are in place and that
communications capability is compatible. The adequacy of voice and data capacity needs to be checked.
Telephony needs to be switched from the disaster site to the standby site. A financial institution’s BCP
should consider addressing diversity guidelines for its telecommunications capabilities. This is
particularly important for the financial services sector that provides critical payment, clearing, and
settlement processes; however, diversity guidelines should be considered by all financial institutions
and should be commensurate with the institution’s size, complexity, and overall risk profile. Diversity
guidelines may include arrangements with multiple telecommunications providers. However, diverse
routing may be difficult to achieve since primary telecommunications carriers may have an agreement
with the same sub-carriers to provide local access service, and these sub-carriers may also have a
contract with the same local access service providers. Financial institutions do not have any control
over the number of circuit segments that will be needed, and they typically do not have a business
relationship with any of the sub-carriers. Consequently, it is important for financial institutions to
understand the relationship between their primary telecommunications carrier and these various
sub-carriers and how this complex network connects to their primary and back-up facilities. To
determine whether telecommunications providers use the same sub-carrier or local access service
provider, banks may consider performing an end-to-end trace of all critical or sensitive circuits to
search for single points of failure such as a common switch, router, PBX, or central telephone office.
Banks may consider the following telecommunications diversity components to enhance BCP:
Internet protocol networking equipment that provides easily configurable re-routing and traffic
load balancing capabilities
Local services to more than one telecommunications carrier’s central office, or diverse
physical paths to independent central offices
Frame relay circuits that do not require network interconnections, which often causes delays
due to concentration points between frame relay providers
Separate power sources for equipment with generator or uninterrupted power supply back-up
Regular use of multiple facilities in which traffic is continually split between the
connections; and
Banks need to monitor their service relationship with telecommunications providers: In order to manage the
inherent risks more effectively. In coordination with vendors, management should ensure that risk
management strategies include
– Establish service level agreements that address contingency measures and change management for
services provided;
– Ensure that primary and back-up telecommunications paths do not share a single point of failure
– Establish processes to periodically inventory and validate telecommunications circuits and routing
paths through comprehensive testing.
Some vendors offer a drop-ship service as an alternative to occupying the standby site. That is, in the event
of equipment failure, for instance, they will drop off a replacement rather than insist the client occupy
the standby site, with all the inconvenience that may involve. But it is essential that a site survey is
undertaken to ensure they can be parked on the required site. Most commercial standby sites offering
IT and work area recovery facilities do not guarantee a service: the contract merely provides access to
the equipment. Although most reputable vendors will negotiate a Service Level Agreement that
specifies the quality of the service, it is rarely offered.
It is important to ensure that a bank’s service will not suffer from unacceptable downtime or response. The
vendor may have skilled staff available – but this is rarely guaranteed and they come at a cost. In terms of
cost, there may be additional fees to pay for testing, on invocation of a disaster, and for occupation in a
disaster. The vendor charging structure also needs to be carefully considered.
Outsourcing Risks: In theory a commercial hot or warm standby site is available 24 / 365. It has staff
skilled in assisting recovery. Its equipment is constantly kept up to date, while older equipment
remains supported. It is always available for use and offers testing periods once or twice a year. The
practice may be different. These days, organizations have a wide range of equipment from different
vendors and different models from the same vendor. Not every commercial standby site is able to
support the entire range of equipment that a bank may have. Instead, vendors form alliances with
others – but this may mean that a bank’s recovery effort is split between more than one standby site.
The standby site may not have identical IT equipment: instead of the use of an identical piece of
equipment, it will offer a partition on a compatible large computer or server. Operating systems and
security packages may not be the same version as the client usually uses. These aspects may cause
setbacks when attempting recovery of IT systems and applications – and weak change control at the
recovery site could cause a disaster on return to the normal site.
It is the responsibility of the IT manager/bank to ensure effective recovery by those vendors, who apply the
highest standards, supporting this by a stringent contract, clearly defining service specifications and technical
requirements, and service-level agreements.
Introduction:
Information and the knowledge based on it have increasingly become recognized as ‘information assets’, which
are vital enablers of business operations. Hence, they require organizations to provide adequate levels of
protection. For banks, as purveyors of money in physical form or in bits and bytes, reliable information is even
more critical and hence information security is a vital area of concern.
Robust information is at the heart of risk management processes in a bank. Inadequate data quality is likely to
induce errors in decision making. Data quality requires building processes, procedures and disciplines for
managing information and ensuring its integrity, accuracy, completeness and timeliness. The fundamental
attributes supporting data quality should include accuracy, integrity, consistency, completeness, validity,
timeliness, accessibility, usability and auditability. The data quality provided by various applications depends on
the quality and integrity of the data upon which that information is built. Entities that treat information as a
critical organizational asset are in a better position to manage it proactively.
Information security not only deals with information in various channels like spoken, written, printed, electronic
or any other medium but also information handling in terms of creation, viewing, transportation, storage or
destruction .This is in contrast to IT security which is mainly concerned with security of information within the
boundaries of the network infrastructure technology domain. From an information security perspective, the
nature and type of compromise is not as material as the fact that security has been breached.
To achieve effective information security governance, bank management must establish and maintain a
framework to guide the development and maintenance of a comprehensive information security programme.
For over twenty years, information security has held confidentiality, integrity and availability (known as the
CIA triad) to be the core principles. There is continuous debate about extending this classic trio. Other
principles such as Authenticity, Non-repudiation and accountability are also now becoming key considerations
for practical security installations.
Integrity: In information security, integrity means that data cannot be modified without authorization.
This is not the same thing as referential integrity in databases.
Integrity is violated when an employee accidentally or with malicious intent deletes important data
files, when he/she is able to modify his own salary in a payroll database, when an employee uses
programmes and deducts small amounts of money from all customer accounts and adds it to his/her
own account (also called salami technique), when an unauthorized user vandalizes a web site, and so
on.
On a larger scale, if an automated process is not written and tested correctly, bulk updates to a database
could alter data in an incorrect way, leaving the integrity of the data compromised. Information
security professionals are tasked with finding ways to implement controls that prevent errors of
integrity.
Availability: For any information system to serve its purpose, the information must be available when
it is needed. This means that the computing systems used to store and process the information, the
security controls used to protect it, and the communication channels used to access it must be
functioning correctly. High availability systems aim to remain available at all times, preventing service
disruptions due to power outages, hardware failures, and system upgrades. Ensuring availability also
involves preventing denial-of-service (DoS) and distributed denial-of service (DDoS) attacks.
Authenticity: In computing, e-business and information security it is necessary to ensure that the data,
transactions, communications or documents (electronic or physical) are genuine. It is also important for
authenticity to validate that both parties involved are who they claim they are.
Non-repudiation: In law, non-repudiation implies one's intention to fulfill one’s obligations under a
contract / transaction. It also implies that a party to a transaction cannot deny having received or having
sent an electronic record. Electronic commerce uses technology such as digital signatures and
encryption to establish authenticity and non-repudiation.
In addition to the above, there are other security-related concepts and principles when designing a
security policy and deploying a security solution. They include identification, authorization,
accountability, and auditing.
Identification: Identification is the process by which a subject professes an identity and accountability
is initiated. A subject must provide an identity to a system to start the process of authentication,
authorization and accountability. Providing an identity can be typing in a username, swiping a smart
card, waving a proximity device, speaking a phrase, or positioning face, hand, or finger for a camera or
scanning device. Proving a process ID number also represents the identification process. Without an
identity, a system has no way to correlate an authentication factor with the subject.
Authorization: Once a subject is authenticated, access must be authorized. The process of authorization
ensures that the requested activity or access to an object is possible given the rights and privileges
assigned to the authenticated identity. In most cases, the system evaluates an access control matrix that
compares the subject, the object, and the intended activity. If the specific action is allowed, the subject
is authorized. Else, the subject is not authorized.
Accountability and auditability: An organization’s security policy can be properly enforced only if
accountability is maintained, i.e., security can be maintained only if subjects are held accountable for
their actions. Effective accountability relies upon the capability to prove a subject’s identity and track
their activities. Accountability is established by linking a human to the activities of an online identity
through the
security services and mechanisms of auditing, authorization, authentication, and identification. Thus,
human accountability is ultimately dependent on the strength of the authentication process. Without a
reasonably strong authentication process, there is doubt that the correct human associated with a
specific user account was the actual entity controlling that user account when an undesired action took
place.
Information security governance consists of the leadership, organizational structures and processes that protect
information and mitigation of growing information security threats like the ones detailed above.
Management and mitigation of risks and reduction of potential impacts on information resources to an
acceptable level
It is important to consider the organisational necessity and benefits of information security governance. They
include increased predictability and the reduction of uncertainty in business operations, a level of assurance that
critical decisions are not based on faulty information, enabling efficient and effective risk management,
protection from the increasing potential for legal liability, process improvement, reduced losses from
security-related events and prevention of catastrophic consequences and improved reputation in the market and
among customers.
The Board of Directors is ultimately responsible for information security. Senior Management is responsible for
understanding risks to the bank to ensure that they are adequately addressed from a governance perspective. To
do so effectively requires managing risks, including information security risks, by integrating information
security governance in the
overall enterprise governance framework of the organization. It is reported that the effectiveness of information
security governance is dependent on the involvement of the Board/senior management in approving policy and
appropriate monitoring of the information security function.
The major role of top management involves implementing the Board approved information security policy,
establishing necessary organizational processes for information security and providing necessary resources for
successful information security. It is essential that senior management establish an expectation for strong cyber
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
security and communicate this to their officials down the line. It is also essential that the senior organizational
leadership establish a structure for implementation of an information security programme to enable a consistent
and effective information security programme implementation apart from ensuring the accountability of
individuals for their performance as it relates to cyber security.
Given that today’s banking is largely dependent on IT systems and since most of the internal processing
requirements of banks are electronic, it is essential that adequate security systems are fully integrated into the IT
systems of banks. It would be optimal to classify these based on the risk analysis of the various systems in each
bank and specific risk mitigation strategies need to be in place.
Banks should form a separate information security function/group to focus exclusively on information security
management. There should be segregation of the duties of the Security Officer/Group dealing exclusively with
information systems security and the Information Technology Division which actually implements the computer
systems. The organization of the information security function should be commensurate with the nature and size
of activities of a bank including a variety of e-banking systems and delivery channels of a bank. The
information security function should be adequately resourced in terms of the number of staff, level of skills and
tools or techniques like risk assessment, security architecture, vulnerability assessment, forensic assessment, etc.
While the information security group/function itself and information security governance related structures
should not be outsourced, specific operational components relating to information security can be outsourced, if
required resources are not available within a bank. However, the ultimate control and responsibility rests with
the bank.
Since information security affects all aspects of an organization, in order to consider information security from a
bank -wide perspective a steering committee of executives should be formed with formal terms of reference.
The Chief Information Security Officer would be the member secretary of the Committee. The committee may
include, among others, the Chief Executive Officer (CEO) or designee, chief financial officer (CFO), business
unit executives, Chief Information Officer (CIO)/ IT Head, Heads of human resources, legal, risk management,
audit, operations and public relations.
A steering committee serves as an effective communication channel for management’s aims and directions and
provides an ongoing basis for ensuring alignment of the security programme with organizational objectives. It is
also instrumental in achieving behavior change toward a culture that promotes good security practices and
compliance with policies.
Developing and facilitating the implementation of information security policies, standards and
procedures to ensure that all identified risks are managed within a bank’s risk appetite
Approving and monitoring major information security projects and the status of information security
plans and budgets, establishing priorities, approving standards and procedures
A sufficiently senior level official, of the rank of GM/DGM/AGM, should be designated as Chief Information
Security Officer, responsible for articulating and enforcing the policies that banks use to protect their
information assets apart from coordinating the security related issues / implementation within the organization
as well as relevant external agencies. The CISO needs to report directly to the Head of Risk Management and
should not have a direct reporting relationship with the CIO. However, the CISO may have a working
relationship with the CIO to develop the required rapport to understand the IT infrastructure and operations, to
build effective security in IT across the bank, in tune with business requirements and objectives.
Banks need to frame Board approved Information Security Policy and identify and implement
appropriate information security management measures/practices keeping in view their business needs.
The policies need to be supported with relevant standards, guidelines and procedures. A policy
framework would, inter-alia, incorporate/take into consideration the following:
An information security strategy that is aligned with business objectives and the legal
requirements
Objectives, scope, ownership and responsibility for the policy
Information security organisational structure
Information security roles and responsibilities that may include information
security-specific roles like IT security manager/officer, administrators, information security
specialists and information asset-specific roles like owners, custodians, end-users
-- Periodic reviews of the policy – at least annually and in the event of significant changes
necessitating revision
-- A periodic compliance review of the policy – about the adherence of users to information
security policies and put up to the information security committee.
-- Exceptions: An exception policy for handling instances of non-compliance with the
information security policy including critical aspects like exception criteria including whether
there is genuine need for exceptions, management of the exception log or register, authority to
grant exemptions, expiry of exceptions and the periodicity of review of exceptions granted.
Where exemptions are granted, banks need to review and assess the adequacy of
compensating controls initially and on an ongoing basis. A sign -off needs to be obtained from
the CISO on the exceptions
Penal measures for violation of policies and the process to be followed in the event of
violation
Identification, authorisation and granting of access to IT assets (by individuals and other IT
assets)
Addressing the various stages of an IT asset’s life to ensure that information security
requirements are considered at each stage of the lifecycle
An incident monitoring and management process to address the identification and
classification of incidents, reporting, escalation, preservation of evidence, the investigation
process
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
Clearly indicating acceptable usage of IT assets including application systems that define the
information security responsibilities of users (staff, service providers and customers) in regard
to the use of IT assets
Requirements relating to recruitment and selection of qualified staff and external contractors
that define the framework for vetting and monitoring of personnel, taking into account the
information security risk
Strategy for periodic training and enhancing skills of information security personnel,
requirement of continuous professional education
Specific policies that would be required include, but not limited to, the following:
Logical Access Control
Asset Management
Network Access Control
Password management
E-mail security
Remote access
Mobile computing
Network security
Application security
Backup and archival
Operating system security
Database administration and security
Physical security
Capacity Management
Incident response and management
Malicious software
IT asset/media management
Change Management
Patch Management
Internet security
Desktop
Encryption
Security of electronic delivery channels
Wireless security
Application/data migration
Accountability for security is increased through clear job descriptions, employment agreements and
policy awareness acknowledgements. It is important to communicate the general and specific security
roles and responsibilities for all employees within their job descriptions. The job descriptions for
security personnel should also clearly describe the systems and processes they will protect and their
responsibility towards control processes. Management should expect all employees, officers and
contractors/consultants to comply with security and acceptable-use policies and protect the institution’s
assets, including information.
Given the critical role of security technologies as part of the information security framework, banks
need to subject them to suitable controls across their lifecycle like guidelines on their usage, standards
and procedures indicating the detailed objectives and requirements of individual information
security-specific technology solutions, authorisation for individuals who would be handling the
technology, addressing segregation of duties issues, appropriate configurations of the devices that
provide the best possible security, regularly assessing their effectiveness and fine-tuning them
accordingly, and identification of any unauthorised changes.
Digital evidence is similar to any other form of legal proof - it needs to withstand challenges to its
integrity, its handling must be carefully tracked and documented, and it must be suitably authenticated
by concerned personnel as per legal requirements. Since the evidence resides on or is generated by a
digital device, a trained information security official or skilled digital forensics examiner may need to
be involved in the handling process to ensure that any material facts is properly preserved and
introduced. A suitable policy needs to be in place in this regard.
Risk Assessment
The likelihood that a threat will use a vulnerability to cause harm creates a risk. When a threat does use a
vulnerability to inflict harm, it has an impact. In the context of information security, the impact is a loss of
availability, integrity and confidentiality, and possibly other losses (lost income, loss of life, loss of
property).
Risk assessment is the core competence of information security management. The risk assessment must, for
each asset within its scope, identify the threat/vulnerability combinations that have a likelihood of
impacting the confidentiality, availability or integrity of that asset - from a business, compliance or
contractual perspective. Standards like ISO27001 and ISO 27002 are explicit in requiring a risk
assessment to be carried out before any controls are selected and implemented and are equally explicit that
the selection of every control must be justified by a risk assessment.
In broad terms, the risk management process consists of:
Identification of assets and estimation of their value. Some aspects to be included are people, buildings,
hardware, software, data (electronic, print) and supplies
Conducting a threat assessment which may include aspects like acts of nature, acts of war, accidents,
malicious acts originating from inside or outside the organization
Conducting a vulnerability assessment for each vulnerability and calculating the probability that it will be
exploited. Evaluating policies, procedures, standards, training, physical security, quality control and
technical security in this regard
Calculating the impact that each threat would have on each asset through qualitative or quantitative
analysis
Identifying, selecting and implementing appropriate controls. Providing proportional response including
considerations like productivity, cost effectiveness, and the value of the asset
Evaluating the effectiveness of the control measures. Ensuring the controls provide the required
cost-effective protection.
The process of risk management is an ongoing iterative process. The business environment is constantly
changing and new threats and vulnerabilities emerge every day. The choice of countermeasures or
controls used to manage risks must strike a balance between productivity, cost-effectiveness of the
countermeasure and the value
of the informational asset being protected. The risk assessment should be carried out by a team of people
who have knowledge of specific areas of the business. The assessment may use a subjective qualitative
analysis based on informed opinion, or where reliable figures and historical information is available,
quantitative analysis.
Quantitative methods involve assigning numerical measurements that can be entered into the analysis to
determine total and residual risks. The various aspects that are considered a part of measurements include
costs to safeguard the information and information systems, value of that information and those systems,
threat frequency and probability, and the effectiveness of controls. A shortcoming of quantitative methods
is a lack of reliable and predictive data on threat frequency and probability. This shortcoming is generally
addressed by assigning numeric values based on qualitative judgments.
Qualitative analysis involves the use of scenarios and attempts to determine the seriousness of threats and
the effectiveness of controls. Qualitative analysis is by definition subjective, relying upon judgment,
knowledge, prior experience and industry information. Qualitative techniques may include walk-throughs,
surveys/questionnaires, interviews and specific workgroups to obtain information about the various
scenarios.
Effective control requires a detailed inventory of information assets. Such a list is the first step in classifying the
assets and determining the level of protection to be provided to each asset.
The inventory record of each information asset should, at the least, include:
Information assets have varying degrees of sensitivity and criticality in meeting business objectives. By
assigning classes or levels of sensitivity and criticality to information resources and establishing specific
security rules/requirements for each class, it is possible to define the level of access controls that should be
applied to each information asset. Classification of information reduces the risk and cost of over- or under -
protecting information resources in aligning security with business objectives since it helps to build and
maintain a consistent and uniform perspective of the security requirements for information assets throughout the
organization. ISO 27001 standards require the inventorying of information assets and the classification,
handling and labelling of information in accordance with preset guidelines.
All defined and documented responsibilities and accountabilities must be established and communicated to all
relevant personnel and management. Some of the major ones include:
Information owner
This is a business executive or business manager who is responsible for a bank’s business information asset.
Responsibilities would include, but not be limited to:
Reviewing and ensuring currency of the access rights associated with information assets they own
Determining security requirements, access criteria and backup requirements for the information
assets they own
Information custodian
The information custodian, usually an information systems official, is the delegate of the information owner
with primary responsibilities for dealing with backup and recovery of the business information.
Responsibilities include, but are not limited to, the following:
Performing backups according to the backup requirements established by the information owner
When necessary, restoring lost or corrupted information from backup media to return the
application to production status
Ensuring record retention requirements are met based on the information owner’s requirements
Application owner
The application owner is the manager of the business line who is fully accountable for the performance of the
business function served by the application. Responsibilities, inter-alia, include:
Establishing user access criteria, availability requirements and audit trails for their applications
Ensuring security controls associated with the application are commensurate with support for the
highest level of information classification used by the application
User manager
The user manager is the immediate manager or supervisor of an employee or HR official of the business
function in which an employee works. He has the ultimate responsibility for all user IDs and information assets
owned by bank employees. In the case of non employee individuals such as contractors, consultants, etc., this
manager is responsible for the activity and for the bank assets used by these individuals. He/she is usually the
manager responsible for hiring the outside contractor. Responsibilities include the following:
-ۯ-Ɩ--- Informing security administration of the termination of any employee so that the user ID
owned by that individual can be revoked, suspended or made inaccessible in a timely manner
-ۯ-Ɩ--- Informing security administration of the transfer of any employee if the transfer involves
the change of access rights or privileges
-ۯ-Ɩ--- Reporting any security incident or suspected incident to the Information Security function
-ۯ-Ɩ--- Ensuring that employees are aware of relevant security policies, procedures and standards
to which they are accountable
Security Administrator
Security administrators have the powers to set system-wide security controls or administer user IDs and
information resource access rights. These security administrators usually report to the Information Security
function. Responsibilities include the following:
Understanding different data environments and the impact of granting access to them
Ensuring access requests are consistent with the information directions and security guidelines
Administering access rights according to criteria established by the Information Owners
Administering the system within the scope of their job description and functional responsibilities
End user
The end users would be any employees, contractors or vendors of the bank who use information systems
resources as part of their job. Responsibilities include :
Using bank business assets and information resources for management approved purposes only
Access Control
An effective process for access to information assets is one of the critical requirements of information
security. Internal sabotage, clandestine espionage or furtive attacks by trusted employees, contractors
and vendors are among the most serious potential risks that a bank faces. Current and past employees,
contractors, vendors and those who have an intimate knowledge of the inner workings of the bank’s
systems, operations and internal controls have a significant advantage over external attackers. A
successful attack could jeopardise customer confidence in a bank’s internal control systems and
processes.
Hence, access to information assets needs to be authorised by a bank only where a valid business need
exists and only for the specific time period that the access is required. The various factors that need to
be considered when authorising access to users and information assets, inter-alia, include business role,
physical location, method of connectivity, remote access, time, anti-malware and patch updation status,
nature of device used and software /operating system.
The provision of access involves various stages like identification and authentication which involves
determination of the person or IT asset requesting access and confirmation of the purported identity and
authorisation. This involves an assessment of whether access is allowed to an information asset by the
request or based on the needs of the business and the level of information security required. These
processes are applicable to both users as well as IT assets.
A bank should take appropriate measures to identify and authenticate users or IT assets. The required
strength of authentication needs to be commensurate with risk. Common techniques for increasing the
strength of identification and authentication include the use of strong password techniques (i.e.
increased length, complexity, re-use limitations and frequency of change) and increasing the number
and/or type of authentication factors used.
The examples where increased authentication strength may be required, given the risks involved
include : administration or other privileged access to sensitive or critical IT assets, remote access
through public networks to sensitive assets and activities carrying higher risk like third-party fund
transfers, etc. The period for which authentication is valid would need to be commensurate with the
risk.
Among the important controls that banks need to consider are:
A systematic process of applying and authorizing the creation of user ids and the access
control matrix
Conducting a risk assessment and granting access rights based on the same. For example,
contractors and temporary staff would have higher inherent risks
For accountability purposes, a bank should ensure that users and IT assets are uniquely identified and
their actions are auditable.
Transaction processes and systems should be designed to ensure that no single employee/outsourced
service provider could enter, authorize and complete a transaction.
Segregation should be maintained between those initiating static data (including web page content) and
those responsible for verifying its integrity. Further, segregation should be maintained between those
developing and those administering e-banking systems.
E-banking systems should be tested to ensure that segregation of duties cannot be bypassed.
Mutual authentication system may be considered. Mutual Authentication, also called two-way
authentication, is a security feature in which a client process must prove his identity to a server, and the
server must prove its identity to the client, before any application traffic is sent over the client-to-server
connection. Identity can be proved through a trusted third party and use of shared secrets or through
cryptographic means as with a public key infrastructure. For e.g., with the mutual authentication
implemented, a connection can occur only when the client trusts the server's digital certificate and the
server trusts the client's certificate. The exchange of certificates will happen through special protocols
like the Transport Layer Security (TLS) protocol. This process reduces the risk that an unsuspecting
network user will inadvertently reveal security information to a malicious or insecure web site.
System administrators, security officers, programmers and staff performing critical operations
invariably possess the capability to inflict severe damage on the banking systems they maintain or
operate by virtue of their job functions and privileged access. Personnel with elevated system access
entitlements should be closely supervised with all their systems activities logged, as they have inside
knowledge and the resources to circumvent systems controls and security procedures. Some of the
control and security practices enumerated below needs to be considered:
Information security needs to be considered at all stages of an information asset’s life-cycle like planning,
design, acquisition and implementation, maintenance and disposal. Banks need to apply systematic
project management oriented techniques to manage material changes during these stages and to ensure
that information security requirements have been adequately addressed.
Planning and design level controls need to be in place to ensure that information security is embodied in the
overall information systems architecture and the implemented solutions are in compliance with the
information security policies and requirements of a bank.
