2003-06-24
Added · Updated
The Hong Kong Monetary Authority issues this non-statutory guideline to establish general principles for Authorized Institutions to manage technology-related risks. The document mandates the implementation of a fit-for-purpose framework encompassing IT governance, security management, system development, and the oversight of technology service providers. It requires senior management and the Board to ensure adequate IT controls, staff competence, and independent audits to mitigate strategic, operational, and reputational risks.
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Supervisory Policy Manual
This module should be read in conjunction with the Introduction and with the Glossary, which contains an explanation of abbreviations and other terms used in this Manual. If reading on-line, click on blue underlined headings to activate hyperlinks to the relevant module. ————————— Purpose To provide AIs with guidance on general principles which AIs are expected to consider in managing technology-related risks Classification A non-statutory guideline issued by the MA as a guidance note Previous guidelines superseded This is a new guideline. Application To all AIs Structure
Supervisory Policy Manual
3.1 Information classification and protection
3.2 Authentication and access control
3.3 Security administration and monitoring
3.4 System security
3.5 End-user and mobile computing
3.6 Physical and personnel security
4. System development and change management
4.1 Project management
4.2 Project life cycle
4.3 Change management
5. Information processing
5.1 IT operations management and support
5.2 Performance monitoring and capacity planning
5.3 IT facilities and equipment maintenance
5.4 Disaster recovery planning
6. Communications networks
6.1 Network management
6.2 Network security and certification
6.3 Wireless local area network
7. Management of technology service providers
7.1 Management of technology outsourcing
7.2 Management of other technology service providers
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Supervisory Policy Manual processing, storing and communicating information, and covers recording devices, communications networks, computer systems (including hardware and software components and data) and other electronic devices;
As set out in the “Guide to Authorization”, the MA will take account of the quality of an institution’s computer systems, among other factors, in considering whether the institution is conducting its business prudently and with competence.
Supervisory Policy Manual
1.2.3 The HKMA will, in the course of its on-site examinations,
off-site reviews and prudential meetings with AIs, determine as appropriate the adequacy of their technology risk management, having regard to the principles set out in this module.
1.3 General framework of technology risk management
1.3.1 This module is intended to supplement IC-1 “General Risk
Management Controls” by setting out general principles that the MA expects AIs to consider in their technology risk management. Further detailed guidance on managing technology-related risks of electronic banking will be covered separately in another module TM-E-1 “Supervision of E-banking”.
1.3.2 As AIs increase their dependency on technology to deliver
banking services, inappropriate usage of AIs’ technology resources may have significant risk implications. These include for example:
2 For the purpose of this module, the responsibility of Board oversight of technology risk management for overseas incorporated AIs in respect of the Hong Kong operation should rest with the local senior management.
Supervisory Policy Manual technology risk management framework3 . This normally comprises IT governance, a continuous technology risk management process, and implementation of sound practices in respect of IT controls.
1.3.4 The general principle is that AIs are expected to
implement the relevant technology risk management framework that is “fit for purpose”, i.e. commensurate with the risks associated with the types of business and operations, the technologies adopted and the overall risk management systems of individual AIs. An overview of a sound framework of technology risk management is illustrated below.
AIs may find it useful to draw other references from additional resources on technology risk management or IT controls, e.g., ISO/IEC 17799:2000 Information Technology – Code of Practice for Information Security Management (www.iso.ch), Information Systems Audit and Control Association (www.isaca.org), IT Governance Institute (www.itgovernance.org) and Information Security Forum (www.securityforum.org).
