Art. 11 Data and system security | RTS on ICT risk management framework | DORA

Article 11 requires financial entities to develop, document, and implement a data and system security procedure as part of their broader ICT security framework under Article 9(2) of DORA.

The article is notably detailed, covering a wide range of practical security requirements — from endpoint device management and malicious code protection, to secure data deletion and the governance of ICT third-party service providers.

The procedure must be shaped by the data classification framework established under Article 8(1) of DORA, meaning the security measures applied must reflect the sensitivity and criticality of the assets involved.

Important points:

Develop and implement a comprehensive data and system security procedure covering ICT assets, endpoint devices, software controls, data handling, and third-party provider arrangements.
Endpoint device security carries specific obligations, including remote management and wiping capabilities, tamper-proof security mechanisms, and restrictions on removable storage based on the financial entity's risk tolerance.
Where ICT assets or services are operated by a third-party provider, financial entities retain full responsibility and must clearly allocate security roles, maintain internal competences, and apply technical and organisational measures to manage associated risks.

1. As part of the ICT security policies, procedures, protocols, and tools referred to in Article 9(2) of Regulation (EU) 2022/2554, financial entities shall develop, document, and implement a data and system security procedure.
1. The data and system security procedure referred to in paragraph 1 shall contain all of the following elements related to data and ICT system security, in accordance with the classification established in accordance with Article 8(1) of Regulation (EU) 2022/2554:
  1. the access restrictions referred to in Article 21 of this Regulation, supporting the protection requirements for each level of classification;
  2. the identification of a secure configuration baseline for ICT assets that minimise exposure of those ICT assets to cyber threats and measures to verify regularly that those baselines are effectively deployed;
  3. the identification of security measures to ensure that only authorised software is installed in ICT systems and endpoint devices;
  4. the identification of security measures against malicious codes;
  5. the identification of security measures to ensure that only authorised data storage media, systems, and endpoint devices are used to transfer and store data of the financial entity;
  6. the following requirements to secure the use of portable endpoint devices and private non-portable endpoint devices:
    the requirement to use a management solution to remotely manage the endpoint devices and remotely wipe the financial entity’s data;
    the requirement to use security mechanisms that cannot be modified, removed or bypassed by staff members or ICT third-party service providers in an unauthorised manner;
    the requirement to use removable data storage devices only where the residual ICT risk remains within the financial entity’s risk tolerance level referred to in Article 3, first subparagraph, point (a);
  7. the process to securely delete data, present on premises of the financial entity or stored externally, that the financial entity no longer needs to collect or to store;
  8. the process to securely dispose or decommission of data storage devices present on premises of the financial entity or stored externally containing confidential information;
  9. the identification and implementation of security measures to prevent data loss and leakage for systems and endpoint devices;
  10. the implementation of security measures to ensure that teleworking and the use of private endpoint devices does not adversely impact the ICT security of the financial entity;
  11. for ICT assets or services operated by an ICT third-party service provider, the identification and implementation of requirements to maintain digital operational resilience, in accordance with the results of the data classification and ICT risk assessment.
2. For the purposes of point (b), the secure configuration baseline referred to in that point shall take into account leading practices and appropriate techniques laid down in the standards defined in Article 2, point (1), of Regulation (EU) No 1025/2012.
3. For the purposes of point (k), financial entities shall consider the following:
  1. the implementation of vendor recommended settings on the elements operated by the financial entity;
  2. a clear allocation of information security roles and responsibilities between the financial entity and the ICT third-party service provider, in accordance with the principle of full responsibility of the financial entity over its ICT third-party service provider referred to in Article 28(1), point (a), of Regulation (EU) 2022/2554, and for financial entities referred to in Article 28(2) of that Regulation, and in accordance with the financial entity’s policy on the use of ICT services supporting critical or important functions;
  3. the need to ensure and maintain adequate competences within the financial entity in the management and security of the service used;
  4. technical and organisational measures to minimise the risks related to the infrastructure used by the ICT third-party service provider for its ICT services, considering leading practices, and standards as defined in Article 2, point (1), of Regulation (EU) No 1025/2012.