Ongoing support and maintenance controls would be needed to ensure that IT assets continue to meet
business objectives. Major controls in this regard include change management controls to ensure that
the business objectives continue to be met following change; configuration management controls to
ensure that the configuration minimises vulnerabilities and is defined, assessed, maintained and
managed; deployment and environment controls to ensure that development, test and production
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
environments are appropriately segregated; and patch management controls to manage the assessment
and application of patches to software that addresses known vulnerabilities in a timely manner
The other relevant controls include service level management, vendor management, capacity management
and configuration management which are described in later chapters. Decommissioning and destruction
controls need to be used to ensure that information security is not compromised as IT assets reach the
end of their useful life. (for example, through archiving strategies and deletion of sensitive information
prior to the disposal of IT assets.)
Personnel security
Application owners grant legitimate users access to systems that are necessary to perform their duties and
security personnel enforce the access rights in accordance with institution standards. Because of their
internal access levels and intimate knowledge of financial institution processes, authorized users pose a
potential threat to systems and data. Employees, contractors, or third-party employees can also exploit
their legitimate computer access for malicious or fraudulent reasons. Further, the degree of internal
access granted to some users can increase the risk of accidental damage or loss of information and
systems.
Risk exposures from internal users include altering data, deleting production and back-up data,
disrupting/destroying systems, misusing systems for personal gain or to damage the institution, holding
data hostage and stealing strategic or customer data for espionage or fraud schemes.
Banks should have a process to verify job application information on all new employees. Additional
background and credit checks may be warranted based on the sensitivity of a particular job or access
level. Personnel with privileged access like administrators, cyber security personnel, etc. should be
subjected to rigorous
background checks and screening. Institutions should verify that contractors are subject to similar
screening procedures. The verification considerations would include:
Physical security
The confidentiality, integrity, and availability of information can be impaired through physical access
and damage or destruction to physical components. Conceptually, those physical security risks are
mitigated through zone-oriented implementations. Zones are physical areas with differing physical
security requirements. The security requirements of each zone are a function of the sensitivity of the
data contained or accessible through the zone and the information technology components in the zone.
The requirements for each zone should be determined through the risk assessment. The risk assessment
should include, but is not limited to, threats like aircraft crashes, chemical effects, dust, electrical
supply interference, electromagnetic radiation, explosives, fire, smoke, theft/destruction,
vibration/earthquake, water, criminals, terrorism, political issues (e.g. strikes, disruptions) and other
threats based on the entity’s unique geographical location, building configuration, neighboring
environment/entities, etc.
A bank needs to deploy the following environmental controls:
Secure location of critical assets providing protection from natural and man-made threats
Restrict access to sensitive areas like data centres, which also includes detailed procedures for
handling access by staff, third party providers and visitors
Suitable preventive mechanisms for various threats indicated above
Monitoring mechanisms for the detection of compromises of environmental controls relating to
temperature, water, smoke, access alarms, service availability alerts (power supply, telecommunication,
servers), access log reviews etc
It is acknowledged that the human link is the weakest link in the information security chain. Hence, there is a
vital need for an initial and ongoing training and information security awareness programme. The programme
may be periodically updated keeping in view changes in information security, threats/vulnerabilities and/or the
bank’s information security framework. There needs to be a mechanism to track the effectiveness of training
programmes through an assessment/testing process designed on testing the understanding of the relevant
information security policies, not only initially but also on a periodic basis. At any point of time, a bank needs to
maintain an updated status on user training and awareness relating to information security and the matter needs
to be an important agenda item during Information Security Committee meetings.
Some of the areas that could be incorporated as part of the user awareness programme include:
Incident management
Incident management is defined as the process of developing and maintaining the capability to manage
incidents within a bank so that exposure is contained and recovery achieved within a specified time
objective. Incidents can include the misuse of computing assets, information disclosure or events that
threaten the continuance of business processes.
Major activities that need to be considered as part of the incident management framework include:
Developing and implementing processes for preventing, detecting, analyzing and responding
to information security incidents
Establishing escalation and communication processes and lines of authority
Developing plans to respond to and document information security incidents
Establishing the capability to investigate information security incidents through various
modes like forensics, evidence collection and preservation, log analysis, interviewing, etc.
Developing a process to communicate with internal parties and external organizations (e.g.,
regulator, media, law enforcement, customers)
Integrating information security incident response plans with the organization’s disaster
recovery and business continuity plan
Organizing, training and equipping teams to respond to information security incidents
Common incident types include, but not limited to, outages/degradation of services due to hardware,
software or capacity issues, unauthorised access to systems, identity theft, data leakage/loss, malicious
software and hardware, failed backup processes, denial of service attacks and data integrity issues.
A bank needs to have clear accountability and communication strategies to limit the impact of
information security incidents through defined mechanisms for escalation and reporting to the Board
and senior management and customer communication, where appropriate. Incident management
strategies would also typically assist in compliance with regulatory requirements. Institutions would
also need to pro-actively notify CERT-In/IDRBT/RBI regarding cyber security incidents.
All security incidents or violations of security policies should be brought to the notice of the CISO.
Financial institutions have different types of applications like the core banking system, delivery channels
like ATMs, internet banking, mobile banking, phone banking, network operating systems, databases,
enterprise resource management (ERP) systems, customer relationship management (CRM) systems, etc.,
all used for different business purposes. Then these institutions have partners, contractors, consultants,
employees and temporary employees. Users usually access several different types of systems throughout
their daily tasks, which makes controlling access and providing the necessary level of protection on
different data types difficult and full of obstacles. This complexity may result in unforeseen and
unidentified holes in the protection of the entire infrastructure including overlapping and contradictory
controls, and policy and regulatory noncompliance.
There are well-known information systems security issues associated with applications software,
whether the software is developed internally or acquired from an external source .Attackers can potentially
use many different paths through the application to do harm to the business. Each of these paths represents
a risk that may or may not be serious enough to warrant attention. Sometimes, these paths are easy to find
and exploit and sometimes they are extremely difficult. Similarly, the harm that is caused may range from
minor to major. To determine the risk to itself, a bank can evaluate the likelihood associated with the threat
agent, attack vector, and security weakness and combine it with an estimate of the technical and business
impact to the organization. Together, these factors determine the overall risk.
The following are the important Application control and risk mitigation measures that need to be
implemented by banks:
Each application should have an owner which will typically be the concerned business
function that uses the application
Some of the roles of application owners include:
Prioritizing any changes to be made to the application and authorizing the changes
Ensuring that the application meets the business/functional needs of the users
Ensuring that the information security function has reviewed the security of the
application
Ensuring that the new applications being purchased/developed follow the Information
Security policy
Ensuring that logs or audit trails, as required, are enabled and monitored for the
applications
All application systems need to be tested before implementation in a robust manner regarding
controls to ensure that they satisfy business policies/rules of the bank and regulatory and legal
prescriptions/requirements. Robust controls need to be built into the system and reliance on
any manual controls needs to be minimized. Before the system is live, there should be clarity
on the audit trails and the specific fields that are required to be captured as part of audit trails
and an audit trail or log monitoring process including personnel responsible for the same.
A bank needs to incorporate information security at all stages of software development. This
would assist in improving software quality and minimizing exposure to vulnerabilities.
Besides business functionalities, security requirements relating to system access control,
authentication, transaction authorization, data integrity, system activity logging, audit trail,
security event tracking and exception handling are required to be clearly specified at the initial
stages of system development/acquisition. A compliance check against the bank’s security
standards and regulatory/statutory requirements would also be required.
All application systems need to have audit trails along with policy/procedure of log
monitoring for such systems including the clear allocation of responsibility in this regard.
Every application affecting critical/sensitive information, for example, impacting financial,
customer, control, regulatory and legal aspects, must provide for detailed audit trails/ logging
capability with details like transaction id, date, time, originator id, authorizer id, actions
undertaken by a given user id, etc. Other details like logging the IP address of the client
machine, terminal identity or location may also be considered.
Applications must also provide for, inter-alia, logging unsuccessful logon attempts, access to
sensitive options in the application, e.g., master record changes, granting of access rights, use
of system utilities, changes in system configuration, etc.
The audit trails need to be stored as per a defined period as per any
internal/regulatory/statutory requirements and it should be ensured that they are not tampered
with.
Access should be based on the principle of least privilege and “need to know” commensurate
with the job responsibilities. Adequate segregation of duties needs to be enforced.
There should be controls on updating key ‘static’ business information like customer master
files, parameter changes, etc.
Any changes to an application system/data need to be justified by genuine business need and
approvals supported by documentation and subjected to a robust change management process.
The change management would involve generating a request, risk assessment, authorization
from an appropriate authority, implementation, testing and verification of the change done.
Potential security weaknesses / breaches (for example, as a result of analyzing user behaviour
or patterns of network traffic) should be identified.
There should be measures to reduce the risk of theft, fraud, error and unauthorized changes to
information through measures like supervision of activities and segregation of duties.
Applications must not allow unauthorized entries to be updated in the database. Similarly,
applications must not allow any modifications to be made after an entry is authorized. Any
subsequent changes must be made only by reversing the original authorized entry and passing
a fresh entry.
Direct back-end updates to database should not be allowed except during exigencies, with a
clear business need and after due authorization as per the relevant policy.
Access to the database prompt must be restricted only to the database administrator.
Robust input validation controls, processing and output controls needs to be built in to the
application.
There should be a procedure in place to reduce the reliance on a few key individuals.
Alerts regarding use of the same machine for both maker and checker transactions need to be
considered.
There should be a proper linkage between a change request and the corresponding action
taken. For example, the specific accounting head or code which was created as a result of a
specific request should be established clearly.
Error / exception reports and logs need to be reviewed and any issues need to be remedied
/addressed at the earliest.
Critical functions or applications dealing with financial, regulatory and legal, MIS and risk
assessment/management, (for example, calculation of capital adequacy, ALM, calculating
VaR, risk weighted assets, NPA classification and provisioning, balance sheet compilation,
AML system, revaluation of foreign currency balances, computation of MTM gains / losses,
etc.,) needs to be done through proper application systems and not manually or in a
semi-automated manner through spreadsheets. These pose risks relating to data integrity and
reliability. Use of spreadsheets in this regard should be restricted and should be replaced by
appropriate IT applications within a definite time-frame in a phased manner.
Banks may obtain application integrity statements in writing from the application system
vendors providing for reasonable level of assurance about the application being free of
malware at the time of sale, free of any obvious bugs, and free of any covert channels in the
code (of the version of the application being delivered as well as any subsequent
versions/modifications done).
For all critical applications, either the source code must be received from the vendor or a
software escrow agreement should be in place with a third party to ensure source code
availability in the event the vendor goes out of business. It needs to be ensured that product
updates and programme fixes are also included in the escrow agreement.
Applications should be configured to logout the users after a specific period of inactivity. The
application must ensure rollover of incomplete transactions and otherwise ensure integrity of
data in case of a log out.
There should be suitable interface controls in place. Data transfer from one process to another
or from one application to another, particularly for critical systems, should not have any
manual intervention in order to prevent any unauthorized modification. The process needs to
be automated and properly integrated with due authentication mechanism and audit trails by
enabling “Straight Through Processing” between applications or from data sources to replace
any manual intervention/semi-automated processes like extracting data in text files and
uploading to the target system, importing to a spreadsheet, etc. Further, proper validations and
reconciliation of data needs to be carried out between relevant interfaces/applications across
the bank. The bank needs to suitably integrate the systems and applications, as required, to
enhance data integrity and reliability.
Multi-tier application architecture needs to be considered for relevant critical systems like
internet banking systems which differentiate session control,
presentation logic, server side input validation, business logic and database access.
In the event of data pertaining to Indian operations being stored and/or processed abroad, for
example, by foreign banks, there needs to be suitable controls like segregation of data and
strict access controls based on ‘need to know’ and robust change controls. The bank should be
in a position to adequately prove the same to the regulator. Regulator’s access to such
data/records and other relevant information should not be impeded in any manner and RBI
would have the right to cause an inspection to be made of the processing centre/data centre
and its books and accounts by one or more of its officers or employees or other persons.
Critical application system logs/audit trails also need to be backed up as part of the application
backup policy.
Robust System Security Testing, in respect of critical e-banking systems, needs to incorporate,
inter-alia, specifications relating to information leakage, business logic, authentication,
authorization, input data validation, exception/error handling, session management,
cryptography and detailed logging, as relevant. These need to be carried out atleast on annual
basis.
Migration controls:
There needs to be a documented Migration Policy indicating the requirement of road-map / migration
plan / methodology for data migration (which includes verification of completeness, consistency and
integrity of the migration activity and pre and post migration activities along with responsibilities and
timelines for completion of same). Explicit sign offs from users/application owners need to be obtained
after each stage of migration and after complete migration process. Audit trails need to be available to
document the conversion, including data mappings and transformations.
The key aspects that are required to be considered include:
a. Integrity of data— indicating that the data is not altered manually or electronically by a person,
programme, substitution or overwriting in the new system. Integrity thus, includes error creep
due to factors like transposition, transcription, etc.
Completeness— ensuring that the total number of records from the source database is transferred
to the new database (assuming the number of fields is the same)
Confidentiality of data under conversion—ensuring that data is backed up before migration for
future reference or any emergency that might arise out of the data migration process
Consistency of data— the field/record called for from the new application should be consistent
with that of the original application. This should enable consistency in repeatability of the
testing exercise
Continuity—the new application should be able to continue with newer records as addition (or
appendage) and help in ensuring seamless business continuity
It is a good practice that the last copy of the data before conversion from the old platform and the first
copy of the data after conversion to the new platform are maintained separately in the archive for any
future reference.
The error logs pertaining to the pre-migration/ migration/ post migration period along with root cause
analysis and action taken need to be available for review.
Banks may need to migrate the complete transaction data and audit trails from the old system to the
new system. Else, banks should have the capability to access the older transactional data and piece
together the transaction trail between older and newer systems, to satisfy any supervisory/legal
requirements that may arise.
Banks need to carry out due diligence with regard to new technologies since they can potentially
introduce additional risk exposures. A bank needs to authorise the large scale use and deployment in
production environment of technologies that have matured to a state where there is a generally agreed
set of industry-accepted controls and robust diligence and testing has been carried out to ascertain the
security issues of the technology or where compensating controls are sufficient to prevent significant
impact and to comply with the institution’s risk appetite and regulatory expectations.
Any new business products introduced along with the underlying information systems need to be
assessed as part of a formal product approval process which incorporates, inter-alia, security related
aspects and fulfilment of relevant legal and regulatory prescriptions. A bank needs to develop an
authorisation process involving a risk assessment balancing the benefits of the new technology with the
risk.
Encryption
Encryption Types:
Symmetric encryption is the use of the same key and algorithm by the creator and reader of a file or message.
The creator uses the key and algorithm to encrypt, and the reader uses both to decrypt. Symmetric encryption
relies on the secrecy of the key. If the key is captured by an attacker, either when it is exchanged between the
communicating parties, or while one of the parties uses or stores the key, the attacker can use the key and the
algorithm to decrypt messages or to masquerade as a message creator.
Asymmetric encryption lessens the risk of key exposure by using two mathematically related keys, the private
key and the public key. When one key is used to encrypt, only the other key can decrypt. Therefore, only one
key (the private key) must be kept secret. The key that is exchanged (the public key) poses no risk if it becomes
known. For instance, if individual A has a private key and publishes the public key, individual B can obtain the
public key, encrypt a message to individual A, and send it. As long as an individual keeps his private key secure
from disclosure, only individual A will be able to decrypt the message.
Typical areas or situations requiring deployment of cryptographic techniques, given the risks involved,
include transmission and storage of critical and/or sensitive data/information in an ‘un-trusted’
environment or where a higher degree of security is required, generation of customer PINs which are
typically used for card transactions and online services, detection of any unauthorised alteration of
data/information and verification of the authenticity of transactions or data/information.
Since security is primarily based on the encryption keys, effective key management is crucial. Effective
key management systems are based on an agreed set of standards, procedures, and secure methods that
address
Dealing with compromised keys, revoking keys and specifying how keys should be withdrawn or
deactivated
Recovering keys that are lost or corrupted as part of business continuity management
Archiving, destroying keys
Logging the auditing of key management-related activities
Instituting defined activation and deactivation dates, limiting the usage period of keys
Additional physical protection of equipment used to generate, store and archive cryptographic
keys
Use of cryptographic techniques to maintain cryptographic key confidentiality
Segregation of duties, with no single individual having knowledge of the entire cryptographic key
(i.e. two-person controls) or having access to all the components making up these keys
Ensuring key management is fully automated (e.g., personnel do not have the opportunity to
expose a key or influence the key creation)
Ensuring no key ever appears unencrypted
Ensuring keys are randomly chosen from the entire key space, preferably by hardware
Ensuring key-encrypting keys are separate from data keys. No data ever appears in clear text that
was encrypted using a key-encrypting key. (A key encrypting key is used to encrypt other keys,
securing them from disclosure.)
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
Make sure that keys with a long life are sparsely used. The more a key is used, the greater the
opportunity for an attacker to discover the key
Normally, a minimum of 128-bit SSL encryption is expected. Constant advances in computer hardware,
cryptanalysis and distributed brute force techniques may induce use of larger key lengths periodically.
It is expected that banks will properly evaluate security requirements associated with their internet
banking systems and other relevant systems and adopt an encryption solution that is commensurate
with the degree of confidentiality and integrity required. Banks should only select encryption
algorithms which are well established international standards and which have been subjected to
rigorous scrutiny by an international cryptographer community or approved by authoritative
professional bodies, reputable security vendors or government agencies.
Data security
Banks need to define and implement procedures to ensure the integrity and consistency of all data stored
in electronic form, such as databases, data warehouses and data archives.
A data security theory seeks to establish uniform risk-based requirements for the protection of data
elements. To ensure that the protection is uniform within and outside of the institution, tools such as data
classifications and protection profiles can be used, as indicated earlier in the chapter.
Data classification and protection profiles are complex to implement when the network or storage is
viewed as a utility. Because of that complexity, some institutions treat all information at that level as if it
were of the highest sensitivity and implement encryption as a protective measure. The complexity in
implementing data classification in other layers or in other aspects of an institution’s operation may result
in other risk mitigation procedures being used. Adequacy is a function of the extent of risk mitigation, and
not the procedure or tool used to mitigate risk.
Policies regarding media handling, disposal, and transit should be implemented to enable the use of
protection profiles and otherwise mitigate risks to data. If protection profiles are not used, the policies
should accomplish the same goal as protection profiles, which is to deliver the same degree of residual
risk without regard to whether the information is in transit or storage, who is directly controlling the data,
or where the storage may be.
There should be secure storage of media. Controls could include physical and environmental controls such
as fire and flood protection, limiting access by means like physical locks, keypad, passwords, biometrics,
etc., labelling, and logged access. Management should establish access controls to limit access to media,
while ensuring that all employees have authorization to access the minimum data required to perform their
responsibilities. More sensitive information such as system documentation, application source code, and
production transaction data should have more extensive controls to guard against alteration (e.g., integrity
checkers, cryptographic hashes). Furthermore, policies should minimize the distribution of sensitive
information, including printouts that contain the information. Periodically, the security staff, audit staff,
and data owners should review authorization levels and distribution lists to ensure they remain appropriate
and current.
The storage of data in portable devices, such as laptops and PDAs, poses unique problems. Mitigation of
those risks typically involves encryption of sensitive data, host-provided access controls, etc.
Banks need appropriate disposal procedures for both electronic and paper based media. Contracts with
third-party disposal firms should address acceptable disposal procedures. For computer media, data
frequently remains on media after erasure. Since that data can be recovered, additional disposal techniques
should be applied to sensitive data like physical destruction, overwriting data, degaussing etc.
Banks should maintain the security of media while in transit or when shared with third parties. Policies
should include contractual requirements that incorporate necessary risk-based controls, restrictions on the
carriers used and procedures to verify the identity of couriers.
Banks should encrypt customer account and transaction data which is transmitted, transported, delivered
or couriered to external parties or other locations, taking into account all intermediate junctures and transit
points from source to destination.
A few other aspects that also needs to be considered include appropriate blocking, filtering and
monitoring of electronic mechanisms like e-mail and printing and monitoring for unauthorised software
and hardware like password cracking software, key loggers, wireless access points, etc.
Concerns over the need to better control and protect sensitive information have given rise to a new set of
solutions aimed at increasing an enterprise’s ability to protect its information assets. These solutions vary
in their capabilities and methodologies, but collectively they have been placed in a category known as data
leak prevention (DLP). It provides a comprehensive approach covering people, processes, and systems
that identify, monitor, and protect data in use (e.g., endpoint actions), data in motion (e.g., network
actions), and data at rest (e.g., data storage) through deep content inspection and with a centralized
management framework.
Most DLP solutions include a suite of technologies that facilitate three key objectives:
Monitor and control the movement of sensitive information across enterprise networks
Monitor and control the movement of sensitive information on end-user systems Banks may
consider such solutions, if required, after assessing their potential to improve data security.
Vulnerability Assessment
Soon after new vulnerabilities are discovered and reported by security researchers or vendors, attackers
engineer the malicious exploit code and then launch that code against targets of interest. Any significant
delays in finding or fixing software with critical vulnerabilities provides ample opportunity for persistent
attackers to break through, gaining control over the vulnerable machines and getting access to the
sensitive data they contain. Banks that do not scan for vulnerabilities and address discovered flaws
proactively face a significant likelihood of having their computer systems compromised.
The following are some of the measures suggested:
Automated vulnerability scanning tools need to be used against all systems on their networks
on a periodic basis, say monthly or weekly or more frequently.
Banks should ensure that vulnerability scanning is performed in an authenticated mode (i.e.,
configuring the scanner with administrator credentials) at least quarterly, either with agents
running locally on each end system to analyze the security configuration or with remote
scanners that are given administrative rights on the system being tested, to overcome
limitations of unauthenticated vulnerability scanning.
Banks should compare the results from back-to-back vulnerability scans to verify that
vulnerabilities were addressed either by patching, implementing a compensating control, or by
documenting and accepting a reasonable business risk. Such acceptance of business risks for
existing vulnerabilities should be periodically reviewed to determine if newer compensating
controls or subsequent patches can address vulnerabilities that were previously accepted, or if
conditions have changed increasing the risk.
Vulnerability scanning tools should be tuned to compare services that are listening on each
machine against a list of authorized services. The tools should be further tuned to identify
changes over time on systems for both authorized and unauthorized services.
The security function should have updated status regarding numbers of unmitigated, critical
vulnerabilities, for each department/division, plan for mitigation and should share
vulnerability reports indicating critical issues with senior management to provide effective
incentives for mitigation.
A bank needs to have robust monitoring processes in place to identify events and unusual activity patterns
that could impact on the security of IT assets. The strength of the monitoring controls needs to be
proportionate to the criticality of an IT asset. Alerts would need to be investigated in a timely manner,
with an appropriate response determined.
Common monitoring processes include activity logging (including exceptions to approved activity), for
example, device, server, network activity, security sensor alerts; monitoring staff or third-party access to
sensitive data/information to ensure it is for a valid business reason, scanning host systems for known
vulnerabilities, checks to determine if information security controls are operating as expected and are
being
complied with, checking whether powerful utilities / commands have been disabled on attached hosts by
using tools like ‘network sniffer’), environment and customer profiling, checking for the existence and
configuration of unauthorised wireless networks by using automated tools, discovering the existence of
unauthorised systems by using network discovery and mapping tools and detecting unauthorised changes
to electronic documents and configuration files by using file integrity monitoring software.
Banks’ networks should be designed to support effective monitoring. Design considerations include
network traffic policies that address the allowed communications between computers or groups of
computers, security domains that implement the policies, sensor placement to identify policy violations
and anomalous traffic, nature and extent of logging, log storage and protection and ability to implement
additional sensors on an ad hoc basis when required.
Banks would need to establish a clear allocation of responsibility for regular monitoring, and the processes
and tools in this regard should be in a position to manage the volume of monitoring required, thereby
reducing the risk of an incident going undetected.
Highly sensitive and/or critical IT assets would need to have logging enabled to record events and
monitored at a level proportional to the level of risk.
Users, like system administrators, with elevated access privileges should be subjected to a greater level of
monitoring in light of the heightened risks involved.
The integrity of the monitoring logs and processes should be safeguarded through appropriate access
controls and segregation of duties.
Banks should frequently review all system accounts and disable any account that cannot be associated with
a business process and business owner. Reports that may be generated from systems and reviewed
frequently may include, among others, a list of locked out accounts, disabled accounts, accounts with
passwords that exceed the maximum password age, and accounts with passwords that never expire.
Banks should establish and follow a process for revoking system access by disabling accounts immediately
upon termination of an employee or contractor.
Banks should regularly monitor the use of all accounts, automatically logging off users after a standard
period of inactivity.
Banks should monitor account usage to determine dormant accounts that have not been used for a given
period, say 15 days, notifying the user or user’s manager of the dormancy. After a longer period, say 30
days, the account may be disabled.