Supervisory Policy Manual
Staff competence and training
Board and senior management oversight IT governance To set out the ground rules for key IT controls IT control policies To deliver technology services and implement IT controls IT functions To perform independent assessment of technology risk management process & IT controls Technology audit To perform certain IT services or controls to support local operations Overseas offices (if any) To manage technology risk management process among business units & IT functions Technology risk management function Technology risk management process Measure Measure To measure the impact, likelihood and direction of technologyrelated risks To measure the impact, likelihood and direction of technologyrelated risks Identify Identify To identify emerging or existing technologyrelated risks To identify emerging or existing technologyrelated risks Control Control To control the risks through preventive, compensating and contingency measures To control the risks through preventive, compensating and contingency measures System development & change management Security management Information processing Communications networks Management of technology service providers Sound practices for IT controls Monitor Monitor To regularly monitor any technology-related issues or incidents To regularly monitor any technology-related issues or incidents
Supervisory Policy Manual
2. IT governance
2.1 IT control policies
2.1.1 Achieving a consistent standard of sound practices for IT
controls across an AI requires clear direction and commitment from the Board and senior management. In this connection, senior management, who may be assisted by a delegated sub-committee, is responsible for developing a set of IT control policies which establish the ground rules for IT controls. These policies should be formally approved by the Board or its designated committee and properly implemented among IT functions and business units.
2.1.2 IT control policies normally cover, at a minimum, the five
aspects of IT controls mentioned in sections 3 to 7 of this module. They should be reviewed regularly, and where necessary updated to accommodate changing operating environments and technologies.
2.1.3 Senior management should ensure that processes used
to verify compliance with IT control policies and the process for seeking appropriate approval for dispensation from IT control policies are specified clearly. Senior management should also define the consequences associated with any failure to adhere to this process. In general, the responsibility for ensuring compliance with IT control policies and the process for seeking dispensation rests with individual business units and IT functions, with the assistance of the technology risk management function (see subsection 2.3 below).
2.1.4 Senior management may put in place mechanisms (e.g.
periodic reminders for relevant staff and policy orientation for new recruits) to promote awareness of IT control policies among relevant personnel on a regular basis.
2.2 Oversight and organisation of IT functions
2.2.1 Senior management should establish an effective
organisation of IT functions to deliver technology services and to provide day-to-day technology support to business units. A clear IT organisation structure and related job descriptions of individual IT functions should be documented and approved by senior management.
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2.2.2 Proper segregation of duties4
within and among various
IT functions is crucial for ensuring an effective IT control environment. In the event that an AI finds it difficult to segregate certain IT control responsibilities, it should put in place adequate compensating controls (e.g. peer reviews) to mitigate the associated risk.
2.2.3 It is recommended that AIs establish an IT planning or
steering committee which oversees whether IT resources are used effectively to support business strategies. This committee should normally consist of representatives of senior management, key business units and IT functions. It should meet regularly and report to senior management, and where appropriate to the Board or its designated committee on the status of major technology-related initiatives and any material IT-related issues.
2.2.4 In general, the IT planning or steering committee should
also be responsible for developing an IT strategy to cover longer and short-term technology-related initiatives, taking into account new business initiatives, organisational changes, technological evolution, regulatory requirements, staffing and control related issues. The IT strategy should be formally documented, endorsed by the Board or its designated committee and senior management, as well as reviewed and updated at least on an annual basis.
2.3 Technology risk management function
2.3.1 IC-1 “General Risk Management Controls” specifies that
AIs should have in place effective risk management systems and that new products and services should be subject to careful evaluation (including a detailed risk assessment) as well as a post-launch review. The same risk management controls apply to the technology risk management of AIs.
2.3.2 Senior management should establish clearly which
function in the AI is responsible for implementing and managing the technology risk management process (the TRM function). Depending on the business and
For example, system development personnel should be prohibited from having access to production systems. The security management function should not be assigned other conflicting duties such as system development, computer operations or technical support.
Supervisory Policy Manual operational needs of individual AIs, the TRM function may refer to a dedicated department of an AI, or a group of departments or support units collectively performing the roles defined for this function.
2.3.3 The TRM function has a role to assist business units and
IT functions in performing the technology risk management process which identifies, measures, monitors and controls technology-related risks. In addition, this function helps to ensure awareness of, and compliance with, the AI’s IT control policies, and to provide support for investigation of any technology-related frauds and incidents.
2.3.4 The TRM function should formulate a formal technology
risk acknowledgement and acceptance process for reviewing, evaluating and approving any major incidents of non-compliance with IT control policies. Typical reasons for such non-compliance are technology limitations (e.g. certain proprietary operating systems are only able to provide primitive password controls), business constraints (e.g. undesirable impact on customer services) and the costs outweighing the associated benefits. The process includes:
Supervisory Policy Manual also ensure that audit issues are properly tracked and, in particular, completely recorded, adequately followed up and satisfactorily rectified.