On a periodic basis, say monthly or quarterly basis, banks should require that managers match active
employees and contractors with each account belonging to their managed staff. Security/system
administrators should then disable accounts that are not assigned to active employees or contractors.
Banks should monitor attempts to access deactivated accounts through audit logging.
Banks should validate audit log settings for each hardware device and the software installed on it, ensuring
that logs include a date, timestamp, source addresses, destination addresses, and various other useful
elements of each packet and/or transaction. Systems should record logs in a standardized format such as
syslog entries. If systems cannot generate logs in a standardized format, banks need to deploy log
normalization tools to convert logs into a standardized format.
System administrators and information security personnel should consider devising profiles of common
events from given systems, so that they can tune detection to focus on unusual activity, reducing false
positives, more rapidly identify anomalies, and prevent overwhelming the analysts with insignificant
alerts.
The following technologies/factors provide capabilities for effective attack detection and analysis:
Security Information and Event Management (SIEM) - SIEM products provide situational
awareness through the collection, aggregation, correlation and analysis of disparate data from
various sources. The information provided by these tools help in understanding the scope of
an incident.
Intrusion Detection and Prevention System (IDS and IPS) - IPS products that have detection
capabilities should be fully used during an incident to limit any further impact on the
organization. IDS and IPS products are often the primary source of information leading to the
identification of an attack. Once the attack has been identified, it is essential to enable the
appropriate IPS rule sets to block further incident propagation and to support containment and
eradication.
Network Behaviour Analysis (NBA) - Network wide anomaly-detection tools will provide
data on traffic patterns that are indicative of an incident. Once an incident has been identified
through the use of these tools, it is important to capture that information for the purposes of
supporting further mitigation activities, including operational workflow to ensure that the
information from these tools is routed to the appropriate response team.
Managed Security Service Provider (MSSP) - If an organization has outsourced security event
management to an MSSP, the latter should provide notification when an incident requires
attention. Organisation must obtain as much information on the incident as possible from
MSSP and implement remediation steps as recommended by MSSP.
Banks also need to pro-actively monitor various authentic sources like CERT-In, security vendors, etc.
for any security related advisories and take suitable measures accordingly.
Malicious software is an integral and a dangerous aspect of internet based threats which target end-users
and organizations through modes like web browsing, email attachments, mobile devices, and other vectors.
Malicious code may tamper with a system's contents, and capture sensitive data. It can also spread to other
systems. Modern malware aims to avoid signature-based and behavioral detection, and may disable
anti-virus tools running on the targeted system. Anti-virus and anti-spyware software, collectively referred
to as anti-malware tools, help defend against these threats by attempting to detect malware and block their
execution.
Typical controls to protect against malicious code use layered combinations of technology, policies and
procedures and training. The controls are of the preventive and detective/corrective in nature. Controls are
applied at the host, network, and user levels:
At host level: The various measures at the host level include host hardening(including patch
application and proper security configurations of the
operating system (OS), browsers, and other network-aware software), considering implementing
host-based firewalls on each internal computer and especially laptops assigned to mobile users. Many
host-based firewalls also have application hashing capabilities, which are helpful in identifying
applications that may have been trojanized after initial installation, considering host IPS and integrity
checking software combined with strict change controls and configuration management, periodic
auditing of host configurations, both manual and automated.
At network level: The various measures include limiting the transfer of executable files through the
perimeter, IDS and IPS monitoring of incoming and outgoing network traffic, including anti-virus,
anti-spyware and signature and anomaly-based traffic monitors, routing Access Control Lists(ACLs)
that limit incoming and outgoing connections as well as internal connections to those necessary for
business purposes, proxy servers that inspect incoming and outgoing packets for indicators of
malicious code and block access to known or suspected malware distribution servers, filtering to
protect against attacks such as cross-site scripting and SQL injection.
At user level: User education in awareness, safe computing practices, indicators of malicious code, and
response actions.
Enterprise security administrative features may be used daily to check the number of systems that do not
have the latest anti-malware signatures. All malware detection events should be sent to enterprise
anti-malware administration tools and event log servers.
Banks should employ anti-malware software and signature auto update features to automatically update
signature files and scan engines whenever the vendor publishes updates. After applying an update,
automated systems should verify that each system has received its signature update. The bank should
monitor anti-virus console logs to correct any systems that failed to be updated. The systems deployed for
client security should be delivering simplified administration through central management and providing
critical visibility into threats and vulnerabilities. It should also integrate with existing infrastructure
software, such as Active Directory for enhanced protection and greater control.
Administrators should not rely solely on AV software and email filtering to detect worm infections. Logs
from firewalls, intrusion detection and prevention sensors, DNS servers and proxy server logs should be
monitored on a daily basis for signs of worm infections including but not limited to:
Outbound SMTP connection attempts from anything other than a bank’s SMTP mail
gateways
Excessive or unusual scanning on TCP and UDP ports 135-139 and 445
Connection attempts on IRC or any other ports that are unusual for the environment
Excessive attempts from internal systems to access non-business web sites
Excessive traffic from individual or a group of internal systems
Excessive DNS queries from internal systems to the same host name and for known
“nonexistent” host names. Using a centralized means such as a syslog host to collect logs
from various devices and systems can help in the analysis of the information
Banks should configure laptops, workstations, and servers so that they do not auto-run content from USB
tokens, USB hard drives, CDs/DVDs, external SATA devices, mounted network shares, or other
removable media.
Banks should configure systems so that they conduct an automated antimalware scan of removable media
when it is inserted.
Banks can also consider deploying the Network Access Control (NAC) tools to verify security
configuration and patch level compliance of devices before granting access to a network. Network
Admission Control (NAC) restricts access to the network based on the identity or security posture of an
organization. When NAC is implemented, it will force a user or a machine seeking network access for
authentication prior to granting actual access to the network. A typical (non-free) WiFi connection is a
form of NAC. The user must present some sort of credentials (or a credit card) before being granted
access to the network. The network admission control systems allow noncompliant devices to be denied
access, placed in a quarantined area, or given restricted access to computing resources, thus keeping
insecure nodes from infecting the network. The key component of the Network Admission Control
program is the Trust Agent, which resides on an endpoint system and communicates with routers on the
network. The information is then relayed to a Secure Access Control Server (ACS) where access control
decisions are made. The ACS directs the router to perform enforcement against the endpoint.
Email Attachment Filtering - Banks should filter various attachment types at the email gateway, unless
required for specific business use. Some examples include .ade .cmd
.eml .ins .mdb .mst .reg .url .wsf .adp .com .exe .isp .mde .pcd .scr .vb .wsh .bas .cpl
.hlp .js .msc .pif .sct .vbe .bat .crt .hta .jse .msi .pl .scx .vbs .chm .dll .inf.lnk .msp .pot
.shs .wsc… etc. Banks should consider only allowing file extensions with a documented business case and
filtering all others.
Patch Management:
A Patch Management process needs to be in place to address technical system and software vulnerabilities
quickly and effectively in order to reduce the likelihood of a serious business impact arising.
There should be documented standards / procedures for patch management. The standards / procedures for
patch management should include a method of defining roles and responsibilities for patch management,
determining the importance of systems (for e.g., based on the information handled, the business processes
supported and the environments in which they are used) , recording patches that have been applied (for
e.g., using an inventory of computer assets including their patch level).
The patch management process should include aspects like:
Determining methods of obtaining and validating patches for ensuring that the patch is
from an authorised source
Identifying vulnerabilities that are applicable to applications and systems used by the
organisation
Assessing the business impact of implementing patches (or not implementing a particular
patch)
Ensuring patches are tested
Describing methods of deploying patches, for example, through automated manner
Critical patches must be evaluated in a test environment before being updated into production on
enterprise systems. If such patches break critical business applications on test machines, the organization
must devise other mitigating controls that block exploitation on systems where the patch is difficult to be
deployed because of its impact on business functionality.
Change Management:
A change management process should be established, which covers all types of change. For example,
upgrades and modifications to application and software, modifications to business information,
emergency ‘fixes’, and changes to the computers / networks that support the application.
The change management process should be documented, and include approving and testing changes to
ensure that they do not compromise security controls, performing changes and signing them off to ensure
they are made correctly and securely, reviewing completed changes to ensure that no unauthorised
changes have been made.
The following steps should be taken prior to changes being applied to the live environment:
Change requests should be documented (e.g., on a change request form) and accepted only from
authorised individuals and changes should be approved by an appropriate authority
The potential business impacts of changes should be assessed (for e.g., in terms of the overall risk and
impact on other components of the application)
Changes should be tested to help determine the expected results (for e.g., deploying the patch into the
live environment)
Changes should be reviewed to ensure that they do not compromise security controls (e.g., by checking
software to ensure it does not contain malicious code, such as a trojan horse or a virus)
Back-out positions should be established so that the application can recover from failed changes or
unexpected results
Changes to the application should be performed by skilled and competent individuals who are capable of
making changes correctly and securely and signed off by an appropriate business official.
Audit trails
Banks needs to ensure that audit trails exist for IT assets satisfying the banks business requirements
including regulatory and legal requirements, facilitating audit, serving as forensic evidence when required
and assisting in dispute resolution. This could include, as applicable, various areas like transaction with
financial consequences, the opening, modifications or closing of customer accounts, modifications in
sensitive master data, accessing or copying of sensitive data/information; and granting, modification or
revocation of systems access rights or privileges for accessing sensitive IT assets.
Audit trails should be secured to ensure the integrity of the information captured, including the
preservation of evidence. Retention of audit trails should be in line with business, regulatory and legal
requirements.
Operating systems should be configured to log access control events associated with a user
attempting to access a resource like a file or directory without the appropriate permissions
Security personnel and/or administrators designated in this regard should identify anomalies in
logs and actively review the anomalies, documenting their findings on an ongoing basis
Each bank can consider at least two synchronized time sources are available in their network
from which all servers and network equipment retrieve time information on a regular basis, so
that timestamps in logs are consistent
Network boundary devices, including firewalls, network-based IPSs, and inbound and
outbound proxies may be configured to log verbosely all traffic (both allowed and blocked)
arriving at the device
Given the multiplicity of devices and systems, banks should consider deploying a Security Information
and Event Management (SIEM) system tool for log aggregation and consolidation from multiple
machines/systems and for log correlation and analysis, as indicated earlier in the chapter. Furthermore,
event logs may be correlated with information from vulnerability scans to fulfill two goals. First,
personnel should verify that the activity of the regular vulnerability scanning tools themselves is logged.
And, secondly, personnel should be able to correlate attack detection events with earlier vulnerability
scanning results to determine whether the given exploit was used against a known-vulnerable target.
E-banking systems should be designed and installed to capture and maintain forensic evidence in a
manner that maintains control over the evidence, and prevents tampering and the collection of false
evidence.
In instances where processing systems and related audit trails are the responsibility of a third-party service
provider, the bank should ensure that it has access to relevant audit trails maintained by the service
provider apart from ensuring that the audit trails maintained by the service provider meet the bank's
standards.
Security monitoring arrangements should provide key decision-makers and Senior Management/Board of
Directors with an informed view of aspects like the effectiveness and efficiency of information security
arrangements, areas where improvement is required, information and systems that are subject to an
unacceptable level of risk, performance against quantitative, objective targets, actions required to help
minimize risk (e.g., reviewing the organization’s risk appetite, understanding the information security
threat environment and encouraging business and system owners to remedy unacceptable risks).
There should be arrangements for monitoring the information security condition of the organisation,
which are documented, agreed with top management and performed regularly. Information generated by
monitoring the information security condition of the organization should be used to measure the
effectiveness of the information security strategy, information security policy and security architecture.
Analysis performed as part of security monitoring and reporting arrangement may include, inter-alia, the
following:
Details relating to information security incidents and their impact
Steps taken for non-recurrence of such events in the future
Major Internal and external audit/vulnerability assessment/penetration test findings and
remediation status
Operational security statistics, such as firewall log data, patch management details and number of
spam e-mails
Costs associated with financial losses, legal or regulatory penalties and risk profile(s)
Information collected as part of security reporting arrangements should include details about all aspects of
information risk like criticality of information, identified vulnerabilities and level of threats, potential
business impacts and the status of security controls in place. Information about the security condition of
the organisation should be provided to key decision-makers/stake holders like the Board, top management,
members of Information Security Committee, and relevant external bodies like regulator as required.
Metrics can be an effective tool for security managers to discern the effectiveness of various components
of their security policy and programs, the security of a specific system, product or process, effectiveness
and efficiency of security services delivery, the impact of security events on business processes and the
ability of staff or departments within an organization to address security issues for which they are
responsible. Additionally, they may be used to raise the level of security awareness within the
organization. The measurement of security characteristics can allow management to increase control and
drive further improvements to the security procedures and processes.
Each dimension of the IT security risk management framework can be measured by at least one metric to
enable the monitoring of progress towards set targets and the identification of trends. The use of metrics
needs to be targeted towards the areas of greatest criticality. Generally, it is suggested that effective
metrics need to follow the SMART acronym i.e. specific, measurable, attainable, repeatable and
time-dependent.
In addition, a comprehensive set of metrics that provide for prospective and retrospective measures, like
key performance indicators and key risk indicators, can be devised.
The efficacy of a security metrics system in mitigating risk depends on completeness and accuracy of the
measurements and their effective analysis. The measurements should be reliable and sufficient to justify
security decisions that affect the institution’s security posture, allocate resources to security-related tasks,
and provide a basis for security-related reports.
Some illustrative metrics include coverage of anti-malware software and their updation percentage, patch
latency, extent of user awareness training, vulnerability related metrics, etc.
Banks use third-party service providers in a variety of different capacities. It can be an Internet service
provider (ISP), application or managed service provider (ASP/MSP) or business service provider (BSP).
These providers may often perform important functions for the bank and usually may require access to
confidential information, applications and systems.
When enterprises use third parties, they can become a key component in an enterprise’s controls and its
achievement of related control objectives. Management should evaluate the role that the third party
performs in relation to the IT environment, related controls and control objectives.
The effectiveness of third-party controls can enhance the ability of an enterprise to achieve its control
objectives. Conversely, ineffective third-party controls can weaken the ability of a bank to achieve its
control objectives. These weaknesses can arise from many sources including gaps in the control
environment arising from the outsourcing of services to the third party, poor control design, causing
controls to operate ineffectively, lack of knowledge and/or inexperience of personnel responsible for
control functions and over-reliance on the third party’s controls (when there are no compensating controls
within the enterprise).
Third-party providers can affect an enterprise (including its partners), its processes, controls and control
objectives on many different levels. This includes effects arising from such things as economic viability of
the third-party provider, third-party provider
access to information that is transmitted through their communication systems and applications, systems
and application availability, processing integrity, application development and change management
processes and the protection of systems and information assets through backup recovery, contingency
planning and redundancy.
The lack of controls and/or weakness in their design, operation or effectiveness can lead to consequences
like loss of information confidentiality and privacy, systems not being available for use when needed,
unauthorized access and changes to systems, applications or data, changes to systems, applications or data
occurring that result in system or security failures, loss of data, loss of data integrity, loss of data
protection, or system unavailability, loss of system resources and/or information assets and Increased
costs incurred by the enterprise as a result of any of the above.
The relationship between the enterprise and a third-party provider should be documented in the form of an
executed contract. The various details and requirements on the matter are covered under chapter on “IT
outsourcing”.
Network Security
Protection against growing cyber threats requires multiple layers of defenses, known as defense in depth.
As every organization is different, this strategy should therefore be based on a balance between protection,
capability, cost, performance, and operational considerations. Defense in depth for most organizations
should at least consider the following two areas:
Protecting the enclave boundaries or perimeter
Protecting the computing environment.
The enclave boundary is the point at which the organization’s network interacts with the Internet. To
control the flow of traffic through network borders and to police its content looking for attacks and
evidence of compromised machines, boundary defenses should be multi-layered, relying on firewalls,
proxies, DMZ perimeter networks, and network-based Intrusion Prevention Systems and Intrusion
Detection Systems.
It should be noted that boundary lines between internal and external networks are diminishing through
increased interconnectivity within and between organizations and use of wireless systems. These blurring
lines sometimes allow attackers to gain access inside networks while bypassing boundary systems.
However, even with this blurring, effective security deployment still rely on carefully configured
boundary defenses that separate networks with different threat levels, different sets of users, and different
levels of control. Effective multi-layered defenses of perimeter networks help to lower the number of
successful attacks, allowing security personnel to focus on attackers who have devised methods to bypass
boundary restrictions.
An effective approach to securing a large network involves dividing the network into logical security
domains. A logical security domain is a distinct part of a network with security policies that differ from
other domains and perimeter controls enforcing access at a network level. The differences may be far
broader than network controls, encompassing personnel, host, and other issues. Before establishing
security domains, banks need to map and configure the network to identify and control all access points.
Network configuration considerations could include the following actions:
Identifying the various applications and systems accessed via the network
Identifying all access points to the network including various telecommunications channels like
ethernet, wireless, frame relay, dedicated lines, remote dial-up access, extranets, internet
Mapping the internal and external connectivity between various network segments
Defining minimum access requirements for network services
Determining the most appropriate network configuration to ensure adequate security and performance
for the bank
With a clear understanding of network connectivity, banks can avoid introducing security vulnerabilities
by minimizing access to less-trusted domains and employing encryption and other controls for less secure
connections. Banks can then determine the most effective deployment of protocols, filtering routers,
firewalls, gateways, proxy servers, and/or physical isolation to restrict access. Some applications and
business processes may require complete segregation from the corporate network, for example, preventing
connectivity between corporate network and wire transfer system. Others may restrict access by placing
the services that must be accessed by each zone in their own security domain, commonly called a
De-Militarized Zone.
Security domains are bounded by perimeters. Typical perimeter controls include firewalls that operate at
different network layers, malicious code prevention, outbound filtering, intrusion detection and prevention
devices, and controls over infrastructure services such as DNS. The perimeter controls may exist on
separate devices or be combined or consolidated on one or more devices. Consolidation on a single device
could improve security by reducing administrative overhead. However, consolidation may increase risk
through a reduced ability to perform certain functions and the existence of a single point of failure.
A few network protection devices are briefly explained as under:
Firewalls: The main purpose of a firewall is access control. By limiting inbound (from the Internet to
the internal network) and outbound communications (from the internal network to the Internet), various
attack vectors can be reduced. Firewalls may provide additional services like Network Address
Translation and Virtual Private Network Gateway.
Financial institutions have four primary firewall types from which to choose: packet filtering, stateful
inspection, proxy servers, and application-level firewalls. Any product may have characteristics of one
or more firewall types. The selection of a firewall type is dependent on many characteristics of the
security zone, such as the amount of traffic, the sensitivity of the systems and data, and applications.
Packet filter firewalls evaluate the headers of each incoming and outgoing packet to ensure it has a valid internal
address, originates from a permitted external address, connects to an authorized protocol or service, and
contains valid basic header instructions. If the packet does not match the pre -defined policy for allowed traffic,
then the firewall drops the packet. Packet filters generally do not analyze the packet contents beyond the header
information. Among the major weaknesses associated with packet filtering firewalls include inability to prevent
attacks that exploit application-specific vulnerabilities and functions because the packet filter does not examine
packet contents and logging functionality is limited to the same information used to make access control
decisions.
Stateful inspection firewalls are packet filters that monitor the state of the TCP connection. Each TCP session
starts with an initial “handshake” communicated through TCP flags in the header information. When a
connection is established the firewall adds the connection information to a table. The firewall can then compare
future packets to the connection or state table. This essentially verifies that inbound traffic is in response to
requests initiated from inside the firewall.
Proxy servers act as an intermediary between internal and external IP addresses and block direct access to the
internal network. Essentially, they rewrite packet headers to substitute the IP of the proxy server for the IP of the
internal machine and forward packets to and from the internal and external machines. Due to that limited
capability, proxy servers are commonly employed behind other firewall devices. The primary firewall receives
all traffic, determines which application is being targeted, and hands off the traffic to the appropriate
proxy server. Common proxy servers are the domain name server (DNS), Web server (HTTP), and mail (SMTP)
server. Proxy servers frequently cache requests and responses, providing potential performance benefits.
Additionally, proxy servers provide another layer of access control by segregating the flow of Internet traffic to
support additional authentication and logging capability, as well as content filtering. Web and e-mail proxy
servers, for example, are capable of filtering for potential malicious code and application -specific commands.
Proxy servers are increasing in importance as protocols are tunnelled through other protocols.
Application-Level Firewalls
Application-level firewalls perform application-level screening, typically including the filtering capabilities of
packet filter firewalls with additional validation of the packet content based on the application.
Application-level firewalls capture and compare packets to state information in the connection tables. Unlike a
packet filter firewall, an application level firewall continues to examine each packet after the initial connection
is established for specific application or services such as telnet, FTP, SMTP, etc. The application- level firewall
can provide additional screening of the packet payload for commands, protocols, packet length, authorization,
content, or invalid headers. Application level firewalls provide the strongest level of security.
Firewall Policy
A firewall policy states management’s expectation for how the firewall should function and is a component of
the overall security management framework. Acceptable inbound communication types for the organization
need to be explicitly defined in the firewall policies. As the firewall is usually one of the first lines of defense,
access to the firewall device itself needs to be strictly controlled.
At a minimum, the policy should address various aspects like Firewall topology and architecture and type of
firewalls being utilized, physical placement of the firewall components, permissible traffic and monitoring
firewall traffic, firewall updating, coordination with security monitoring and intrusion response mechanisms,
responsibility for monitoring and enforcing the firewall policy, protocols and applications permitted, regular
auditing of a firewall’s configuration and testing of the firewall’s effectiveness, and contingency planning.
Firewalls should not be relied upon, however, to provide full protection from attacks. Banks should complement
firewalls with strong security policies and a range of other controls. In fact, firewalls are potentially vulnerable
to attacks including spoofing trusted IP addresses, denial of service by overloading the firewall with excessive
requests or malformed packets, sniffing of data that is being transmitted outside the network, hostile code
embedded in legitimate HTTP, SMTP, or other traffic that meet all firewall rules, etc. Banks can reduce their
vulnerability to these attacks through network configuration and design, sound implementation of its firewall
architecture that includes multiple filter points, active firewall monitoring and management, and integrated
security monitoring. In many cases, additional access controls within the operating system or application will
provide additional means of defense.
Given the importance of firewalls as a means of access control, good firewall related practices include:
Using a rule set that disallows all inbound and outbound traffic that is not specifically allowed
Using NAT and split DNS to hide internal system names and addresses from external networks
Using proxy connections for outbound HTTP connections and filtering malicious code
Hardening the firewall by removing all unnecessary services and appropriately patching, enhancing,
and maintaining all software on the firewall unit
Restricting network mapping capabilities through the firewall, primarily by blocking inbound ICMP
(Internet Control Messaging Protocol) traffic
Backing up firewalls to internal media and not backing up the firewall to servers on protected networks
Logging activity, with daily administrator review and limiting administrative access to few individuals
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
Using security monitoring devices and practices to monitor actions on the firewall and to monitor
communications allowed through the firewall
Administering the firewall using encrypted communications and strong authentication, accessing the
firewall only from secure devices, and monitoring all administrative access
Making changes only through well-administered change control procedures.
The firewall also needs to be configured for authorized outbound network traffic. In the case of a compromised
host inside the network, outbound or egress filtering can contain that system and prevent it from communicating
outbound to their controller – as in the case with botnets. Often times, firewalls default to allowing any
outbound traffic, therefore, organizations may need to explicitly define the acceptable outbound communication
policies for their networks. In most cases the acceptable outbound connections would include SMTP to any
address from only your SMTP mail gateway(s), DNS to any address from an internal DNS server to resolve
external host names, HTTP and HTTPS from an internal proxy server for users to browse web sites, NTP to
specific time server addresses from an internal time server(s), any ports required by Anti-Virus, spam filtering,
web filtering or patch management software to only the appropriate vendor address(es) to pull down updates
and any other rule where the business case is documented and signed off by appropriate management.
Perimeters may contain proxy firewalls or other servers that act as a control point for Web browsing, e-mail,
P2P, and other communications. Those firewalls and servers frequently are used to enforce the institution’s
security policy over incoming communications. Enforcement is through anti-virus, anti-spyware, and anti-spam
filtering, the blocking of downloading of executable files, and other actions. To the extent that filtering is done
on a signature basis, frequent updating of the signatures may be required, as had been explained earlier.
Perimeter servers also serve to inspect outbound communications for compliance with the institution’s security
policy. Perimeter routers and firewalls can be configured to enforce policies that forbid the origination of
outbound communications from certain computers. Additionally, proxy servers could be configured to identify
and block customer data and other data that should not be transmitted outside the security domain.
The goal of an IDS is to identify network traffic in near real time. Most IDSs use signatures to detect port scans,
malware, and other abnormal network communications. The ideal placement of an IDS is external to the
organization as well as internally, just behind the firewall. This would enable a bank to view the traffic
approaching the organization as well as the traffic that successfully passed through the firewall. Conversely,
there will be visibility on internal traffic trying to communicate externally to the network – particularly useful
for situations where malicious activity originates from inside the firewall.
To use a network IDS (NIDS) effectively, an institution should have a sound understanding of the detection
capability and the effect of placement, tuning, and other network defences on the detection capability.
The signature-based detection methodology reads network packets and compares the content of the packets
against signatures, or unique characteristics, of known attacks. When a match is recognized between current
readings and a signature, the IDS generates an alert. A weakness in the signature-based detection method is that
a signature must exist for an alert to be generated. Signatures are written to either capture known exploits, or to
alert to suspected vulnerabilities. Vulnerability-based detection is generally broad based, alerting on many
exploits for the same vulnerability and potentially alerting on exploits that are not yet known which is not the
case with exploit-based signatures which may be based on specific exploits only and may not alert when a new
or previously unknown exploit is attempted.
This problem can be particularly acute if the institution does not continually update its signatures to reflect
lessons learned from attacks on itself and others, as well as developments in attack tool technologies. It can also
pose problems when the signatures only address known attacks. Another weakness is in the capacity of the
NIDS to read traffic. If the NIDS falls behind in reading network packets, traffic may be allowed to bypass the
NIDS. Such traffic may contain attacks that would otherwise cause the NIDS to issue an alert.
The anomaly -based detection method generally detects deviations from a baseline. The baseline can be either
protocol- based, or behaviour-based. The protocol-based baseline detects differences between the detected
packets for a given protocol and the Internet’s RFCs (Requests for Comment) pertaining to that protocol. For
example, a header field could exceed the RFC-established expected size.
The behaviour -based anomaly detection method creates a statistical profile of normal activity on the host or
network. Normal activity generally is measured based on the volume of traffic, protocols in use, and connection
patterns between various devices. Benchmarks for activity are established based on that profile. When current
activity exceeds the identified boundaries, an alert is generated. Weaknesses in this system involve the ability of
the system to accurately model activity, the relationship between valid activity in the period being modelled and
valid activity in future periods, and the potential for malicious activity to take place while the modelling is
performed. This method is best employed in environments with predictable, stable activity.
Anomaly detection can be an effective supplement to signature- based methods by signalling attacks for which
no signature yet exists. Proper placement of NIDS sensors is a strategic decision determined by the information
the bank is trying to obtain. Placement outside the firewall will deliver IDS alarms related to all attacks, even
those that are blocked by the firewall. With this information, an institution can develop a picture of potential
adversaries and their expertise based on the probes they issue against the network.
Because the placement is meant to gain intelligence on attackers rather than to alert on attacks, tuning generally
makes the NIDS less sensitive than if it is placed inside the firewall. A NIDS outside the firewall will generally
alert on the greatest number of unsuccessful attacks while NIDS monitoring behind the firewall is meant to
detect and alert on hostile intrusions. Multiple NIDS units can be used, with placement determined by the
expected attack paths to sensitive data. In general, the closer the NIDS is to sensitive data, the more important
the tuning, monitoring, and response to NIDS alerts. It is generally recommended that NIDS can be placed at
any location where network traffic from external entities is allowed to enter controlled or private networks.
“Tuning” refers to the creation of signatures and alert filters that can distinguish between normal network traffic
and potentially malicious traffic apart from involving creation and implementation of different alerting and
logging actions based on the severity of the perceived attack. Proper tuning is essential to both reliable detection
of attacks and the
enabling of a priority-based response. If IDS is not properly tuned, the volume of alerts it generates may
degrade the intrusion identification and response capability.
Switched networks pose a problem for a network IDS since the switches ordinarily do not broadcast traffic to all
ports while NIDS may need to see all traffic to be effective. When switches do not have a port that receives all
traffic, a bank may have to alter its network to include a hub or other device to allow the IDS to monitor traffic.
Encryption poses a potential limitation for a NIDS. If traffic is encrypted, the NIDS’s effectiveness may be
limited to anomaly detection based on unencrypted header information. This limitation can by overcome by
decrypting packets within the IDS at rates commensurate with the flow of traffic. Decryption is a
device-specific feature that may not be incorporated into all NIDS units.
All NIDS detection methods result in false positives (alerts where no attack exists) and false negatives (no alert
when an attack does take place). While false negatives are obviously a concern, false positives can also hinder
detection. When security personnel are overwhelmed with the number of false positives, their review of NIDS
reports may be less effective thereby allowing real attacks to be reported by the NIDS but not suitably acted
upon. Additionally, they may tune the NIDS to reduce the number of false positives, which may increase the
number of false negatives. Risk-based testing is necessary in this regard to ensure the detection capability is
adequate.
Network Intrusion Prevention Systems (NIPS) are an access control mechanism that allow or disallow access
based on an analysis of packet headers and packet payloads. They are similar to firewalls because they are
located in the communications line, compare activity to pre-configured decisions of the type of packets to filter
or block, and respond with pre-configured actions. The IPS units generally detect security events in a manner
similar to IDS units and are subject to the same limitations. After detection, however, the IPS unit have the
capability to take actions beyond simple alerting to potential malicious activity and logging of packets such as
blocking traffic flows from an offending host. The ability to sever communications can be useful when the
activity can clearly be identified as malicious. When the activity cannot be clearly identified, for example where
a false positive may exist, IDS-like alerting commonly is preferable to blocking. Although IPS units are access
control devices, many of these units implement a security model that is different from firewalls. Firewalls
typically allow only the traffic necessary for business purposes, or only “known good” traffic. IPS units
typically are configured to disallow traffic that triggers signatures, or “known bad” traffic, while allowing all
else. However, IPS units can be configured to more closely mimic a device that allows only “known good”
traffic. IPS units also contain a “white list” of IP addresses that should never be blocked. The list helps ensure
that an attacker cannot achieve a denial of service by spoofing the IP of a critical host.
d) Quarantine
Quarantining a device protects the network from potentially malicious code or actions. Typically, a device
connecting to a security domain is queried for conformance to the domain’s security policy. If the device does
not conform, it is placed in a restricted part of the network until it does conform. For example, if the patch level
is not current, the device is not allowed into the security domain until the appropriate patches are downloaded
and installed.
e) DNS Placement
Effective protection of the institution’s DNS servers is critical to maintaining the security of the institution’s
communications. Much of the protection is provided by host security However, the placement of the DNS also
is an important factor. The optimal placement is split DNS, where one firewalled DNS server serves public
domain information to the outside
and does not perform recursive queries, and a second DNS server, in an internal security domain and not the
DMZ, performs recursive queries for internal users.
In addition to the above, the following are among the factors that need to be followed for improving the security
of networks:
Identifying all connections to critical networks and conducting risk analysis including
necessity for each connection. All unnecessary connections to critical networks to be
disconnected.
Implementation of the security features recommended by device and system vendors.
Establishing strong controls over any medium that is used as a backdoor into the critical
network. If backdoors or vendor connections do exist in critical systems, strong
authentication must be implemented to ensure secure communications.
Implementation of internal and external intrusion detection system, incident response
system and establishing 24x7 incident monitoring
Establishing critical "Red Teams" to identify and evaluate possible attack scenarios.
There is a need to feed information resulting from the "Red Team" evaluation into risk
management processes to assess the information and establish appropriate protection
strategies.
Documenting network architecture and identifying systems that serve critical functions or
contain sensitive information that require additional levels of protection.
Establishing a rigorous, ongoing risk management process.
Establishing a network protection strategy and layered security based on the principle of
defense-in-depth is an absolute necessity for banks. This would require suitable measures
to address vulnerabilities across the hardware, operating system, middleware, database,
network and application layers. Security is not an event but a process which requires all
its various components to be functioning well together for their effectiveness.
Additionally, each layer must be protected against other systems at the same layer. For
example, to protect against insider threat, restrict users to access only those resources
necessary to perform their job functions.
m. Establishing system backups and disaster recovery plans. Establish a disaster recovery plan
that allows for rapid recovery from any emergency (including a cyber attack).
Network operation standards and protocols should be documented and made available to
the operators, and should be reviewed periodically to ensure compliance.
Network access by system engineers should be monitored and reviewed closely to detect
unauthorized access to the network.
Another important security improvement is the ability to identify users at every step of
their activity. Some application packages use predefined user id. New monitoring tools
have been developed to resolve this problem.
Remote Access:
Banks may sometimes provide employees, vendors, and others with access to the institution’s network
and computing resources through external connections. Those connections are typically established
through modems, the internet, or private communications lines. The access may be necessary to remotely
support the institution’s systems or to support institution operations at remote locations. In some cases,
remote access may be required periodically by vendors to make emergency programme fixes or to support
a system.
Remote access to a bank’s provides an attacker with the opportunity to manipulate and subvert the bank’s
systems from outside the physical security perimeter. The management should establish policies
restricting remote access and be aware of all remote-access devices attached to their systems. These
devices should be strictly controlled.
Using VLANs, network segments, directories, and other techniques to restrict remote access to
authorized network areas and applications within the institution
Logging remote access communications, analyzing them in a timely manner, and following up on
anomalies
Centralize modem and Internet access to provide a consistent authentication process, and to subject
the inbound and outbound network traffic to appropriate perimeter protections and network
monitoring
Logging and monitoring the date, time, user, user location, duration, and purpose for all remote
access including all activities carried out through remote access
Requiring a two-factor authentication process for remote access (e.g., PIN based token card with a
one-time random password generator, or token based PKI)
Implementing controls consistent with the sensitivity of remote use. For example, remote use to
administer sensitive systems or databases may include the controls like restricting the use of the
access device by policy and configuration, requiring authentication of the access device itself and
ascertaining the trustworthiness of the access device before granting access
Require an operator to leave the modems unplugged or disabled by default, to enable modems only for
specific and authorized external requests, and disable the modem immediately when the requested
purpose is completed
Configure modems not to answer inbound calls, if modems are for outbound use only
Use automated callback features so the modems only call one number although this is subject to call
forwarding schemes
Install a modem bank where the outside number to the modems uses a different prefix than internal
numbers and does not respond to incoming calls
While using TCP/IP Internet-based remote access, organizations need to establish a virtual private
network over the Internet to securely communicate data packets over this public infrastructure. Available
VPN technologies apply the Internet Engineering Task Force (IETF) IPSec security standard advantages
are their ubiquity, ease of use, inexpensive connectivity, and read, inquiry or copy only access.
Disadvantages include the fact that they are significantly less reliable than dedicated circuits, lack a
central authority, and can have troubleshooting problems.
Banks need to be aware that using VPNs to allow remote access to their systems can create holes in their
security infrastructure. The encrypted traffic can hide unauthorized actions or malicious software that can
be transmitted through such channels. Intrusion detection systems and virus scanners able to decrypt the
traffic for analysis and then encrypt and forward it to the VPN endpoint should be considered as
preventive controls. A good practice will terminate all VPNs to the same end-point in a so called VPN
concentrator, and will not accept VPNs directed at other parts of the network.
As part of the defence strategy, banks should install and configure network security devices
discussed earlier in the chapter for reasonable preventive/detective capability. Potential
bottlenecks and single points of failure vulnerable to DDoS attacks could be identified
through source code
review, network design analysis and configuration testing. Addressing these vulnerabilities
would improve resilience of the systems.
Banks can also consider incorporating DoS attack considerations in their ISP selection process.
An incident response framework should be devised and validated periodically to facilitate fast
response to a DDoS onslaught or an imminent attack. Banks may also need to be familiar with
the ISPs’ incident response plans and suitably consider them as part of their incident response
framework. To foster better coordination, banks should establish a communication protocol
with their ISPs and conduct periodic joint incident response exercises.
Commercial banks should implement Information Security Management System (ISMS) best practices
for their critical functions/processes.
The best known ISMS is described in ISO/IEC 27001 and ISO/IEC 27002 and related standards
published jointly by ISO and IEC. ISO 27001 is concerned with how to implement, monitor, maintain
and continually improve an Information Security Management System while ISO 27002 provides
detailed steps or a list of security measures which can be used when building an ISMS. Other
frameworks such as COBIT and ITIL though incorporate security aspects, but are mainly geared
toward creating a governance framework for information and IT more generally. As with all
management processes, an ISMS must remain effective and efficient in the long term, adapting to
changes in the internal organization and external environment. ISO/IEC 27001, thus, incorporates the
typical "Plan-Do-Check-Act" (PDCA), or Deming cycle, approach:
The Plan phase is about designing the ISMS, assessing information security risks and selecting
appropriate controls.
The Do phase involves implementing and operating the controls.
The Check phase objective is to review and evaluate the performance (efficiency and effectiveness)
of the ISMS.
In the Act phase, changes are made where necessary to bring the ISMS back to peak performance.
An ISMS developed and based on risk acceptance/rejection criteria, and using third party accredited
certification to provide an independent verification of the level of assurance, is an extremely useful
management tool. It offers the opportunity to define and monitor service levels internally as well as
with contractor/partner organizations, thus demonstrating the extent to which there is effective control
of security risks.
Further, a bank should also regularly assess the comprehensiveness of its information security risk
management framework by comparison to peers and other established control frameworks and
standards including any security related frameworks issued by reputed institutions like IDRBT or
DSCI.
While implementing ISO 27001 and aspects from other relevant standards, banks should be wary of a
routine checklist kind of mindset but ensure that the security management is dynamic in nature through
proactively scanning the environment for new threats and suitably attuned to the changing milieu.
Wireless Security
Wireless networks security is a challenge since they do not have a well-defined perimeter or well-defined
access points. It includes all wireless data communication devices like personal computers, cellular
phones, PDAs, etc. connected to a bank’s internal networks.
Unlike wired networks, unauthorized monitoring and denial of service attacks can be performed without a
physical wire connection. Additionally, unauthorized devices can potentially connect to the network,
perform man-in-the- middle attacks, or connect to other wireless devices. To mitigate those risks, wireless
networks rely on extensive use of encryption to authenticate users and devices and to shield
communications. If a bank uses a wireless network, it should carefully evaluate the risk and implement
appropriate additional controls. Examples of additional controls may include one or more of the
following:
Treating wireless networks as untrusted networks, allowing access through protective devices
similar to those used to shield the internal network from the Internet environment
Using end-to-end encryption in addition to the encryption provided by the wireless connection
Using strong authentication and configuration controls at the access points and on all clients
Using an application server and dumb terminals
Shielding the area in which the wireless LAN operates to protect against stray emissions and
signal interference
Monitoring and responding to unauthorized wireless access points and clients
All wireless Access Points / Base Stations connected to the corporate network must be registered and
approved by Information Security function of a bank. These Access Points / Base Stations need to
subjected to periodic penetration tests and audits. Updated inventory on all wireless Network Interface
Cards used in corporate laptop or desktop computers must be available. Access points/Wireless NIC
should not be installed /enabled on a bank’s network without the approval of information security
function.
Banks should ensure that each wireless device connected to the network matches an authorized
configuration and security profile, with a documented owner of the connection and a defined business
need. Organizations should deny access to those wireless devices that do not have such a configuration
and profile.
Banks should ensure that all wireless access points are manageable using enterprise management tools.
Network vulnerability scanning tools should be configured to detect wireless access points connected to
the wired network. Identified devices should be reconciled against a list of authorized wireless access
points. Unauthorized (i.e., rogue) access points should be deactivated.
Banks should use wireless intrusion detection systems (WIDS) to identify rogue wireless devices and
detect attack attempts and successful compromise. In addition to WIDS, all wireless traffic should be
monitored by a wired IDS as traffic passes into the wired network.
Where a specific business need for wireless access has been identified, banks should configure wireless
access on client machines to allow access only to authorized wireless networks.
For devices that do not have an essential wireless business purpose, organizations should consider disable
wireless access in the hardware configuration (BIOS or EFI), with password protections to lower the
possibility that the user will override such configurations.
Banks should regularly scan for unauthorized or misconfigured wireless infrastructure devices, using
techniques such as “war driving” to identify access points and clients accepting peer-to-peer connections.
Such unauthorized or misconfigured devices should be removed from the network, or have their
configurations altered so that they comply with the security requirements of the organization.
Banks should ensure all wireless traffic leverages at least AES encryption used with at least WPA2
protection. Banks should ensure wireless networks use authentication protocols such as EAP/TLS or
PEAP, which provide credential protection and mutual authentication.
Banks should ensure wireless clients use strong, multi-factor authentication credentials to mitigate the risk
of unauthorized access from compromised credentials.
Banks should disable peer-to-peer wireless network capabilities on wireless clients, unless such
functionality meets a documented business need.
Banks should disable wireless peripheral access of devices (such as Bluetooth), unless such access is
required for a documented business need.
Banks may consider configuring all wireless clients used to access other critical networks or handle
organization data in a manner so that they cannot be used to connect to public wireless networks or any
other networks beyond those specifically allowed by the bank.
All computers with wireless LAN devices must utilize a Virtual Private Network (VPN) that
configured to drop all unauthenticated and unencrypted traffic
Wireless implementations must maintain point-to-point hardware encryption of at least 128 bits
Supporting a hardware address, like MAC address, that can be registered and tracked and
supporting strong user authentication which checks against an external database such as
TACACS+, RADIUS etc
Implementation of mutual authentication of user and authentication server and survey needs to be
done before location of access points to ensure that signals are confined within the premise as
much as possible
Communication between the workstations and access points should be encrypted using dynamic
session keys
Events that trigger the implementation of a business continuity plan may have significant security implications.
Depending on the event, some or all of the elements of the security environment may change. Different
tradeoffs may exist between availability, integrity, confidentiality, and accountability, with a different appetite
for risk on the part of management. Business continuity plans should be reviewed as an integral part of the
security process.
Risk assessments should consider the changing risks that appear in business continuity scenarios and the
different security posture that may be established. Strategies should consider the different risk environment and
the degree of risk mitigation necessary to protect the institution in the event the continuity plans must be
implemented. The implementation should consider the training of appropriate personnel in their security roles,
and the implementation and updating of technologies and plans for back-up sites and communications networks.
These security considerations should be integrated with the testing of business continuity plan implementations.
More information on “Business Continuity Planning” is provided in a separate chapter.
Penetration Testing:
Penetration testing is defined as a formalized set of procedures designed to bypass the security controls of a
system or organization for the purpose of testing that system’s or organization’s resistance to such an attack.
Penetration testing is performed to uncover the security weaknesses of a system and to determine the ways in
which the system can be compromised by a potential attacker. Penetration testing can take several forms but, in
general, a test consists of a series of “attacks” against a target. The success or failure of the attacks, and how the
target reacts to each attack, will determine the outcome of the test.
The overall purpose of a penetration test is to determine the subject’s ability to withstand an attack by a hostile
intruder. As such, the tester will be using the tricks and techniques a real-life attacker might use. This simulated
attack strategy allows the subject to discover and mitigate its security weak spots before a real attacker discovers
them. Because a penetration test seldom is a comprehensive test of the system’s security, it should be combined
with other monitoring to validate the effectiveness of the security process.
Audits
Auditing compares current practices against a set of policies/standards/guidelines formulated by the institution,
regulator including any legal requirements. Bank management is responsible for demonstrating that the
standards it adopts are appropriate for the institution. Audits should not only look into technical aspects but also
the information security governance process.
Assessment
An assessment is a study to locate security vulnerabilities and identify corrective actions. An assessment differs
from an audit by not having a set of standards to test against. It differs from a penetration test by providing the
tester with full access to the systems being tested. Assessments may be focused on the security process or the
information system. They may also focus on different aspects of the information system, such as one or more
hosts or networks. Vulnerability assessment was explained earlier in the chapter.
The assurance work needs to be performed by appropriately trained and independent information security
experts/auditors. The strengths and weaknesses of critical internet-based applications, other critical systems and
networks needs to be carried out before each initial implementation, and at least annually thereafter. Any
findings needs to be reported and monitored using a systematic audit remediation or compliance tracking
methodology.
A bank needs to regularly assess information security vulnerabilities and evaluate the effectiveness of the
existing IT security risk management framework, making any necessary adjustments to ensure emerging
vulnerabilities are addressed in a timely manner. This assessment should also be conducted as part of any
material change.
Robust performance evaluation processes are needed to provide organizations with feedback on the
effectiveness of cyber security policy and technical implementation. A sign of a mature organization is one that
is able to self-identify issues, conduct root cause analyses, and implement effective corrective actions that
address individual and systemic problems. Self-assessment processes that are normally part of an effective cyber
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
security program include routine scanning for vulnerabilities, automated auditing of the network, and -
assessments of organizational and individual business line security related performance.
A bank should manage the information security risk management framework on an ongoing basis as a security
programme following project management approach, addressing the control gaps in a systematic way.
When new operating features or functions, particularly those relating to security, integrity and
authentication, are being introduced, the bank should ensure that customers have sufficient
instruction and information to be able to properly utilize them.
To raise security awareness, banks should sensitize customers on the need to protect their PINs,
security tokens, personal details and other confidential data.
Banks are responsible for the safety and soundness of the services and systems they provide to their
customers. Reciprocally, it is also important that customers take appropriate security measures to
protect their devices and computer systems and ensure that their integrity is not compromised when
engaging in online banking. Customers should implement the measures advised by their banks
regarding protecting their devices or computers which they use for accessing banking services.
In view of the constant changes occurring in the internet environment and online delivery channels,
management should institute a risk monitoring and compliance regime on an ongoing basis to
ascertain the performance and effectiveness of the risk management process. When risk parameters
change, the risk process needs to be updated and enhanced accordingly. Re-evaluation of past
risk-control measures and equations, renewed testing and auditing of the adequacy and effectiveness
of the risk management process and the attendant controls and security measures taken should be
conducted.
Internet banking:
Banks need to ensure suitable security measures for their web applications and take reasonable mitigating
measures against various web security risks indicated earlier in the chapter.
ii.Web applications should not store sensitive information in HTML hidden fields, cookies, or any other
client-side storage leading to compromise in the integrity of the data. Critical web applications should enforce at
least SSL v3 or Extended Validation –SSL / TLS 1.0 128 bit encryption level for all online activity.
identification, authentication, and authorization. Moreover, strong server side validation should be enabled.
Compiled by Srinivas Kante Email: [email protected]
Compiled by Srinivas Kante Email: [email protected]
Banks need to follow a defense in depth strategy by applying robust security measures across various
technology layers
Implementation of two-factor authentication and other security measures for internet banking:
In view of the proliferation of cyber attacks and their potential consequences, banks should implement
two-factor authentication for fund transfers through internet banking.
There is a legal risk in not using the asymmetric cryptosystem and hash function for authenticating
electronic transactions. However, it is observed that some banks still use weak user id/password based
authentication for fund transfers using internet banking. For carrying out critical transactions like fund
transfers, the banks, at the least, need to implement robust and dynamic two-factor authentication
through user id/password combination and second factor like (a) a digital signature (through a token
containing digital certificate and associated private key) (preferably for the corporate customers) or (b)
OTP/dynamic access code through various modes (like SMS over mobile phones or hardware token).
To enhance online processing security, confirmatory second channel procedures(like telephony, SMS,
email etc) should be applied in respect of transactions above pre-set values, creation of new account
linkages, registration of third party payee details, changing account details or revision to funds transfer
limits. In devising these security features, the bank should take into account their efficacy and differing
customer preferences for additional online protection.
Based on mutual authentication protocols, customers could also authenticate the bank’s web site
through security mechanisms such as personal assurance messages/images, exchange of challenge
response security codes and/or the secure sockets layer (SSL) server certificate verification. In recent
times, Extended Validation Secure Sockets Layer (EV-SSL) Certificates are increasingly being used.
These are special SSL Certificates that work with high security Web browsers to
clearly identify a Web site's organizational identity. It should, however, be noted that SSL is only
designed to encrypt data in transit at the network transport layer. It does not provide end-to-end
encryption security at the application layer.
An authenticated session, together with its encryption protocol, should remain intact throughout the
interaction with the customer. Else, in the event of interference, the session should be terminated and
the affected transactions resolved or reversed out. The customer should be promptly notified of such an
incident as the session is being concluded or subsequently by email, telephone or through other means.
Changes in mobile phone number may be done through request from a branch only
By definition true multifactor authentication requires the use of solutions from two or more of the three
categories of factors. Using multiple solutions from the same category at different points in the process
may be part of a layered security or other compensating control approach, but it would not constitute a
true multifactor authentication.
As an integral part of the two factor authentication architecture, banks should also implement
appropriate measures to minimise exposure to a middleman attack which is more commonly known as
a man-in-the-middle attack (MITM), man-in-the browser(MITB) attack or man-in-the application
attack. The banks should also consider, and if deemed appropriate, implement the following control
and security measures to minimise exposure to man-in-the middle attacks:
Specific OTPs for adding new payees: Each new payee should be authorized by the
customer based on an OTP from a second channel which also shows payee details or the
customer’s handwritten signature from a manual procedure which is verified by the bank.
Individual OTPs for value transactions (payments and fund transfers) :Each value
transaction or an approved list of value transactions above a certain rupee threshold determined
by the customer should require a new OTP.
OTP time window: Challenge-based and time-based OTPs provide strong security
because their period of validity is controlled entirely by the bank and does not depend user behaviour.
It is recommended that the banks should not allow the OTP time window to exceed 100 seconds on
either side of the server time since the smaller the time window, the lower the risk of OTP misuse.
Payment and fund transfer security: Digital signatures and key-based message
authentication codes (KMAC) for payment or fund transfer transactions could be considered for the
detection of unauthorized modification or injection of transaction data in a middleman attack. For this
security solution to work effectively, a customer using a hardware token would need to be able to
distinguish the process of generating a one-time password from the process of digitally signing a
transaction. What he signs digitally must also be meaningful to him, which means the token should at
least explicitly show the payee account number and the payment amount from which a hash value may
be derived for the purpose of creating a digital signature. Different crypto keys should be used for
generating OTPs and for signing transactions.
Second channel notification / confirmation: The bank should notify the customer,
through a second channel, of all payment or fund transfer transactions above a specified value
determined by the customer.
Session time-out: An online session would be automatically terminated after a fixed period of
time unless the customer is re-authenticated for the existing session to be maintained. This prevents an
attacker from keeping an internet banking session alive indefinitely.
SSL server certificate warning: Internet banking customers should be made aware of and shown how to react to SSL
or EV-SSL certificate warning
Discussed below are some emerging technologies which are increasingly being adopted/likely to be considered in
the near future. However, the security concerns in respect of such technologies need to be considered.
Virtualization
Background:
Over the last 10 years, the trend in the data center has been towards decentralization, also known as horizontal
scaling. Centralized servers were seen as too expensive to purchase and maintain. Due to this expense, applications
were moved from a large shared server to their own physical machine. Decentralization helped with the ongoing
maintenance of each application, since patches and upgrades could be applied without interfering with other running
systems. For the same reason, decentralization improves security since a compromised system is isolated from other
systems on the network.
However, decentralization’s application sandboxes come at the expense of more power consumption, more physical
space requirement, and a greater management effort which increased annual maintenance costs per machine. In
addition to this maintenance overhead, decentralization decreases the efficiency of each machine, leaving the
average server idle 85% of the time. Together, these inefficiencies often eliminate any savings promised by
decentralization.
Virtualization is a modified solution between centralized and decentralized deployments. Instead of purchasing and
maintaining an entire computer for one application, each application can be given its own operating system, and all
those operating systems can reside on a single piece of hardware. This provides the benefits of decentralization, like
security and stability, while making the most of a machine’s resources.
Challenges of Virtualization
Compatibility and support – Often software developers are not ready to guarantee fail-safe
operation of all their programs in virtual machines.
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Licensing – There is a need for thorough examination of licenses of OS, as well as other software
as far as virtualization is concerned. OS manufacturers introduce some limitations on using their
products in virtual machines (especially OEM versions). Such scenarios are often described in
separate license chapters. There may also be some problems with licensing software based on
number of processors, as a virtual machine may emulate different number of processors than in a
host system.
Staff training - This problem is currently one of the most burning ones, as are difficulty in finding
exclusive virtualization experts, who can deploy and maintain a virtual infrastructure. "Heavy"
virtualization platforms may require serious training of staff who will maintain them.
Reliability - As several virtual servers work on a single physical server, failures of hardware
components may affect all the virtual servers running on it. Planning and implementing disaster
recovery strategies to ensure reliability of a virtual infrastructure will be a better solution.
There is a misconception that if we virtualize, let's say, a Windows 2003 Server, that virtualized system should be
secure because it is completely separate from the VM Server operating system and it could be potentially
"protected" by VM Server. This is not true and there are a lot of aspects one needs to know about virtualization
security.
The ultimate attack on a virtual host system would be for a guest system to run malicious code allowing it to gain
elevated privilege and gain access to the underneath VM Server. If the malicious code could create a new "phantom"
virtual machine that could be controlled by the attacker, they would have full access to the virtual host and all virtual
guests. With this form of "hyperjacking", the attacker would be invisible to traditional virtualization management
software and security tools. From there, the attacker would perform a DoS (denial of service) attack by overloading
the virtual guest systems.
The below covers full virtualization environments that are most commonly used in servers. A few major indicative
measures are provided below. Additionally, detailed vendor recommended security measures may be followed.
a. Securing the virtualization platform - Privileged partition operating system hardening – (i) Limit VM resource use:
set limits on the use of resources (e.g., processors, memory, disk space, virtual network interfaces) by each VM so
that no one VM can monopolize resources on a system. (ii) Ensure time synchronization: ensure that host and guests
use synchronized time for investigative and forensic purposes.
b. Unnecessary programmes and services: all unnecessary programs should be uninstalled, and all unnecessary
services should be disabled.
c. Host OS must be patched regularly and in a timely fashion to ensure that the host OS is protecting the system
itself and guest OSs properly. In addition, the same patching requirements apply to the virtualization software.
d. Partitioning and resource allocation space restrictions: volumes or disk partitioning should be used to prevent
inadvertent denials of service from virtual machines (guest operating systems, OSs) filling up available space
allocations, and allow role-based access controls to be placed individually on each virtual machine (guest OS).
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e. Disconnect unused physical devices: individual VMs can be configured to directly or indirectly control peripheral
devices attached to the host system. VMs should be configured by default to disable such connections. Connections
to peripheral devices should be enabled only when necessary.
f. Virtual devices: ensure that virtual devices for guest OSs are associated with the appropriate physical devices on
the host system, such as the mapping between virtual network interface cards (NICs) to the proper physical NICs.
g. File sharing should not be allowed between host and guest OSs: while it might be convenient to enable the
sharing of system files between the host and guest OSs, allowing such introduces an unacceptable risk of a guest OS
possibly maliciously changing a host OS file.
h. Just as with physical servers, virtual systems need to be regularly backed-up for error recovery.
i. Carrying out logging and auditing is critical along with correlating server and network logs across virtual and
physical infrastructures to reveal security vulnerabilities and risk
J. Network access for the host OS should be restricted to management services only, and, if necessary, network
access to storage (iSCSI).
K. A firewall should ideally be placed on the host OS to protect the system, or a firewall should at least be local to a
small number of systems for protection purposes, with access allowed only for management purposes. Additionally,
the firewall should restrict access to only those systems authorized to manage the virtual infrastructure
l. Guest operating system hardening - Minimize number of accounts- guests should have accounts necessary for
running each VM only with passwords that are strong, hard to guess, changed frequently, and only provided to staff
that must have access. Separate credentials should be used for access to each guest OS; credentials should not shared
across guest OSs, and should not be the same as used for access to the host OS
m. The guest OS should be protected by a firewall running on the host OS, or at least running locally (i.e., local to a
small number of systems for protection purposes). Firewall needs to discriminate against inappropriate and/or
malicious traffic using networking communications effective for the environment (e.g., if bridging is used instead of
routing).
n. Consider using introspection capabilities to monitor the security of activity occurring between guest OSs. This is
particularly important for communications that in a non-virtualized environment were carried over networks and
monitored by network security controls (such as network firewalls, security appliances, and network IDS/IPS
sensors).
Cloud Computing
Background: Computing environment owned by a company is shared with client companies through web-based
service over Internet which hosts all the programs to run everything from e-mail to word processing to complex data
analysis programs. This is called cloud computing.
The term cloud computing probably comes from the use of a cloud image to represent the Internet or some large
networked environment. We don’t care much what’s in the cloud or what goes on there except that we get the
services we require. Service may include software, platform or infrastructure.
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At the backend, cloud computing can make use of virtualization and grid computing. In grid computing, networked
computers are able to access and use the resources of every other computer on the network.
Perhaps the biggest concerns about cloud computing are security and privacy. The idea of handing over important
data to another company worries some people. Corporate executives might hesitate to take advantage of a cloud
computing system because they can't keep their company's information under lock and key.
Privacy is another matter. If a client can log in from any location to access data and applications, it's possible the
client's privacy could be compromised. Cloud computing companies will need to find ways to protect client privacy
by implementing reliable authentication techniques.
A cloud computing system must ensure backup of all its clients' information.
Some questions regarding cloud computing are more legal. Does the user or company subscribing to the cloud
computing service own the data? Does the cloud computing system, which provides the actual storage space, own it?
Is it possible for a cloud computing company to deny a client access to that client's data? Several companies, law
firms and universities are debating these and other questions about the nature of cloud computing. Thus, there are
issues relating to data security and privacy, compliance and legal/contractual issues.
Enterprises need to be particular in choosing a provider. Reputation, history and sustainability should all be
factors to consider. Sustainability is of particular importance to ensure that services will be available and
data can be tracked.
The cloud provider often takes responsibility for information handling, which is a critical part of the
business. Failure to perform to agreed-upon service levels can impact not only confidentiality but also
availability, severely affecting business operations.
The dynamic nature of cloud computing may result in confusion as to where information actually resides.
When information retrieval is required, this may create delays.
The geographical location of data storage and processing is not definite unlike traditional data centre.
Trans-border data flows, business continuity requirements, log retention, data retention, audit trails are
among the issues that contribute to compliance challenges in Cloud Computing environment.
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The contractual issues in the cloud services can relate to ownership of intellectual property, unilateral
contract termination, vendor lock-in, fixing liability and obligations of Cloud service providers, exit
clause,etc.
Public clouds allow high-availability systems to be developed at service levels often impossible to create in
private networks, except at extraordinary costs. The downside to this availability is the potential for
commingling of information assets with other cloud customers, including competitors. Compliance to
regulations and laws in different geographic regions can be a challenge for enterprises. At this time there is
little legal precedent regarding liability in the cloud. It is critical to obtain proper legal advice to ensure that
the contract specifies the areas where the cloud provider is responsible and liable for ramifications arising
from potential issues.
Due to the dynamic nature of the cloud, information may not immediately be located in the event of a
disaster. Business continuity and disaster recovery plans must be well documented and tested. The cloud
provider must understand the role it plays in terms of backups, incident response and recovery. Recovery
time objectives should be stated in the contract.
Service providers must demonstrate the existence of effective and robust security controls, assuring customers that
their information is properly secured against unauthorized access, change and destruction. Key questions to decide
are: What employees (of the provider) have access to customer information? Is segregation of duties between
provider employees maintained? How are different customers’ information segregated? What controls are in place
to prevent, detect and react to breaches
IS AUDIT
Introduction:
In the past decade, with the increased technology adoption by Banks, the complexities within the IT environment
have given rise to considerable technology related risks requiring effective management.
This led the Banks to implement an Internal Control framework, based on various standards and its own control
requirements and the current RBI guidelines. As a result, Bank’s management and RBI, need an assurance on the
effectiveness of internal controls implemented and expect the IS Audit to provide an independent and objective view
of the extent to which the risks are managed.
As a consequence, the nature of the Internal Audit department has undergone a major transformation and IS audits
are gaining importance as key processes are automated, or enabled by technology. Hence, there is a need for banks
to re-assess the IS Audit processes and ensure that IS Audit objectives are effectively met.
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Determining adequacy of enterprise-wide compliance efforts, related to IT policies and internal control
procedures
Identifying areas with deficient internal controls, recommend corrective action to address deficiencies and
follow-up, to ensure that the management effectively implements the required actions
IS Audit: The organisation's structure, roles and responsibilities. The chapter identifies the IS Audit
stakeholders, defines their roles, responsibilities and competencies required to adequately support the IS
Audit function
Audit Charter or Policy (to be included in the IS Audit): This point addresses the need to include IS Audit
as a part of the Audit Charter or Policy
Planning an IS Audit: This point addresses planning for an IS Audit, using Risk Based Audit Approach. It
begins with an understanding of IT risk assessment concepts, methodology and defines the IS Audit
Universe, scoping and planning an audit execution
Executing an IS Audit: This describes steps for executing the audit, covering activities such as
understanding the business process and IT environment, refining the scope and identifying internal controls,
testing for control design and control objectives, appropriate audit evidence, documentation of work papers
and conclusions of tests performed
Reporting and Follow-up: Describes the audit summary and memorandum, the requirements for discussing
findings with the management, finalising and submitting reports, carrying out follow-up procedures,
archiving documents and ensuring continuous auditing
Quality Review: This addresses the quality aspects which ensures supervision and exercising due care.
Board of Directors and senior management are responsible for ensuring that an institution’s system of internal
controls operates effectively. One important element of an effective
internal control system is an internal audit function that includes adequate IT coverage. To meet its responsibility of
providing an independent audit function with sufficient resources to ensure adequate IT coverage, the Board, or its
Audit Committee, should enable an internal audit function, capable of evaluating IT controls adequately.
An institution’s board of directors establishes an “Audit Committee” to oversee audit functions and to report on
audit matters periodically to the Board of Directors. Banks should enable adequately skilled Audit Committee
composition to manage the complexity of the IS Audit oversight.
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A designated member of an Audit Committee needs to possess the knowledge of Information Systems, related
controls and audit issues. Designated member should also have competencies to understand the ultimate impact of
deficiencies identified in IT internal control framework by the IS Audit. The committee should devote appropriate
time to IS audit findings identified during IS Audits and members of the Audit Committee need to review critical
issues highlighted and provide appropriate guidance to a bank’s management.
As a part of its overall responsibilities, the committee should also be ultimately responsible for the following IS
Audit areas:
Bank's compliance with legal and regulatory requirements such as (among others) Information Technology
Act-2000, Information Technology (Amendment) Act-2008, Banker's Books (Evidence) Act-1891, The
Banking Regulation Act-1949, Reserve Bank of India Act-1934 and RBI circulars and guidelines
Performance of IS Audit
Internal Audit is a part of the Board’s assurance process with regard to the integrity and effectiveness of systems and
controls. It is an independent group that reports directly to the Audit Committee or the Board of Directors. IS Audit,
being an integral part of Internal Audit, requires an organisation structure with well-defined roles which needs to
function in alignment with the Internal Audit, and provide technical audit support on key focus areas of audit or its
universe, identified by an Internal Audit department. A well-defined IS Audit organisation structure ensures that the
tasks performed fulfill a bank’s overall audit objective, while preserving its independence, objectivity and
competence.
In this regard, banks require a separate IS Audit function within an Internal Audit department led by an IS Audit
Head reporting to the Head of Internal Audit or Chief Audit Executive (CAE). The personnel needs to assume
overall responsibility and accountability of IS Audit functions. Where the bank leverages external resources for
conducting IS Audit on areas where skills are lacking, the responsibility and accountability for such external IS
Audits still remain with the IS Audit Head and CAE.
Because the IS Audit is an integral part of the Internal Auditors, auditors will also be required to be independent,
competent and exercise due professional care.
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related to the audit, the IS Audit should be independent of the auditee, both in attitude and appearance. The Audit
Charter or Policy, or engagement letter (in case of external professional service provider), should address
independence and accountability of the audit function. In case independence is impaired (in fact or appearance),
details of the impairment should be disclosed to the Audit Committee or Board. Independence should be regularly
assessed by the Audit Committee. In case of rotation of audit staff members from IT department to the IS Audit,
care should be taken to ensure that the past role of such individuals do not impact their independence and objectivity
as an IS Auditor.
Additionally, to ensure independence for the IS Auditors, Banks should make sure that:
Auditors have the right to conduct independent data inspection and analysis
Competence: IS Auditors should be professionally competent, having skills, knowledge, training and relevant
experience. They should be appropriately qualified, have professional certifications and maintain professional
competence through professional education and training. As IT encompasses a wide range of technologies, IS
Auditors should possess skills that are commensurate with the technology used by a bank. They should be
competent audit professionals with sufficient and relevant experience. Qualifications such as CISA (offered by
ISACA), DISA (offered by ICAI), or CISSP (offered by ISC2), along with two or more years of IS Audit
experience, are desirable. Similar qualification criteria should also be insisted upon, in case of outsourced
professional service providers.
Due Professional Care: IS Auditors should exercise due professional care, which includes following the professional
auditing standards in conducting the audit. The IS Audit Head should deal with any concerns in applying them
during the audit. IS Auditors should maintain the highest degree of integrity and conduct. They should not adopt
methods that could be seen as unlawful, unethical or unprofessional to obtain or execute an audit.
Banks may decide to outsource execution of segments of audit plan to external professional service providers, as per
the overall audit strategy decided in co-ordination with the CAE and the Audit Committee. This may be due to
inadequate staff available internally within the bank to conduct audits, or insufficient levels of skilled staff. The
work outsourced shall be restricted to execution of audits identified in the plan. Banks need to ensure that the
overall ownership and responsibility of the IS Audit, including the audit planning process, risk assessment and
follow-up of compliance remains within the bank. External assistance may be obtained initially to put in place
necessary processes in this regard.
Both the CAE and Audit Committee should ensure that the external professional service providers appointed should
be competent in the area of work that is outsourced and should have relevant prior experience in that area.
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Audit Charter or Policy is a document, which guides and directs activities of an internal audit function. IS Audit,
being integral part of an Internal Audit department, should also be governed by the same charter or policy. The
charter should be documented to contain a clear description of its mandate, purpose, responsibility, authority and
accountability of relevant members or officials in respect of the IS Audit (namely the IS Auditors, management and
Audit Committee) apart from the operating principles. The IS Auditor will have to determine how to achieve the
implementation of the applicable IS Audit standards, use professional judgment in their application, and be prepared
to justify any departure therefrom.
The Policy should clearly address the aspects of responsibility, authority and accountability
Responsibility:
Mission Statement
Scope or Coverage
Audit Methodology
Objectives
Independence
Relationship with External Audit
Auditee’s Requirements
Critical Success Factors
Key Performance Indicators
Other Measures of Performance
Providing Assurance on Control Environment
Reviewing Controls on Confidentiality, Integrity and Availability of Data or Systems
Authority:
Risk Assessment
Mandate to perform an IS Audit
Allocation of resources
Right to access the relevant information, personnel, locations and systems
Scope or limitations of scope
Functions to be audited
Auditee’s expectations
Organizational structure
Gradation of IS Audit Officials or Staff
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Auditees’ Rights
Independent Quality Reviews
Assessment of Compliance with Standards
Benchmarking Performance and Functions
Assessment of Completion of the Audit Plan
Agreed Actions (e.g. penalties when either party fails to carry out responsibilities)
Co-ordinate with and provide Oversight over other control functions like risk management, security and
compliance
The policy should also cover Audit Rating Methodology and Quality Assurance Reviews. There should also be
annual review of IS Audit Policy or Charter to ensure continued relevance.
Determining relationship between the service offered, and the needs of the auditee
The Audit Charter forms a basis for communication with an auditee. It should include relevant references to
service-level agreements for aspects like the following, as applicable:
Delivery of reports
Costs
Quality of Service
Review of Performance
Needs Assessment
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Reporting Process
Agreement of Findings
The IS Auditor should consider establishing a quality assurance process (e.g., interviews, customer satisfaction
surveys, or assignment performance surveys) to understand his expectations relevant to the function. These needs
should be evaluated against the Charter, to improve the service or change the service delivery or Audit Charter, if
necessary.
Engagement Letter
Engagement letters are often used for individual assignments. They set out the scope and objectives of a relationship
between an external IS audit agency and an organisation. The letter should address the three aspects of responsibility,
authority and accountability.
Responsibility: The aspects addressed includes scope, objectives, independence, risk assessment, specific auditee
requirements and deliverables
Authority: The aspects to be addressed include right of access to information, personnel, locations and systems
relevant to the performance of the assignment, scope or any limitations of scope and documentary evidence or
information of agreement to the terms and conditions of the engagement
Accountability: Areas addressed include designated or intended recipients of reports, auditees’ rights, quality
reviews, agreed completion dates and agreed budgets or fees if available
Planning an IS Audit
(a) Introduction
An effective IS Audit programme addresses IT risk exposures throughout a bank, including areas of IT management
and strategic planning, data centre operations, client or server architecture, local and wide-area networks,
telecommunications, physical and information security, electronic banking, applications used in banking operations,
systems development, and business continuity planning.
A well-planned, properly structured audit programme is essential to evaluate risk management practices, internal
control systems and compliance with policies concerning IT-related risks of every size and complexity. Effective
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programmes are risk -focused, promote sound IT controls, ensure timely resolution of audit deficiencies, and inform
the Audit Committee of the effectiveness of Risk Management practices and internal control systems.
In the past, the Internal Audit concentrated on transaction testing, testing of accuracy and reliability of accounting
records and financial reports, integrity, reliability and timeliness of control reports, and adherence to legal and
regulatory requirements.
However, in the changing scenario, there is an increased need for widening, as well as redirecting, the scope of
Internal Audit to evaluate the adequacy of IT Risk Management procedures and internal control systems. To achieve
these, banks are moving towards risk-based internal audit, which include, in addition to selective transaction testing,
an evaluation of the Risk Management systems and control procedures prevailing in a bank’s operations.
Adopting a suitable IT Risk Assessment Methodology–used to examine auditable units in the IS audit universe
and select areas for review to include in the IS Annual Plan that have the greatest risk exposure
Defining the IS Audit Universe: This covers the IS Audit Universe, which defines the areas to be covered
Scoping for IS Audit: This addresses the scoping requirements and includes:
Defining control objectives and activities
Considering materiality
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Planning Execution of an Audit: This describes the steps of a planning process before IS Audit starts execution
of the plan
Sampling techniques
Resource management
This internal audit approach is aimed at developing a risk-based audit plan keeping in mind th inherent risks of a
business or location and effectiveness of control systems managing inherent risks. In this approach, every bank
business or location, including risk management function, undergoes a risk assessment by the internal audit function.
RBI issued the “Guidance Note on Risk-based Internal Audit” in 2002 to all scheduled commercial banks,
introducing the system of “risk-based internal audit”.
Development of risk profile and drawing up of risk matrix taking inherent business risk and effectiveness of the
control system for monitoring the risk
Preparation of annual audit plan, covering risks and prioritization, based on level and direction of each risk
Setting up of communication channels between audit staff and management, for reporting issues that pose a
threat to a bank’s business
Periodic evaluation of the risk assessment methodology
Identification of appropriate personnel to undertake risk-based audit, and imparting them with relevant training
Addressing transitional and change management issues
The overall plan, arrived at, using the risk assessment approach enables the Internal Audit to identify and examine
key business areas that have highest exposure and enables effective allocation of Audit resources. As stated earlier,
IS Audit, being an integral part of the Internal Audit, there is a need for IS Auditors to focus on the IT risks, related
to the high-risk business areas identified by the Internal Audit for review during a year. This enables the IS Audit to
provide an assurance to the management on the effectiveness of risk management and internal controls underlying
the high-risk business processes, which when read in conjunction with the Internal Audit reports, provides a holistic
view of the effectiveness.
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Includes Board or Audit Committee approval of risk assessments and annual Risk-based
Audit Plans that establish audit schedules, cycles, work programme scope and resource
allocation for each area audited
Further, while identifying IT risks, an IS Auditor must consider the impact of non-alignment with any information
security-related guidelines issued by RBI based on recommendations in Chapter 2 of this report. It should also be
ensured that all systems, domains and processes, irrespective of their risk-levels, are covered within a period of three
years.
The IS Auditor must define, adopt and follow a suitable risk assessment methodology. This should be in consonance
with the focus on risks, to be addressed as a part of the overall Internal Audit Strategy.
A successful risk-based IS Audit Programme can be based on an effective scoring system arrived at by considering
all relevant risk factors.
Major risk factors used in scoring systems include: Adequacy of internal controls, business criticality, regulatory
requirements, amount or value of transactions processed, if a key customer information is held, customer facing
systems, financial loss potential, number
of transactions processed, availability requirements, experience of management and staff, turnover, technical
competence, degree of delegation, technical and process complexity, stability of application, age of system, training
of users, number of interfaces, availability of documentation, extent of dependence on the IT system, confidentiality
requirements, major changes carried out, previous audit observations and senior management oversight.
On the basis of risk matrix of business criticality and system or residual risk, applications or systems can be graded,
based on where they fall on the “risk map” and accordingly their audit frequency can be decided. Banks should
develop written guidelines on the use of risk assessment tools and risk factors and review these with the Audit
Committee or the Board. Risk assessment guidelines will vary for banks depending on size, complexity, scope of
activities, geographic diversity and technology systems used. Auditors should use the guidelines to grade major risk
areas and define range of scores or assessments
(e.g., groupings such as low, medium, or high risk or a numerical sequence such as 1 to 5).
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The written risk assessment guidelines should specify the following elements:
Maximum length for audit cycles based on the risk assessment process: For example, very high to high risk
applications audit cycle can be at a frequency ranging from six months upto 12, medium risk applications
can be 18 months (or below) and up to 36 months for low-risk areas. Audit cycles should not be
open-ended.
Timing of risk assessments for each business area or department: While risk assessment is expected to be on an
annual basis, frequent assessments may be needed if an institution experiences rapid growth or change in
operation or activities.
Notwithstanding the above, IT governance, information security governance -related aspects, critical IT general
controls such as data centre controls and processes and critical business applications/systems having
financial/compliance implications, including regulatory reporting, risk management, customer access (delivery
channels) and MIS systems, needs to be subjected to IS Audit at least once a year (or more frequently, if warranted
by the risk assessment).
IS Auditors should periodically review results of internal control processes and analyse financial or operational data
for any impact on a risk assessment or scoring. Accordingly, auditee units should be required to keep auditors up-to-
date on major changes, such as introduction of a new product, implementation of a new system, application
conversions, significant changes in organisation or staff, regulatory and legal requirements, security incidents.
An Audit Universe is an outcome of the risk assessment process. It defines the audit areas to be covered by the IS
Auditor. It is usually a high-level structure that identifies processes, resources, risks and controls related to IT,
allowing for a risk-based selection of the audit areas. The IT risks faced by banks due to emerging technologies,
prioritisation of IS Audit Universe, selection of types of audits that need to be performed, optimisation of available
resources, and ensuring quality of findings, are challenges faced by IS Audit.
The IS Audit Universe can be built around the four types of IT resources and processes:
such as hardware, operating systems, database management systems, networking, multimedia, and the environment
that houses and supports them and enable processing of applications) and people (internal or outsourced personnel
required to plan, organise, acquire, implement, deliver, support, monitor and evaluate the information systems and
services).
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The challenge is to provide the “right level of granularity” in the definition of the universe, so as to make it effective
and efficient.
Though this is different for every bank, below are some of the considerations for defining IS Audits:
Using overly-broad definitions for IS Audits (e.g. IT general controls) will ensure a scope creep in audit
procedures. The IS Audit Head should make sure that the definition of each IS Audit is an accurate
description of what is being reviewed.
Audit Universe for a year should touch upon all layers in the IT environment. Though each IT environment is
different, layers tend to be the same. If an IS Audit plan does not include some review for each of the layers,
odds are that the plan, as a whole, is deficient.
IS Audits should be structured in such a way as to provide for effective and logical reporting. For example: IS
Audits of pervasive technologies (e.g. networks or processes) are more effective when audited at an
enterprise level.
IS Audits should address appropriate risks. In many cases, IS Audit budgets are determined before the IT risk
assessment is performed. This inevitably leads to one of two situations:
An inadequate number of audit hours are spread over too many audits, which results in consistently poor quality
audits, because there is not enough time.
Audits that should be performed are not performed because the budget does not allow it.
Information gathered by the IS Auditors during IT risk assessment about the IT system processing and operational
environment, threats, vulnerabilities, impact and controls, enables identification of the control objectives and
activities to be tested for design and implementation effectiveness and its operating effectiveness.
Scoping plays a crucial role in overall effectiveness. This is exacerbated by the need for the IS Auditors to integrate
with the process, operational or financial auditors, and the procedures they are performing, particularly in
environments with large integrated CBS applications, where a high number of key process controls are contained
within the systems. (An illustrative list of areas which can form a part of IS Audit scope are given in Annex-B.)
IS Audits should also cover branches, with focus on large and medium branches, in areas such as control of
passwords, user ids, operating system security, anti-malware, maker-checker, segregation of duties, physical security,
review of exception reports or audit trails, BCP policy and or testing.
Reports and circulars issued by RBI for specific areas which also need to be covered in the
IS Audit Scope:
Report of the Committee on Computer Audit (dated: April 2, 2002) Circular on Information
System Audit–A Review of Policies and Practices
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IT control objectives, based on well known frameworks can be included in the scope.
Materiality
When conducting financial statement audits, Internal Auditors measure materiality in monetary terms, since areas
that are audited are also measured and reported in monetary terms. However, since IS Auditors conduct audit on
non-financial items, alternative measures are required to assess materiality. Such assessments are a matter of
professional judgment. They include consideration of its effect on a bank as a whole, of errors, omissions,
irregularities and illegal acts, which may have happened as a result of “internal control weaknesses” in an area being
audited. ISACA IS Auditing Guideline G6: specifies that if the IS Audit focus relates to systems or operations that
process financial transactions, the value of assets controlled by the system(s), or the value of transactions processed
per day/week/month/year, should be considered in assessing materiality. In case, the focus is on systems that do not
process financial transactions, then following measures should be considered:
Cost of system or operation (hardware, software, staff, third-party services, overheads or a combination of
these)
Potential cost of errors (possibly in terms of irrecoverable development costs, cost of publicity required for
warnings, rectification costs, health and safety costs, high wastage, etc.)
IS Auditors should review the following additional areas that are critical and high risk such as:
Testing the controls on new development systems before implementing them in live
environment.
Controls in existing application are not diluted, while migrating data to the new
application
Controls are designed and implemented to meet requirements of a bank’s
policies and procedures, apart from regulatory and legal requirements
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Detailed audit of SDLC process to confirm that security features are incorporated into a
new system, or while modifying an existing system, should be carried out.
In planning and performing an audit to reduce risks to a low level, the auditor should consider the risk of
irregularities and illegal acts. He should maintain professional skepticism during an audit, recognising the possibility
that “material mis-statements due to irregularities and illegal acts” could exist, irrespective of their evaluation of risk
of irregularities and illegal acts.
IS Auditors are also required to consider and assess the risk of fraud, while performing an audit. They should design
appropriate plans, procedures and tests, to detect irregularities, which can have a material effect on either a specific
area under an audit, or the bank as a whole. IS Auditors should consider whether internal control weaknesses could
result in material irregularities, not being prevented or detected. The auditor should design and perform procedures
to test the appropriateness of internal control and risk of override of controls. They should be reasonably conversant
with fraud risk factors and indicators, and assess the risk of irregularities connected with the area under audit.
In pursuance to the understanding gathered during threat identification step of the IT Risk Assessment process, the
auditors should identify control objectives and activities. These are required to be tested to address fraud risk. He
should consider “fraud vulnerability assessments” undertaken by the “Fraud Risk Management Group”, while
identifying fraud risk factors in the IT risk assessment process. He should be aware that certain situations may
increase a bank’s vulnerability to fraud risk (e.g. introduction of a new line of business, new products, new delivery
channels and new applications or systems.)
In preparing an audit scope, auditors should consider fraud risk factors including these:
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Technical sophistication and complexity of the information system(s) supporting the area under audit
Existence of in-house (developed or maintained) application systems, as compared with the packaged software
for core business systems
Frauds involving amounts of Rs 1 crore (and above) should be reported to Special Committee formed to monitor
and follow up large fraud cases
Other fraud cases should be reported to Fraud Review Councils or independent groups formed to manage frauds
The status of fraud cases should be reported to Audit Committee as a part of their review of IS audit
IS Auditors should also extend necessary support to Fraud Review Councils or independent groups or Special
Committees in their investigations
The IS Audit Head is responsible for the annual IS Audit Plan, prepared after considering the risk assessment and
scoping document. The plan covers overall audit strategy, scoped areas, details of control objectives identified in the
scoping stage, sample sizes, frequency or timing of an audit based on risk assessment, nature and extent of audit and
IT resource skills availability, deployment and need for any external expertise. A report on the status of planned
versus actual audits, and any changes to the annual audit plan, needs to be periodically presented to Audit
Committee and Senior Management on a periodic basis.
There are well-known guidance on IS Audit. The Institute of Chartered Accountants of India (ICAI), in March 2009,
published the “Standard on Internal Audit (SIA) 14: Internal Audit in an Information Technology Environment”
covering requirements of the planning stage, which an auditor should follow. IIA has provided guidance on defining
the IS Audit Universe, through the guide issued on “Management of IS Auditing” under the “Global Technology
Audit Guide” series. ITGI has provided guidance on audit planning in its “IT Assurance Guide using COBIT”.
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Nature of Audit: Compliance with legal, regulatory or standards, performance metrics assessment or security
configuration testing
Scoped Systems: Identified IT resources that are in the scope based on the risk assessment process
System Overview: Details of System Environment based on the risk assessment process
Audit Details: Details of risks and controls identified, based on the risk assessment process
Nature and Extent of Tests: Controls testing for effectiveness of design and implementation of controls,
substantive testing for operating effectiveness of controls implemented
Method of Internal Audit: Brief audit approach and methodology
Team and Roles and Responsibilities: Identified skills and names of IS Auditors including their roles and
responsibilities
Co-ordination: Names of the project lead and higher official for escalation of issues
Test of Control Implementation: Tests are performed to confirm that the control that has been appropriately
designed is implemented and is operating at the time of testing. Mitigating or compensating controls are
also reviewed wherever necessary
Assessing Operational Effectiveness of Controls: Wherever the controls designed are found to be in operation,
additional testing is performed for the period of reliance (audit period) to confirm if they are operating
effectively and consistently
On case-to -case basis, the auditor should exercise professional judgment and decide the nature and extent of
procedures that need to be adopted for conclusions. ISA 330 gives guidance on the nature, timing and extent of
procedures.
During an audit, auditors should obtain sufficient, reliable and relevant evidence to achieve their objectives.
Findings and conclusions should be supported by appropriate analysis and interpretation. Auditors should consider
sample selection techniques, which result in a statistically-based representative sample for performing compliance or
substantive testing. Statistical sampling involves the use of techniques from which mathematically-constructed
conclusions regarding the population can be drawn. Non-statistical sampling is not statistically -based. Its results
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should not be extrapolated over the population as a sample is unlikely to be representative of the population.
Examples of compliance testing of controls where sampling could be considered, include user-access rights,
programme change control procedures, procedures documentation, programme documentation, follow-up of
exceptions, review of logs and software licences audits. Examples of substantive tests where sampling could be
considered, include re-performance of a complex calculation (e.g., interest applied), on a sample of accounts, sample
of transactions to vouch to supporting documentation, etc.
Design of A Sample
While designing the size and structure of an audit sample, auditors may consider the following guidelines:
– Sampling Unit: The unit will depend on the sample purpose. For compliance testing of controls, attribute sampling
is typically used, where the unit is an event or transaction (e.g., a control such as an authorisation of transaction).
– Audit objectives: IS Auditors should consider the audit objectives to be achieved and the audit procedures, which
are most likely to achieve those objectives. In addition, when sampling is appropriate, consideration should be given
to the nature of the audit evidence sought, and possible error conditions.
– Population: Population is an entire set of data from which auditors wish to sample, in order to reach a conclusion.
Hence, the population from which a sample is drawn, has to be appropriate and verified as a “complete” for audit
objective.
– Stratification: To assist in efficient and effective design of a sample, stratification may be appropriate.
Stratification is a process of dividing a population into “sub-populations” with
similar characteristics, explicitly defined, so that each sample unit can belong to only one stratum.
Selection of A Sample
IS Auditors should use statistical sampling methods. They may consider using the following:
– Random Sampling: It ensures that all combinations of units in the population have an equal chance of selection
– Systematic Sampling: It involves selecting units using a fixed interval between selections, the first interval having
a random start. Examples include “Monetary Unit Sampling” or “Value Weighted Selection”, where each individual
monetary value (e.g., Rs 100) in the population, is given an equal chance of selection. As an individual monetary
unit cannot ordinarily be examined separately, the item which includes that monetary unit is selected for
examination. This method systematically weighs the selection in favour of the larger amounts, but gives every
monetary value an equal opportunity for selection. Another example includes selecting every ‘nth sampling unit”.
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One challenge that the IS Auditors face is knowing what to audit against as a fully-developed
IT control baselines for applications and technologies that may not have been developed.
Rapid evolution of technology is likely to render baselines useless, after a period of time.
However, this does not detract from the concept of control objectives.
Control objectives, by definition, should remain more or less constant (from environment to environment). Consider
the objective that critical business data and programmes should be backed up and recoverable. Now, each
environment may do that differently; backups could be manual, or automated, or a tool may be used. They could be
incremental only, or there may be complete backups of everything. Backups could be done daily, weekly, or
monthly. Storage of backups could be onsite in a fireproof safe, off-site at another company facility, or outsourced
to a third party. Method used by the organisation to manage backups would certainly impact the audit procedures
and budget, but the control objective will not change. IS Auditor should be able to start with a set of IT control
objectives, and though not specific to particular environments, select an appropriate framework.
Resource Management
A bank’s auditors play a critical role in efficiency and effectiveness of audits. IT encompasses a wide range of
technology and sophistication—the skill set needed to audit a Firewall configuration is vastly different from the skill
set needed to audit application controls. It is critical to match the skills needed to perform a particular IS Audit, with
the appropriate auditor. IS Auditors should also have the appropriate analytical skills to determine and report the
root cause of deficiencies. Bank’s hiring and training practices should ensure that it has qualified IS Auditors where
education and experience should be consistent with job responsibilities. Audit management should also provide an
effective programme of continuing education and development.
The main issue is having staff with the requisite range of IS Audit skills, needed to audit an IS Audit universe,
effectively. If internal expertise is inadequate, the Board should consider using qualified external sources, such as
management consultants, independent auditors, or professionals, to supplement internal resources and support bank's
objectives.
Executing IS Audit
As mentioned earlier, auditors must understand the business and IT environment, risks and internal control
framework. During audit, auditors should obtain evidences, perform test
procedures, appropriately document findings, and conclude a report. This section provides guidance on matters that
IS Auditor should consider while executing the Plan.
ICAI, in March 2009, had published a “Standard on Internal Audit (SIA) 14: Internal Audit in an Information
Technology Environment” covering the requirements of executing a plan that an IS Auditor should follow.
Additionally, IIA has also provided guidance in their “Management of IS Auditing” under their “Global Technology
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Audit Guide” series. The ITGI has also provided guidance on execution of assurance initiative in its “IT Assurance
Guide Using COBIT”.
The first step of the execution stage is refining the understanding of an IT environment, in which a review is being
planned. This implies understanding of a bank’s business processes to confirm the correct scope and control
objectives. The scope of the IS Audit need to be communicated to and agreed upon by stakeholders.
The IS Auditor can structure this step along the following lines:
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Collect and read process description, policies, input or output, issues, meeting minutes, past audit reports, past
audit recommendations, business reports
Prepare a scoping task (process objective, goals and metrics)
While understanding and evaluating internal controls of a bank, areas mentioned under “Scope of IS Audit”
needs to be covered. However, the nature and extent of control risks may vary, depending on nature and
characteristics of a bank’s information system:
Reliance on systems or programmes that are inaccurately processing data, or processing inaccurate data, or both
Unauthorised access to data which may result in destruction of data, or improper changes to data, including
recording of unauthorised or non-existent transactions, or inaccurate recording of transactions
This section lists the different techniques that will be used in detailed audit steps. Testing of controls is
performed covering the main test objectives:
In the testing phase, different types of testing can be applied. Five generic testing methods include enquire and
confirm, inspect, compare actual with expected findings, re-perform or re-calculate and review automated evidence
collection through analyzing date using computer assisted audit techniques and extracting exceptions or key
transactions.
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To assess the adequacy of the design of controls the following steps should be performed:
– Observe, inspect and review control approach. Test the design for completeness, relevance, timeliness and
measurability
– Enquire whether, or confirm that, the responsibilities for control practices and overall accountability have been
assigned
– Test whether accountability and responsibilities are understood and accepted. Verify that the right skills and the
necessary resources are available
– Enquire through interviews with key staff involved whether they understand the control mechanism, its purpose
and the accountability and responsibilities.
Additionally, specifically in internal audit assignments, cost-effectiveness of a control design may also be verified,
with the following audit steps:
– If the control design is effective: Investigate whether it can be made more efficient by optimising steps, looking
for synergies with other mechanisms, and reconsidering the balance of prevention versus detection and correction.
Consider the effort spent in maintaining the control practices
– If the control is operating effectively: Investigate whether it can be made more cost-effective. Consider analysing
performance metrics of activities associated, automation opportunities or skill level
Audit steps performed ensure that control measures established are working as prescribed and conclude on the
appropriateness of the control environment. To test the effectiveness of a control, the auditor needs to look for direct
and indirect evidence of the control’s impact on the process outputs. This implies the direct and indirect
substantiation of measurable contribution of the control to the IT, process and activity goals, thereby recording
direct and indirect evidence of actually achieving the outcomes or various control objectives (based on those
documented in standards like COBIT, as relevant).
The auditor should obtain direct or indirect evidence for selected items or periods to ensure that the control under
review is working effectively by applying a selection of testing techniques as presented in step on test of control
design. The IS Auditor should also perform a limited review of the adequacy of the process deliverables, determine
the level of substantive testing and additional work needed to provide assurance that the IT process is adequate.
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Substantive testing would involve performing analytical procedures and tests of details, to gain assurance on areas
where control weaknesses are observed. Substantive testing is performed to ascertain the actual impact of control
weaknesses.
IS Auditors should obtain sufficient and reliable audit evidence to draw reasonable conclusions on which to base the
audit results.
Sufficient Evidence: Evidence can be considered sufficient if it supports all material questions in the audit objective
and scope. Evidence should be objective and sufficient to enable a qualified independent party to re-perform tests
and obtain the same results. The evidence should be commensurate with the materiality of an item and risks
involved. In instances where IS Auditor believes sufficient audit evidence cannot be obtained, they should disclose
this in a manner consistent with the communication of the audit results.
Appropriate Evidence: Appropriate evidence shall include the following indicative criteria:
Reliable Evidence: IS Auditors should take note of following examples of evidence that is more reliable when it is:
Procedures used to gather evidence can be applied through the use of manual audit procedures, computer-assisted
techniques, or a combination of both. For example: a system, which uses manual control totals to balance data entry
operations might provide audit evidence that the control procedure is in place by way of an appropriately reconciled
and annotated report. IS Auditors should obtain audit evidence by reviewing and testing this report. Detailed
transaction records may only be available in machine-readable format, requiring IS Auditors to obtain evidence
using computer-assisted techniques.
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When information produced by a bank is used by auditors, they should obtain evidence about the completeness and
accuracy by the following means:
Performing tests of the operating effectiveness of controls over the production and maintenance of information,
to be used as audit evidence
Auditors should consider the following controls over production and maintenance of information produced by a
bank:
– Controls over the integrity, accuracy, and completeness of the source data
– Controls over the creation and modification of the applicable report logic and parameters
(f) Documentation
Audit evidence gathered should be documented and organised to support findings and conclusions. IS Audit
documentation is a record of the work performed and evidence supporting findings and conclusions.
Demonstration of the extent to which the auditor has complied with professional standards related to IS auditing
– Supervisory review
Extent of an IS Auditor’s documentation may depend on needs for a particular audit and should include such things
as:
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His understanding of the information processing systems and internal control environment
Audit evidence, source of audit documentation and date of completion
Documentation should include audit information, required by law, government regulations, or by applicable
professional standards. Documentation should be clear, complete and understandable, by a reviewer. IS Audit owns
evidences documented by them, in order to substantiate conclusions on tests performed and specific observations
reported to management and Audit Committee.
IS Auditors should evaluate conclusions drawn as a basis for forming an opinion on the audit. Conclusions should
be substantiated by evidences, collected and documented. The IS Audit Team may be required to provide and
maintain evidences in respect of observations reported by them.
IS Auditors may perform following activities required to conclude on tests performed based on nature and amount
of identified control failures and likelihood of undetected errors:
– Decide whether the scope of IS Audit was sufficient to enable the auditors to draw reasonable conclusions on
which to base audit opinion
− Perform audit procedures designed to obtain sufficient appropriate audit evidence: events upto the date of
audit report may be included and identified in the report
− Prepare an audit summary memorandum documenting findings and conclusions on important issues of IS
Auditing and reporting, including judgments made by an IS Audit team
− Prepare a report appropriate to circumstances, and in conformity with, applicable professional standards and
regulatory and legal requirements
Maintain effective controls over processing and distribution of reports relating to the IS Audit
If audit evidence or information indicate that irregularities could have occurred, IS auditors should recommend the
bank management on matters that require detailed investigation to enable the management to initiate appropriate
investigative actions. The auditors should also consider consulting the Audit Committee and legal counsel about the
advisability and risks of reporting the findings outside the Bank.
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RBI (vide its circular DBS.CO.FrMC.BC.No.7/23.04.001/ 2009-10, dated: September 16, 2009) requires that fraud
cases should be reported to law enforcement agencies and to the RBI. Banks should appropriately include
requirements for reporting to RBI, of such instances, in engagement letters issued to external IS Auditors.
Since IS Audit budgets can be difficult to estimate and manage, CAEs can consider using testing accelerators—tools
or techniques that help support procedures that the IS Auditors will be performing —to increase efficiency and
effectiveness. CAEs can use an accelerator to do the same audit in less time, or do more detailed audit procedures in
the same amount of time. Audit accelerators can be divided into two categories:
– Audit Facilitators: Tools that help support the overall management of an audit (e.g., an electronic workpaper
management tool)
– Testing Accelerators: Tools that automate the performance of audit tests (e.g., data analysis tools).
Audit Facilitators
These include Electronic Workpapers, project management software, flow charting software and open issue tracking
software.
Testing Accelerators
Testing accelerators can automate time-consuming audit tasks, such as reviewing large populations of data. Also,
using a tool to perform audit procedures helps establish consistency. For example, if a tool is used to assess server
security configuration, servers tested with that tool will be assessed along the same baselines. Performing these
procedures manually allows for a degree of interpretation on the part of the IS Auditor. Lastly, the use of tools
enables IS Auditors to test an entire population of data, rather than just a sample of transactions. This provides for a
much higher degree of audit assurance.
Data Analysis Software: These allow an auditor to perform robust statistical analysis of large data sets. They can
also be used to support process or operational audits like KYC reviews. They can support types of testing. One
consideration when using a data analysis tool is that it may be difficult to extract the data from the original source. It
is critical that audit procedures be performed to ensure the completeness and accuracy of the source data.
Security Analysis Tools: These are a broad set of tools that can review a large population of devices or users and
identify security exposures. There are different types of security analysis tools. Generally they can be categorised as
follows:
Network Analysis Tools: These consist of software programmes that can be run on a network and gather
information about it. IS Auditors can use these tools for a variety of audit procedures, including:
Verifying the accuracy of network diagrams by mapping corporate network Identifying key
network devices that may warrant additional audit attention
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Gathering information about what traffic is permitted across a network (which would directly support the IT risk
assessment process).
Hacking Tools: Most technologies have a number of standard vulnerabilities, such as the existence of default
IDs and passwords or default settings when the technology is installed out-of-the-box. Hacking tools
provide for an automated method of checking for these. Such tools can be targeted against Firewalls,
servers, networks and operating systems.
Application Security Analysis Tools: If an organisation is using large integrated business application, key
internal controls are highly security dependent. Application-level security must be well-designed and built
in conjunction with the application’s processes and controls.
The CAE should be aware that most of these come with a set of pre-configured rules, or vendor-touted “best
practices”. Implementation of one will need to be accompanied by a substantive project to create a rule set that is
relevant for that particular organisation. Failure to do so will result in audit reports that contain a number of either
false-positives or false-negatives.
CAEs should be aware of the following considerations, with respect to IS Audit Accelerators:
Tools cost money. The CAE should be sure that the benefits outweigh the costs
That IS Auditors will need to be trained on the new tool. It is not uncommon that a tool sits unused in an
Internal Audit Department
That the tool will need support, patch management and upgrades. Depending on the quality, it may require a
standalone server, as well. For this, any tool selection should be managed with the IT department’s
assistance
Sometimes, IT management or third -party service providers are not allowed tools to access the production
environment directly. They are instead asked to do so from a copy of data from an alternative site, or standby server.
Any use of tools or scripts should be thoroughly discussed with and approved by IT management and be tested fully
before deploying.
IS Auditors can use an appropriate combination of manual techniques and CAATs. IS Audit function needs to
enhance the use of CAATs, particularly for critical functions or processes carrying financial or regulatory or legal
implications. The extent to which CAATs can be used will depend on factors such as efficiency and effectiveness of
CAATs over manual techniques, time constraints, integrity of the Information System and IT environment and level
of audit risk.
CAATs may be used in critical areas ( like detection of revenue leakage, treasury functions, assessing impact of
control weaknesses, monitoring customer transactions under AML requirements and generally in areas where a large
volume of transactions are reported).
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Determine accessibility and availability of a bank’s IS facilities, programs, systems and data
Define procedures to be undertaken (e.g., statistical sampling, recalculation, or confirmation)
Define output requirements
Determine resource requirements: i.e. personnel, CAATs, processing environment, bank’s IS facilities or audit
IS facilities
Obtain access to the bank’s IS facilities, programmes, systems and data, including file definitions
Document CAATs to be used, including objectives, high-level flowcharts, and run instructions
CAATs may be used to perform the following audit procedures among others:
– Compliance tests of general controls: testing set-up or configuration of the operating system, or access procedures
to the programme libraries
– Penetration testing
In instances, where CAATs may be used to extract sensitive programmes, system information or production data, IS
Auditors should safeguard the programme, system information or production data, with an appropriate level of
confidentiality and security. In doing so, IS Auditors should consider the level of confidentiality and security
required by the bank, owning the data and any relevant legislation. IS Auditors should be provided with “view
access” to systems and data. In case audit procedures cannot be performed in the live environment, appropriate test
environment should be made available to IS Auditors. Systems and data under test environment should be
synchronised to the live environment.
IS Auditors should use and document results of appropriate procedures to provide for ongoing integrity, reliability,
usefulness and security of the CAATs. Example: this should include a review of programme maintenance and
change controls over embedded audit software to determine that only authorised changes were made to the CAATs.
In instances where CAATs reside in an environment not under the control of the IS Auditor, an appropriate level of
control should, in effect, be placed to identify changes. When the CAATs are changed, IS Auditors should obtain
assurance of their integrity, reliability, usefulness and security, through appropriate planning, design, testing,
processing and review of documentation, before placing their reliance.
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Traditionally, testing of controls performed by an internal audit team was on a retrospective and cyclical basis, often
many months after business activities have occurred. The testing procedures have often been based on a sampling
approach. They included activities such as reviews of policies, procedures, approvals and reconciliations. Today,
however, it is recognised that this approach only affords internal auditors a narrow scope, and is often too late to be
of “real value” to business performance or regulatory compliance.
Continuous auditing is a method used to perform control and risk assessments automatically on a more frequent
basis using technology which is key to enabling such an approach. Continuous auditing changes the audit paradigm
from periodic reviews of a sample of transactions to ongoing audit testing of 100 percent of transactions. It becomes
an integral part of modern auditing at many levels. It also should be closely tied to management activities such as
performance monitoring, scorecard or dashboard and enterprise risk management.
A continuous audit approach allows internal auditors to fully understand critical control points, rules, and exceptions.
With automated, frequent analyses of data, they are able to perform control and risk assessments in real time or near
real time. They can analyse key business systems for both anomalies at the transaction level and for data-driven
indicators of control deficiencies and emerging risk.
Finally, with continuous auditing, the analysis results are integrated into all aspects of the audit process, from the
development and maintenance of the enterprise audit plan to the conduct and follow-up of specific audits.
Depending on the level of implementation and
sustenance of risk-based IS Audit approach; banks may explore implementation of continuous auditing in critical
areas in a phased manner.
Detailed pre-implementation application control audits and data migration audits in respect of critical systems needs
to be subjected to independent external audit. Banks also need to conduct a post-implementation detailed
application control audit. Furthermore, banks should also include application control audits in a risk based
manner as part of the regular Internal Audit/IS Audit plans with focus on data integrity (among other factors).
General internal auditors with requisite functional knowledge need to be involved along with the IS Auditors in
the exercise to provide the requisite domain expertise.
Some of the considerations in application control audit (based on ISACA guidelines) include:
An IS Auditor should understand the IS environment to determine the size and complexity of the systems, and
the extent of dependence on information systems by the bank
Application-level risks at system and data-level include, system integrity risks relating to the incomplete,
inaccurate, untimely or unauthorized processing of data; system-security risks relating to unauthorized
access to systems or data; data risks relating to its completeness, integrity, confidentiality and accuracy;
system-availability risks relating to the lack of system operational capability; and system maintainability
risks in terms of adequate change control procedures.
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Application controls to address the application-level risks may be in the form of computerized controls built
into the system, manually performed controls, or a combination of both. Risks of manual controls in critical
areas need to be considered. Where the option to place reliance on programmed controls is taken, relevant
general IT controls should be considered, as well as controls specifically relevant to the audit objective.
Objectives should be developed to address criteria such as integrity, availability, compliance, reliability and
confidentiality. Effectiveness and efficiency can also be additional criteria.
As part of documenting the flow of transactions, information gathered should include both computerized and
manual aspects of the system. Focus should be on data input (electronic or manual), processing, storage and
output which are of significance to the audit objective.
Consideration should also be given to documenting application interfaces with other systems. The auditor may
confirm the documentation by performing procedures such as a walk-through test.
Specific controls to mitigate application risks may be identified. Sufficient audit evidence obtained to assure the
auditor that controls are operating as intended through procedures such as inquiry and observation, review
of documentation and testing of the application system controls, where programmed controls are being
tested. Use of computer-assisted audit techniques (CAATs) also needs to be considered.
Nature, timing and extent of testing should be based on the level of risk to the area under review and audit
objectives. In absence of strong general IT controls, an IS auditor may make an assessment of the effect of
this weakness on the reliability of the computerized application controls.
If an IS auditor finds significant weaknesses in the computerized application controls, assurance should be
obtained (depending on the audit objective), if possible, from the manually performed processing controls.
Effectiveness of computerized controls is dependent on general IT controls. Therefore, if general IT controls are
not reviewed, ability to place reliance on controls may be limited. Then the IS Auditor should consider
alternative procedures.
Where weaknesses identified during the application systems review are considered
Purpose of an IS Audit standard is to establish and provide a guidance to auditors who can use the work of experts
on an audit. The following are standards, to test the reliability of the work of an expert:
IS Auditors should, where appropriate, consider using the work of other experts for audit
They should assess, and then be satisfied with professional qualifications, competencies, relevant experience,
resources, independence and quality control processes, prior to engagement
They should assess, review and evaluate work of experts, as a part of an audit, and then conclude the extent of
use and reliance of the work
They should determine and conclude whether the work of experts is adequate and competent to enable them to
conclude on current audit objectives. Such conclusion should be documented
They should apply additional test procedures to gain and include scope limitation, where required evidence is
not obtained through additional test procedures
An expert could be an IS Auditor from external auditing firm, a management consultant, an IT domain expert,
or an expert in the area of audit, who has been appointed by management or by the IS Audit Team
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An expert could be internal or external to the bank. If an expert is engaged by another part of the organisation,
reliance may be place on the banks' report. In some cases, this may reduce the need of an IS Audit coverage,
though IS Auditors do not have supporting documentation and work papers. IS Auditors should be cautious
in providing an opinion on such cases
An IS Auditor should have access to all papers, supporting documents and reports of other experts, where such
access does not create legal issues. Where access creates legal issues, or such papers are not accessible,
auditors should determine and conclude on the extent of use and reliance on expert’s work
The IS Auditor’s views, relevance and comments on adopting the expert’s report should form a part of the IS
Auditor’s Report
A bank may use a third-party service provider (service organisation) to obtain services of packaged software
applications and technology environment, which enables customers to process financial and operational transactions
(ATM management, networking and infrastructure development and maintenance, document imaging and indexing,
software development and maintenance). RBI has issued “Guidelines on Managing Risks and Code of Conduct in
Outsourcing of Financial Services by Banks” (circular no: DBOD.NO.BP.40/21.04.158/ 2006-07 dated November 3,
2006), asking banks to adhere to guidelines before outsourcing activities related to financial services.
Services provided by a third party are relevant to the scope of IS Audit. Especially, when those services and controls
within them, are a part of the bank’s information systems. Though controls at the service organisation are likely to
relate to financial reporting, there may be other controls that may also be relevant to the IS Audit (controls over
safeguarding of assets or document images).
A service organisation’s services are a part of a bank’s information system, including related business processes,
relevant to IS Audit if these services affect any of the following:
initiated, recorded, processed, corrected (when necessary), transferred to a general ledger and reported, in
financial statements
The way events and conditions, other than transactions, significant to bank’s Information System are captured
IS Auditors will have to obtain an understanding of how a bank uses services of a service organisation in the bank’s
IS operations, including:
Nature of services provided by the organisation and significance of those to the bank’s information system,
including the effect thereof on the bank’s internal control
Nature and materiality of transactions, accounts or financial reporting processes, affected by the service
organisation
Degree of interaction between activities of the organisation and bank
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Nature of relationship between the bank and organisation, including relevant contractual terms for activities
undertaken by the organisation
In situations, services provided by the organisation may not appear to be “material” to the bank’s IS operations. But,
the service nature may be. IS Auditors should determine that an understanding of those controls is necessary in the
circumstances. Information on the nature of services, provided by an organisation, may be available from a variety
of sources:
User manual
System overview
Technical manuals
Reports by service organisation, internal auditors, or regulatory authorities, on service organisation controls
Reports by an auditor of the organisation (service auditor), including management letters
IS Auditors may use a service auditor to perform procedures such as tests of controls at service organisation, or
substantive procedures on the bank’s IS operations, served by a service organisation.
This phase involves reporting audit findings to the CAE and Audit Committee. Before reporting the findings, it is
imperative that IS Auditors prepare an audit summary memorandum providing overview of the entire audit
processing from planning to audit findings, discuss the findings with auditee and obtain responses. Additionally,
reviewing the actions taken by management to mitigate the risks observed in audit findings and appropriately
updating the audit summary memorandum is also important. Reporting entails deciding the nature, timing and extent
of follow-up activities and planning future audits.
Professional bodies like ISACA, IIA, ICAI have issued guidance in this regard.
– Archiving documents
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Audit Summary and Memorandum: An IS Auditor should perform audits or reviews of control procedures and
form a conclusion about, and reporting on, the design and
operating effectiveness of the control procedures based on the identified criteria. The conclusion for an
audit is expressed as a positive expression of opinion and provides a high level of assurance. The
conclusion for a review is expressed as a statement of negative assurance and provides only a moderate
level of assurance.
Discuss Findings with Management: Bank’s management is responsible for deciding the appropriate action to
be taken in response to reported observations and recommendations. IS Auditors are responsible for
assessing such management action for appropriateness and the timely resolution of the matters reported as
observations and recommendations.
Senior Management may decide to accept the risk of not correcting the reported condition because of cost or
other considerations. The Board (or the Audit Committee, if one exists) should be informed of Senior
Management’s decision on significant observations and recommendations. When Auditors IS believes that an
organisation has accepted a level of residual risk that is inappropriate for the organisation, they should discuss
the matter with Internal Audit and Senior Management. If the IS Auditors are not in agreement with the
decision, regarding residual risk, IS Auditors and Senior Management should report the matter to the Board, or
Audit Committee, for resolution.
Events sometimes occur, subsequent to the point in time or period of time of the subject matter being tested, but
prior to the date of the IS Auditor’s report, that have a material effect on the subject matter and therefore require
adjustment or disclosure in the presentation of the subject matter or assertion.
IS Auditors should review and assess the conclusions drawn from the evidence obtained as the basis for forming an
opinion on the effectiveness of the control procedures based on the identified criteria.
Major findings identified during an audit should have a definite time line indicated for remedial actions, these
should be followed up intensively and compliance should be confirmed.
An IS Auditor’s report about the effectiveness of control procedures should cover aspects like:
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– A statement that the maintenance of an effective internal control structure, including control procedures
for the area of activity, is the responsibility of management
– A statement that IS Auditors have conducted the engagement to express an opinion on the effectiveness of control
After reporting of findings and recommendations, IS Auditors should request and evaluate relevant information to
conclude whether appropriate action has been taken by management in a timely manner. If management’s proposed
actions to implement reported recommendations have been discussed with, or provided to, the IS Auditor, these
actions should be recorded as a management response in the final report. The nature, timing and extent of the
follow-up activities should take into account the significance of the reported finding and the impact if corrective
action is not taken. The timing of IS Audit follow-up activities in relation to the original reporting should be a matter
of professional judgment dependent on a number of considerations, such as the nature or magnitude of associated
risks and costs to the entity.
– The recording of a time frame within which management should respond to agreed-upon recommendations
– A communications procedure that escalates outstanding and unsatisfactory responses/ actions to the appropriate
levels of management
– A process for providing reasonable assurance of management’s assumption of associated risks, in the event that
remedial action is delayed or not proposed to be implemented
– An automated tracking system or database can assist in the carrying out of follow-up activities.
–Changes in the bank, its environment and banking industry that come to the attention after the completion of the
audit planning memorandum and that caused to change audit plan –Conclusion regarding the appropriateness of the
going concern assumption and the effect, if any, on financial statements
–The result of subsequent reviews and conclusion regarding the effect of subsequent events on financial statements
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–If contradiction or inconsistency with final conclusion regarding a significant matter is observed, there should be
proper documentation of addressing the inconsistency –Conclusion of whether the audit procedures performed and
the audit evidence obtained were appropriate and consistent to support the audit conclusion
Banks are recommended to have an archiving/ retention policy to archive the audit results.
Quality Review
This section is aimed at emphasising quality of work of IS Auditors, while performing duties as an auditor.
Appropriate levels in IS Audit function are recommended to assess audit quality by reviewing documentation,
ensuring appropriate supervision of IS Audit members and assessing whether IS Audit members have taken due care
while performing their duties. This will bring efficiency, control and improve quality of the IS Audit.
IS Auditors may perform the following progressive reviews of the evidences and documentation:
– A detailed review of each working paper prepared by a less-experienced member of the IS Audit team, by a more
experienced member, who did not participate in the preparation of such working paper
– A primary review of the evidences and documentation by the Manager or IS Audit Head. Where the manager
performs a primary review, this does not require that each working paper be reviewed in detail by the manager, as
each working paper has already been reviewed in detail by the person who performed the detailed review.
Supervision
IS Audit staff should be supervised to provide reasonable assurance that audit objectives are accomplished and
applicable professional auditing standards are met.
Due Care
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The standard of “due care” is that level of diligence which a prudent and competent person would exercise under a
given set of circumstances. “Due professional care” applies to an individual who professes to exercise a special skill
such as IS auditing. Due professional care requires the individual to exercise that skill to a level commonly
possessed by auditors with the specialty.
Due professional care applies to the exercise of professional judgment in the conduct of work performed. It implies
that the professional approaches matters requiring professional judgment with proper diligence. Despite the exercise
of due professional care and professional judgment, situations may arise where an incorrect conclusion may be
drawn from a diligent review of the available facts and circumstances. Therefore, the subsequent discovery of
incorrect conclusions does not, in and of itself, indicate inadequate professional judgment or lack of diligence on the
part of the IS Auditor.
Due professional care should extend to every aspect of the audit, including the evaluation of audit risk, the
formulation of audit objectives, the establishment of the audit scope, the selection of audit tests, and the evaluation
of test results.
Significance of identified risks and the potential effect of such risks on the audit
Competence, integrity and conclusions of others upon whose work IS Auditors places reliance
Intended recipients of audit reports have an appropriate expectation that IS Auditors have exercised due professional
care throughout the course of the audit. IS Auditors should not accept an assignment unless adequate skills,
knowledge, and other resources are available to complete the work in a manner expected of a professional. IS
Auditors should conduct the audit with diligence while adhering to professional standards. IS Auditors should
disclose the circumstances of any non -compliance with professional standards in a manner consistent with the
communication of the audit results.
With a view to provide assurance to bank’s management and regulators, banks are required to conduct a quality
assurance, at least once in three years, on the bank's Internal Audit, including IS Audit function, to validate approach
and practices adopted by them in the discharge of its responsibilities as laid out in the Audit Policy.
Assess efficiency and effectiveness of an Internal Audit for current and future business goals
Determine value addition from Internal Audit to the business units
Benchmark, identify and recommend, successful practices of Internal Audit
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Others:
As a matter of prudence, banks should rotate IS Auditors in a specific area on periodic basis,
An information system (IS) audit or information technology(IT) audit is an examination of the controls within an
entity's Information technology infrastructure. These reviews may be performed in conjunction with a financial
statement audit, internal audit, or other form of attestation engagement. It is the process of collecting and evaluating
evidence of an organization's information systems, practices, and operations. Obtained evidence evaluation can
ensure whether the organization's information systems safeguard assets, maintains data integrity, and are operating
effectively and efficiently to achieve the organization's goals or objectives.
An IS audit is not entirely similar to a financial statement audit. An evaluation of internal controls may or may not
take place in an IS audit. Reliance on internal controls is a unique characteristic of a financial audit. An evaluation of
internal controls is necessary in a financial audit, in order to allow the auditor to place reliance on the internal
controls, and therefore, substantially reduce the amount of testing necessary to form an opinion regarding the
financial statements of the company. An IS audit, on the other hand, tends to focus on determining risks that are
relevant to information assets, and in assessing controls in order to reduce or mitigate these risks. An IT audit may
take the form of a "general control review" or an "specific control review". Regarding the protection of information
assets, one purpose of an IS audit is to review and evaluate an organization's information system's availability,
confidentiality, and integrity by answering the following questions:
1. Will the organization's computerized systems be available for the business at all times when required?
(Availability)
2. Will the information in the systems be disclosed only to authorized users? (Confidentiality)
3. Will the information provided by the system always be accurate, reliable, and timely? (Integrity).
The performance of an IS Audit covers several facets of the financial and organizational functions of our Clients.
The diagram to the right gives you an overview of the Information Systems Audit flow: From Financial Statements
to the Control Environment and Information Systems Platforms.
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1. Responsibility: The Audit Charter should define the mission, aims, goals and objectives of the Information
System Audit. At this stage we also define the Key Performance Indicators and an Audit Evaluation process;
2. Authority: The Audit Charter should clearly specify the Authority assigned to the Information Systems
Auditors with relation to the Risk Assessment work that will be carried out, right to access the Client’s information,
the scope and/or limitations to the scope, the Client’s functions to be audited and the auditee expectations; and
3. Accountability: The Audit Charter should clearly define reporting lines, appraisals, assessment of compliance
and agreed actions.
The Audit Charter should be approved and agreed upon by an appropriate level within the Client’s Organization.
See Template for an Audit Charter/ Engagement Letter here.
In addition to the Audit Charter, we should be able to obtain a written representation (“Letter of Representation”)
from the Client’s Management acknowledging:
1. Their responsibility for the design and implementation of the Internal Control Systems affecting the IT Systems
and processes
2. Their willingness to disclose to the Information Systems Auditor their knowledge of irregularities and/or illegal
acts affecting their organisation pertaining to management and employees with significant roles within the internal
audit department.
3. Their willingness to disclose to the IS Auditor the results of any risk assessment that a material misstatement
may have occurred
See a Template for a Letter of Representation here.
PHASE 2 – Risk Assessment and Business Process Analysis
Risk is the possibility of an act or event occurring that would have an adverse effect on the organisation and its
information systems. Risk can also be the potential that a given threat will exploit vulnerabilities of an asset or group
of assets to cause loss of, or damage to, the assets. It is ordinarily measured by a combination of effect and
likelihood of occurrence.
More and more organisations are moving to a risk-based audit approach that can be adapted to develop and improve
the continuous audit process. This approach is used to assess risk and to assist an IS auditor’s decision to do either
compliance testing or substantive testing. In a risk based audit approach, IS auditors are not just relying on risk.
They are also relying on internal and operational controls as well as knowledge of the organisation. This type of risk
assessment decision can help relate the cost/benefit analysis of the control to the known risk, allowing practical
choices.
The process of quantifying risk is called Risk Assessment. Risk Assessment is useful in making decisions such as:
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Inherent Risk: Inherent risk is the susceptibility of an audit area to error which could be material, individually or in
combination with other errors, assuming that there were no related internal controls. In assessing the inherent risk,
the IS auditor should consider both pervasive and detailed IS controls. This does not apply to circumstances where
the IS auditor’s assignment is related to pervasive IS controls only. A pervasive IS Control are general controls
which are designed to manage and monitor the IS environment and which therefore affect all IS-related activities.
Some of the pervasive IS Controls that an auditor may consider include:
Changes in IS management
Pressures on IS management which may predispose them to conceal or misstate information (e.g. large
business-critical project over-runs, and hacker activity)
The nature of the organisation’s business and systems (e.g., the plans for electronic commerce, the complexity
of the systems, and the lack of integrated systems)
Factors affecting the organisation’s industry as a whole (e.g., changes in technology, and IS staff availability)
The level of third party influence on the control of the systems being audited (e.g., because of supply chain
integration, outsourced IS processes, joint business ventures, and direct access by customers)
The susceptibility to loss or misappropriation of the assets controlled by the system (e.g., inventory, and
payroll)
Activities outside the day-to-day routine of IS processing (e.g., the use of operating system utilities to amend
data)
The integrity, experience and skills of the management and staff involved in applying the IS controls
Control Risk: Control risk is the risk that an error which could occur in an audit area, and which could be material,
individually or in combination with other errors, will not be prevented or detected and corrected on a timely basis by
the internal control system. For example, the control risk associated with manual reviews of computer logs can be
high because activities requiring investigation are often easily missed owing to the volume of logged information.
The control risk associated with computerised data validation procedures is ordinarily low because the processes are
consistently applied. The IS auditor should assess the control risk as high unless relevant internal controls are:
Identified
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Evaluated as effective
A risk based approach to an Information Systems Audit will enable us to develop an overall and effective IS Audit
plan which will consider all the potential weaknesses and /or absence of Controls and determine whether this could
lead to a significant deficiency or material weakness.
In order to perform an effective Risk Assessment, we will need to understand the Client’s Business Environment and
Operations. Usually the first phase in carrying out a Risk Based IS Audit is to obtain an understanding of the Audit
Universe. In understanding the Audit Universe we perform the following:
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Assess the uncertainty that exists in relation to the critical control systems
In carrying out the Business Process Analysis we:
2. For each of the Controls Identified, we would rate the impact/effect of the lack of that control (on a rating of 1 -
5, with 5 indicating the highest impact),we will then determine the likelyhood of the threat occuring( also on a rating
of 1 - 5 with 5 representing the highest likelyhood).
<< Outline specific risk assessment methodology here>>
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In the performance of Audit Work the Information Systems Audit Standards require us t o provide supervision,
gather audit evidence and document our audit work. We achieve this objective through:
Establishing an Internal Review Process where the work of one person is reviewed by another, preferably a
more senior person.
We obtain sufficient, reliable and relevant evidence to be obtained through Inspection, Observation, Inquiry,
Confirmation and recomputation of calculations
We document our work by describing audit work done and audit evidence gathered to support the auditors’
findings.
Based on our risk assessment and upon the identification of the risky areas, we move ahead to develop an Audit Plan
and Audit Program. The Audit Plan will detail the nature, objectives, timing and the extent of the resources required
in the audit.
See Template for a Sample Audit Plan.
Based on the compliance testing carried out in the prior phase, we develop an audit program detailing the nature,
timing and extent of the audit procedures. In the Audit Plan various Control Tests and Reviews can be done. They
are sub-divided into:
2. Specific Controls
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The Chat below to the left shows the Control Review Tests that can be performed in the two Control Tests above.
Control Objectives for Information and related Technology (COBIT)
The Control Objectives for Information and related Technology (COBIT) is a set of best practices (framework) for
information (IT) management created by the Information Systems Audit and Control Association (ISACA), and the
IT Governance Institute (ITGI) in 1992.
COBIT provides managers, auditors, and IT users with a set of generally accepted measures, indicators, processes
and best practices to assist them in maximizing the benefits derived through the use of information technology and
developing appropriate IT governance and control in a company.
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COBIT helps meet the multiple needs of management by bridging the gaps between business risks, control needs
and technical issues. It provides a best practices framework for managing IT resources and presents management
control activities in a manageable and logical structure. This framework will help optimise technology information
investments and will provide a suitable benchmark measure.
The Framework comprises a set of 34 high-level Control Objectives, one for each of the IT processes listed in the
framework. These are then grouped into four domains: planning and organisation, acquisition and implementation,
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delivery and support, and monitoring. This structure covers all aspects of information processing and storage and the
technology that supports it. By addressing these 34 high-level control objectives, we will ensure that an adequate
control system is provided for the IT environment. A diagrammatic representation of the framework is shown below.
We shall apply the COBIT framework in planning, executing and reporting the results of the audit. This will enable
us to review the General Controls Associated with IT Governance Issues. Our review shall cover the following
domains;
The planning and acquisition of systems and path in stage growth model of information systems;
The delivery and support of the IS/IT including facilities, operations, utilisation and access;
The level of effectiveness, efficiency, confidentiality, integrity, availability, compliance and reliability
associated with the information held in; and
The level of utilisation of IT resources available within the environment of the IS including people, the
application systems of interface, technology, facilities and data.
The above control objectives will be matched with the business control objectives to apply specific audit procedures
that will provide information on the controls built in the application, indicating areas of improvement that we need
to focus on achieving.
Application Control Review
An Application Control Review will provide management with reasonable assurance that transactions are processed
as intended and the information from the system is accurate, complete and timely. An Application Controls review
will check whether:
Applications Security
1. Data Origination controls are controls established to prepare and authorize data to be entered into an
application. The evaluation will involve a review of source document design and storage, User procedures and
manuals, Special purpose forms, Transaction ID codes, Cross reference indices and Alternate documents where
applicable. It will also involve a review of the authorization procedures and separation of duties in the data capture
process.
2. Input preparation controls are controls relating to Transaction numbering, Batch serial numbering, Processing,
Logs analysis and a review of transmittal and turnaround documents
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3. Transmission controls involve batch proofing and balancing, Processing schedules, Review of Error messages,
corrections monitoring and transaction security
4. Processing controls ensure the integrity of the data as it undergoes the processing phase including Relational
Database Controls, Data Storage and Retrieval
5. Output controls procedures involve procedures relating to report distribution, reconciliation, output error
processing, records retention.
The use of Computer Aided Audit Techniques (CAATS) in the performance of an IS Audit
The Information Systems Audit Standards require us that during the course of an audit, the IS auditor should obtain
sufficient, reliable and relevant evidence to achieve the audit objectives. The audit findings and conclusions are to be
supported by the appropriate analysis and interpretation of this evidence. CAATs are useful in achieving this
objective.
Computer Assisted Audit Techniques (CAATs) are important tools for the IS auditor in performing audits.They
include many types of tools and techniques, such as generalized audit software, utility software, test data,
application software tracing and mapping, and audit expert systems.For us, our CAATs include ACL Data Analysis
Software and the Information Systems Audit Toolkit(ISAT).
CAATs may be used in performing various audit procedures including:
Determine the accessibility and availability of the organisation’s IS facilities, programs/system and data
Define the procedures to be undertaken (e.g., statistical sampling, recalculation, confirmation, etc.)
Determine resource requirements, i.e., personnel, CAATs, processing environment (organisation’s IS facilities
or audit IS facilities)
Obtain access to the clients’s IS facilities, programs/system, and data, including file definitions
Document CAATs to be used, including objectives, high-level flowcharts, and run instructions
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1. Data files, such as detailed transaction files are retained and made available before the onset of the audit.
2. You have obtained sufficient rights to the client’s IS facilities, programs/system, and data
3. Tests have been properly scheduled to minimise the effect on the organisation’s production environment.
4. The effect that changes to the production programs/system have been properly consideered.
See Template here for example tests that you can perform with ACL
PHASE 4: Reporting
Upon the performance of the audit test, the Information Systems Auditor is required to produce and appropriate
report communicating the results of the IS Audit. An IS Audit report should:
2. State the scope, objectives, period of coverage, nature, timing and the extend of the audit work
3. State findings, conclusions, recommendations and any reservations, qualifications and limitations
The Information Systems (IS) audit group assesses the University's critical systems, technology architecture and
processes to assure information assets are protected, reliable, available and compliant with University policies and
procedures, as well as applicable laws and regulations. We emphasize the importance of mitigating security risks
during our audit coverage of the University’s application, operating and networking systems. Through our integrated
and IT governance audits, we evaluate information technology’s impact on the University’s processes and its
abilities to achieve its goals and objectives. Our evaluations are objective and professional, utilizing COBIT
(Control Objectives for Information and related Technology) framework, an international standard for good IT
control practices.
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Control Self-assessments - Control Self-assessments are designed for department that manages and operates a
technology environment. These self-assessment tools can be used to identify potential areas of control weakness in
the management of the technology environment.
Compliance - Compliance audits include University policies and procedures, Payment Card Industry (PCI),
the Health Insurance Portability and Accountability Act (HIPAA), Family Education Rights and Privacy Act
(FERPA) and any other applicable laws and regulations.
Introduction
Basel Committee on Banking Supervision, in its “Consultative Document on Operational Risk”, defines
“operational risk” as the risk of direct, or indirect, loss resulting from inadequate or failed internal processes,
people and systems, or from external events. This definition includes legal risk1.
The Information Technology Act, 2000 (IT Act, 2000) was enacted to handle certain issues relating to
Information Technology. The IT Amendment Act, 2008 has made further modifications to address more issues
such as cyber crimes. It is critical that impact of cyber laws is taken into consideration by banks to obviate any
risk arising there from.
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Board: The Risk Management Committee at the Board-level needs to put in place, the processes to ensure that
legal risks arising from cyber laws are identified and addressed. It also needs to ensure that the concerned
functions are adequately staffed and that the human resources are trained to carry out the relevant tasks in this
regard
Operational Risk Group: This group needs to incorporate legal risks as part of operational risk framework and
take steps to mitigate the risks involved in consultation with its legal functions within the bank.
Legal Department: The legal function within the bank needs to advise the business groups on the legal issues
arising out of use of Information Technology with respect to the legal risk identified and referred to it by the
Operational Risk Group.
The IT Act, 2000 as amended, exposes the banks to both civil2 and criminal3 liability. The civil liability could
consist of exposure to pay damages by way of compensation upto 5 crore under the amended Information
Technology Act before the Adjudicating Officer and beyond five crore in a court of competent jurisdiction.
There could also be exposure to criminal liability to the top management of the banks given the provisions of
Chapter XI of the amended IT Act4 and the exposure to criminal liability could consist of imprisonment for a
term which could extend from three years to life imprisonment as also fine. Further, various computer related
offences are enumerated in the aforesaid provisions.
Critical aspects
Legal risk and operational risk are same. Most risks are sought to be covered by
documentation, particularly where the law is silent. The Basel-II accord
http://www.bis.org/publ/bcbsca07.pdf
Sections 43-45
Sections 65-74
Section 85
covers “legal risk” under “operational risk.” Documentation forms an important part of the
banking and financial sector. For many, documentation is a panacea to the legal risks that may
arise in banking activities. But then, it has also been realized and widely acknowledged that
loopholes do exist in documentation.
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Legal risks need to be incorporated as part of operational risks and the position need to be
periodically communicated to the top management and Board/Risk Management Committee of the
Board.
As the law on data protection and privacy, in the Indian context are in an evolving stage, banks
have to keep in view the specific provisions of IT Act, 2000 (as amended in 2008), various
judicial and quasi judicial pronouncements and related developments in the Cyber laws in India as
part of legal risk mitigation measures. Banks are also required to keep abreast of latest
developments in the IT Act, 2000 and the rules, regulations, notifications and orders issued there
under pertaining to bank transactions and emerging legal standards on digital signature, electronic
signature, data protection, cheque truncation, electronic fund transfer etc. as part of overall
operational risk management process.
Section 69A and the Blocking Rules: Allowing the Government to block content under certain circumstances
Section 69A of the IT (Amendment) Act, 2008, allows the Central Government to block content where it believes
that this content threatens the security of the State; the sovereignty, integrity or defence of India; friendly relations
with foreign States; public order; or to prevent incitement for the commission of a cognisable offence relating to any
of the above. A set of procedures and safeguards to which the Government has to adhere when doing so have been
laid down in what have become known as the Blocking Rules.
Section 79 of the Information Technology (Amendment) Act, 2008 regulates the liability of a wide range of
intermediaries in India. The section came in the limelight mostly because of the infamous Intermediary Guidelines
Rules, or IT Rules, which were made under it. The IT Rules constitute an important and worrying move towards the
privatisation of censorship in India.
The large amounts of ‘obscene’ material that circulate on the Internet have long attracted comment in India. Not
surprsingly, then, in the same way as obscenity is prohobited offline in the country, so it is online as well. The most
important tools to curtail it are sections 67 and 67A of the IT Act, prohibiting obscene and sexually explicit material
respectively.
Section 66A of the Information Technology (Amendment) Act, 2008 prohibits the sending of offensive messages
though a communication device (i.e. through an online medium). The types of information this covers are offensive
messages of a menacing character, or a message that the sender knows to be false but is sent for the purpose of
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‘causing annoyance, inconvenience, danger, obstruction, insult, injury, criminal intimidation, enmity, hatred, or ill
will.’ If you’re booked under Section 66A, you could face up to 3 years of imprisonment along with a fine.
Freedom of expression
To balance freedom of expression with other human rights is, at times, a difficult and delicate task. From hate speech
to intermediary liability, we tease out and shed greater light on the various challenges that make this task particularly
complicated, proposing ways forward that can further strengthen and promote the right to freedom of expression, in
India and beyond, as well.
With the advent of new technology, new security threats have emerged for people, businesses and states. Oftentimes,
responses to such threats, including states’ exercise of their unprecedented power to surveil their populations, have
been criticised for their negative impact on human rights. Can security and human rights no longer be reconciled in
the Internet age?
The Information Technology (Amendment) Act, 2008 an act to amend the IT Act 2000 received the assent of the
President on 5th February 2009. Several legal & security experts are in the process of analyzing the contents and
possible impacts of the amendments. The objective of this note is to try and study the possible implications and
impacts on Indian companies. This note is not intended to be a comprehensive analysis of the amendments, but only
certain key points which could impact Indian Companies
Data Protection
The IT Act 2000 did not have any specific reference to Data Protection, the closet being a provision to treat data
vandalism as an offense. The Government introduced a separate bill called “Personal Data Protection Act 2006”
which his pending in the Parliament and is likely to lapse. The ITA 2008 has introduced two sections which address
Data Protection aspects to an extent, which gives rise to certain key considerations for the sector.
The sections under consideration are:
Section 43A: Compensation for failure to protect data
Section 72A: Punishment for disclosure of information in breach of lawful contract
Section 43A states
Where a body corporate, possessing, dealing or handling any sensitive personal data or information in a computer
resource which it owns, controls or operates, is negligent in implementing and maintaining reasonable security
practices and procedures and thereby causes wrongful loss or wrongful gain to any person, such body corporate shall
be liable to pay damages by way of compensation, to the person so affected.
By way of explanation: "Body corporate means Indian companies"
"Reasonable security practices mean a mutual contract between the customer and service provider OR as per the
specified law. In absence of both then as specified by the Central Government
Hence it would be important for Indian companies to seriously look at SLA’s and agreements which have been
signed with clients to understand the data protection implications. The same goes for understanding the applicable
laws.
A major modification is that this clause doesn’t mention the compensation limit of Rs. 1 Crore which was there as
part of section 43 of the ITA 2000. This implies that there is no upper limit for damages that can be claimed. This
essentially is “unlimited liability” for Indian companies, which could cause serious business implications.
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Section 72A:
Under this section disclosure without consent exposes a person including an "intermediary" to three years
imprisonment of fine upto Rs. Five lacs or both.
This section uses the term “personal information” and not “sensitive personal information” as in section 43A. Hence
it could apply to any information which is obtained in order to deliver services. Hence in some ways broadens the
definition of information.
2. Information Preservation
Across the amendments there are several references to “service providers” or “intermediaries”, which in some form
would apply to all Indian companies.
e.g. Section 67C: Preservation and Retention of information by intermediaries.
Intermediary shall preserve and retain such information as may be specified for such duration and in such manner
and format as the Central Government may prescribe”. Any intermediary who intentionally or knowingly
contravenes the provisions shall be punished with an imprisonment for a term which may extend to 3 years and shall
also be liable to fine.
The notifications on time for preservation etc. are not yet released. However since this is a “cognizable” offense any
police inspector can start investigations against the CEO of a company.
Apart from the two aspects discussed in this note, there are other areas which could also be considerations for E.g.
Sec 69: Power to issue directions for interception or monitoring or decryption of any information through any
computer resource.
Sec 69B: Power to authorize to monitor and collect traffic data or information through any computer resource for
Cyber Security.etc.
In summary, IT Risk management and response needs to be looked at by all companies for various reasons including
customer assurance, compliance, customer regulations, protection of information assets etc. The ITA 2008
amendments provide us with few additional factors for considerations which could have significant impact on
business. Information technology regulations and laws would only get more stringent and defined; hence it’s
imperative for organizations to be aware and prepared
MCQs:
a) 2
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b) 3
c) 4
d) 5
Answer: b
4. In the Handshake protocol action, which is the last step of the Phase 2 : Server Authentication and Key Exchange?
a) server_done
b) server_key_exchange
c) certificate_request
d) crtificate_verify
a) RSA
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b) Fixed Diffie-Hellman
c) Ephemeral Diffie-Hellman
Answer: d
Explanation: We can use either of the following for the CipherSuite key exchange-
i) RSA
v) Fortezza.
6.The certificate message is required for any agreed-on key exchange method except _______________
a) Ephemeral Diffie-Hellman
b) Anonymous Diffie-Hellman
c) Fixed Diffie-Hellman
d) RSA
Answer: b
Explanation: The certificate message is required for any agreed-on key exchange method except Anonymous
Diffie-Hellman.
7. In the Phase 2 of the Handshake Protocol Action, the step server_key_exchange is not needed for which of the
following cipher systems?
a) Fortezza
b) Anonymous Diffie-Hellman
c) Fixed Diffie-Hellman
d) RSA
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a) MD5
b) SHA-2
c) SHA-1
Answer: c
a) MD5
b) SHA-1
Answer: c
Explanation: The MD5 and SHA-1 hash is concatenated together and the then encrypted with the server’s private
key.
10. What is the size of the RSA signature hash after the MD5 and SHA-1 processing?
a) 42 bytes
b) 32 bytes
c) 36 bytes
d) 48 bytes
Answer: c
11. The certificate_request massage includes two parameters, one of which is-
a) certificate_extension
b) certificate_creation
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c) certificate_exchange
d) certificate_type
Answer: d
Explanation: The certificate_request massage includes two parameters : certificate_type and certificate_authorities.
a) 48 bytes
b) 56 bytes
c) 64 bytes
d) 32 bytes
Answer: a
Explanation: The client_key_exchange message uses a pre master key of size 48 bytes.
13. The certificate_verify message involves the process defined by the pseudo-code (in terms of MD5) –
c) Yes. master_key should not be used, the pre_master key should be used
d) No Error
Answer: d
14. In the handshake protocol which is the message type first sent between client and server ?
a) server_hello
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b) client_hello
c) hello_request
d) certificate_request
Answer: b
Explanation: Interaction between the client and server starts via the client_hello message
MCQs 2
a) transport layer
b) network layer
c) application layer
d) session layer
Answer: b
Explanation: None.
a) Entire IP packet
b) IP header
c) IP payload
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Answer: a
Explanation: None.
a) frame filter
b) packet filter
Answer: b
Explanation: None.
Answer: a
Explanation: None.
a) ethernet
b) bluetooth
c) wi-fi
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Answer: c
Explanation: None.
a) denial-of-service attack
b) virus attack
c) worms attack
d) botnet process
Answer: a
Explanation: None.
b) wireless networks
a) browser security
b) email security
c) FTP security
Answer: b
Explanation: None.
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Answer: a
Explanation: None.
10. When a DNS server accepts and uses incorrect information from a host that has no authority giving that
information, then it is called
a) DNS lookup
b) DNS hijacking
c) DNS spoofing
Answer: c
Explanation: None.
MCQs 3
loss of hardware
loss of data
loss of software
loss of printouts*
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internal components
software
all of these*
biometrics data
backup
passwords*
private words
badge
retina
face
palm print*
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MCQs 4
loss of hardware
loss of data
loss of software
loss of printouts
Answer
internal components
software
all of these
Answer
biometrics data
backup
passwords
private words
Answer
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badge
retina
face
palm print
Answer
MCQs 5:
1)The secret key between members needs to be created as a ______ key when two members
contact KDC.
A)public
B)session
C)complimentary
D) none of the above
2)IKE creates SAs for _____.
A)SSL
B)PGP
C)IPSec
D)VP
3) ______ provides either authentication or encryption, or both, for packets at the IP level.
A)AH
B)ESP
C)PGP
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D)SSL
4)One security protocol for the e-mail system is _________.
A)IPSec
B)SSL
C)PGP
D)none of the above
5)IPSec de nes two protocols: _______ and ________.
A) AH; SSL
B) PGP; ESP
C) AH; ESP
D) all of the above
6) A modern cipher is usually a complex _____cipher made of a combination of di erent
simple ciphers.
A)round
B)circle
C)square
D)none of the above
7)______ is the protocol designed to create security associations, both inbound and outbound.
A)SA
B)CA
C)KDC
D)IKE
8)The Internet authorities have reserved addresses for _______.
A)intranets
B)internets
C)extranets
D)none of the above
9) An _________ is a network that allows authorized access from outside users.
A)intranet
B)internet
C)extranet
D)none of the above
10) _________ is a collection of protocols designed by the IETF (Internet Engineering Task Force)
to provide security for a packet at the network level.
A)IPSec
B)SSL
C)PGP
D)none of the above
11) In ______, there is a single path from the fully trusted authority to any certi cate.
A)X509
B)PGP
C)KDC
D)none of the above
12)A ______ provides privacy for LANs that must communicate through the global Internet.
A)VPP
B)VNP
C)VNN
D)VPN
13)IPSec in the ______ mode does not protect the IP header.
A)transport
B)tunnel
C)either (a) or (b)
D)neither (a) nor (b)
14) In _______, the cryptographic algorithms and secrets are sent with the message.
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A)IPSec
B)SSL
C)TLS
D)PGP
15)A _______ layer security protocol provides end-to-end security services for applications.
A)data link
B)network
C)transport
D)none of the above
16) In PGP, to exchange e-mail messages, a user needs a ring of _______ keys.
A)secret
B)public
C)either (a) or (b)
D)both (a) and (b)
17)The ________ method provides a one-time session key for two parties.
A)Di e-Hellman
B)RSA
C)DES
D)AES
18)_______ is a round cipher based on the Rijndael algorithm that uses a 128-bit block of data.
A)AEE
B)AED
C)AER
D)AES
19)AES has _____ di erent con gurations.
A)two
B)three
C)four
D)ve
20)DES uses a key generator to generate sixteen _______ round keys.
A)32-bit
B)48-bit
C)54-bit
D)42-bit
1)b
2)c
3)b
4)c
5)c
6)a
7)d
8)d
9)c
10)a
11)a
12)d
13)a
14)d
15)c
16)b17)a
18)d
19)b
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20)b
2. CYBER LAWS
The real power of today's Internet is that it is available to anyone with a computer and a telephone line. Internet
places at an individual's hands the immense and invaluable power of information and communication.
Internet usage has significantly increased over the past few years. The number of data packets which flowed through
the Internet have increased dramatically. According to International Data Corporation ("IDC"), approximately 163
million individuals or entities will use the Internet by the end of this year as opposed to 16.1 million in 1995. If left
to its own measure, it is highly unlikely that such a trend can reverse itself. Given this present state of the Internet,
the necessity of Cyberlaws becomes all the more important.
When Internet was developed, the founding fathers of Internet hardly had any inclination that Internet could
transform itself into an all pervading revolution which could be misused for criminal activities and which required
regulation. Today, there are many disturbing things happening in cyberspace. Due to the anonymous nature of the
Internet, it is possible to engage into a variety of criminal activities with impunity and people with intelligence, have
been grossly misusing this aspect of the Internet to perpetuate criminal activities in cyberspace. Hence the need for
Cyberlaws.
Internet is believed to be full of anarchy and a system of law and regulation therein seems contradictory. However,
cyberspace is being governed by a system of law and regulation called Cyberlaw. There is no one exhaustive
definition of the term “Cyberlaw”. Simply speaking, Cyberlaw is a generic term which refers to all the legal and
regulatory aspects of Internet and the World Wide Web. Anything concerned with or related to or emanating from
any legal aspects or issues concerning any activity of netizens and others, in Cyberspace comes within the ambit of
Cyberlaw. The growth of Electronic Commerce has propelled the need for vibrant and effective regulatory
mechanisms which would further strengthen the legal infrastructure, so crucial to the success of Electronic
Commerce. All these regulatory mechanisms and legal infrastructures come within the domain of Cyberlaw.
Importance of Cyberlaw
Cyberlaw is important because it touches almost all aspects of transactions and activities on and concerning the
Internet, the World Wide Web and Cyberspace. Initially it may seem that Cyberlaws is a very technical field and
that it does not have any bearing to most activities in Cyberspace. But the actual truth is that nothing could be
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further than the truth. Whether we realize it or not, every action and every reaction in Cyberspace has some legal
and Cyber legal perspectives.
Cyber crimes are anew class of crimes which are increasing day by day due to
extensive use of internet these days. To combat the crimes related to internet The Information Technology Act, 2000
was enacted with prime objective to create an enabling environment for commercial use of I.T. The IT Act
specifies the acts which have been made punishable. The Indian Penal Code, 1860 has also been amended to take
into its purview cyber crimes.
The various offenses related to internet which have been made punishable under the IT Act and the IPC are
enumerated below:
Online sale of Drugs under Narcotic Drugs and Psychotropic Substances Act
Online sale of Arms Arms Act
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GLOSSORY
Access control
Controlling who has access to a computer or online service and the information it stores.
Asset
Something of value to a person, business or organization.
Authentication
The process to verify that someone is who they claim to be when they try to access a computer or online service.
Backing up
To make a copy of data stored on a computer or server to lessen the potential impact of failure or loss.
Broadband
High-speed data transmission system where the communications circuit is shared between multiple users.
Certification
Declaration that specified requirements have been met.
Certification body
An independent organization that provides certification services.
Chargeback
A payment card transaction where the supplier initially receives payment but the transaction is later rejected by the
cardholder or the card issuing company. The supplier’s account is then debited with the disputed amount.
Cloud computing
Delivery of storage or computing services from remote servers online (ie via the internet).
Common text
A structure and series of requirements defined by the International Organization for Standardization, that are being
incorporated in all management system International Standards as they are revised.
Data server
A computer or program that provides other computers with access to shared files over a network.
Declaration of conformity
Confirmation issued by the supplier of a product that specified requirements have been met.
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DMZ
Segment of a network where servers accessed by less trusted users are isolated. The name is derived from the term
“demilitarised zone”.
Encryption
The transformation of data to hide its information content.
Ethernet
Communications architecture for wired local area networks based uponIEEE 802.3 standards.
Firewall
Hardware or software designed to prevent unauthorised access to a computer or network from another computer or
network.
Gap analysis
The comparison of actual performance against expected or required performance.
Hacker
Someone who violates computer security for malicious reasons, kudos or personal gain.
Hard disk
The permanent storage medium within a computer used to store programs and data.
Identification
The process of recognising a particular user of a computer or online service.
Infrastructure-as-a-service (IaaS)
Provision of computing infrastructure (such as server or storage capacity) as a remotely provided service accessed
online (ie via the internet).
Inspection certificate
A declaration issued by an interested party that specified requirements have been met.
Instant messaging
Chat conversations between two or more people via typing on computers or portable devices.
Keyboard logger
A virus or physical device that logs keystrokes to secretly capture private information such as passwords or credit
card details.
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Leased circuit
Communications link between two locations used exclusively by one organization. In modern communications,
dedicated bandwidth on a shared link reserved for that user.
Macro virus
Malware (ie malicious software) that uses the macro capabilities of common applications such as spreadsheets and
word processors to infect data.
Malware
Software intended to infiltrate and damage or disable computers. Shortened form of malicious software.
Management system
A set of processes used by an organisation to meet policies and objectives for that organisation.
Network firewall
Device that controls traffic to and from a network.
Outsourcing
Passing off
Making false representation that goods or services are those of another business.
Password
Personal firewall
Software running on a PC that controls network traffic to and from that computer.
Personal information
Phishing
Method used by criminals to try to obtain financial or other confidential information (including user names and
passwords) from internet users, usually by sending an email that looks as though it has been sent by a legitimate
organization (often a bank). The email usually contains a link to a fake website that looks authentic.
Platform-as-a-service (PaaS)
The provision of remote infrastructure allowing the development and deployment of new software applications over
the internet.
Portable device
A small, easily transportable computing device such as a smartphone, laptop or tablet computer.
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Proxy server
Server that acts as an intermediary between users and others servers, validating user requests.
Restore
Risk
Something that could cause an organization not to meet one of its objectives.
Risk assessment
Router
Screen scraper
A virus or physical device that logs information sent to a visual display to capture private or personal information.
Security control
Process in which network information is aggregated, sorted and correlated to detect suspicious activities.
Security perimeter
Server
Smartphone
A mobile phone built on a mobile computing platform that offers more advanced computing ability and connectivity
than a standard mobile phone.
Software-as-a-service (SaaS)
The delivery of software applications remotely by a provider over the internet; perhaps through a web interface.
Spyware
Malware that passes information about a computer user’s activities to an external party.
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Supply chain
A set of organisations with linked resources and processes involved in the production of a product.
Tablet
An ultra-portable, touch screen computer that shares much of the functionality and operating system of smartphones,
but generally has greater computing power.
Threat
Threat actor
Two-factor authentication
Obtaining evidence of identity by two independent means, such as knowing a password and successfully completing
a smartcard transaction.
Username
The short name, usually meaningful in some way, associated with a particular computer user.
User account
The record of a user kept by a computer to control their access to files and programs.
Link(s) between computers or local area networks across different locations using a wide area network that cannot
access or be accessed by other users of the wide area network.
Virus
Malware that is loaded onto a computer and then run without the user’s knowledge or knowledge of its full effects.
Vulnerability
Communications network linking computers or local area networks across different locations.
Wi-Fi
Worm
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Crime is not because of need, opportunity and rationalization. One wrong option
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Robo backup
Auditing around the computer, auditing through the computer, auditing with computer
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Version control
Escrow arrangement
**BEST OF LUCK **
Disclaimer
While every effort has been made by me to avoid errors or omissions in this publication, any error or
discrepancy noted may be brought to my notice through e-mail to
[email protected] which shall be taken care of in the subsequent editions. It is also suggested that to
clarify any doubt colleagues should cross-check the facts, laws and contents of this publication with original Govt. /
RBI / Manuals/Circulars/Notifications/Memo/Spl Comm. of our bank.
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