2.4.2 It is recognised that the internal audit function of some AIs
may find it difficult to build up in-house technology audit expertise. In these circumstances, technology audit support may be supplemented by external specialists or internal technology auditors of other offices of the same banking group.
2.5 Staff competence and training
2.5.1 Given the rapid pace of technological development, senior
management needs to ensure that staff of IT functions, the TRM function and internal technology auditors are competent and able to meet required levels of expertise and experience on an ongoing basis. It is also important to ensure that staffing levels are sufficient to handle present and expected work demands, and to cater reasonably for staff turnover.
2.5.2 To ensure that an adequate training programme is in
place for IT personnel, it is essential to establish a process to identify any material skill gaps5 of staff of technology-related functions. AIs may encourage and, where appropriate, facilitate their staff to acquire relevant professional qualifications, such as for those who are responsible for security management, technology risk management and technology audits.
2.6 IT support provided by overseas offices
2.6.1 Some AIs may rely upon or work with their overseas
offices (e.g. parent banks, subsidiaries, head offices or other regional offices of the same banking group) with regard to certain IT controls or support activities. Senior management should ensure that the respective responsibilities of the local and overseas offices in these areas are clearly set out in the relevant documents (e.g. policies, procedures or service agreements).
Skill gaps can be identified by evaluating the skill set of personnel against a pre-defined skill matrix which defines the required knowledge, qualifications and experience for a particular job or position.
Supervisory Policy Manual
3. Security management
3.1 Information classification and protection
3.1.1 For each application system, AIs should preferably assign
an individual as the information owner6 . The information owner normally needs to work with the TRM and IT functions to ensure confidentiality and integrity of information, and to protect the information in accordance with the level of risk present and envisaged.
3.1.2 Information can be classified into different categories
according to the degree of sensitivity (e.g. highly sensitive, sensitive, internal and public) to indicate the extent of protection required. To aid the classification process, AIs should ideally develop guidelines and definitions for each classification and define an appropriate set of procedures for information protection in accordance with the classification scheme. The level of detail of the information classification scheme adopted should be practicable and appropriate to AIs’ circumstances.
3.1.3 Protection of information confidentiality should be in place
regardless of the media (including paper and electronic media) in which the information is maintained. AIs should ensure that all media are adequately protected, and establish secure processes for disposal and destruction of sensitive information in both paper and electronic media.
3.1.4 If cryptographic technology is used to protect the
confidentiality and integrity of AIs’ information, AIs should adopt industry-accepted cryptographic solutions and implement sound key management practices to safeguard the associated cryptographic keys. Sound practices of key management generally include:
An information owner refers to an individual who has been assigned as the business owner of an application system and is accountable for the protection of information processed by, and stored in, this application system.
Supervisory Policy Manual recommended to prevent the disclosure of the cryptographic keys; and
7 Mobile computing includes access to AIs’ computing resources from a remote location outside office premises (e.g. using notebook computers and other mobile devices). 8 Privileged and emergency IDs are system accounts which are created with special authorities and extended access to system resources. These IDs are normally established for system administration (i.e. system administration IDs) or for introducing emergency solutions to system problems of the production environment.
Supervisory Policy Manual
Supervisory Policy Manual of unauthorized activities being performed by the security administration function.
3.3.3 AIs should establish incident response and reporting
procedures to handle information security-related incidents during or outside office hours. The incident response and reporting procedures should include timely reporting to the HKMA of any confirmed IT-related fraud cases or major security breaches.
3.4 System security
3.4.1 Control procedures and baseline security requirements
should be developed to safeguard application programs, operating systems, system software and databases. For example:
Supervisory Policy Manual
9 End-user computing is the transfer of information processing and system development capabilities from centralised data centres onto the user’s desktop.
Supervisory Policy Manual
10 Mobile codes refer to small programs automatically downloaded from web sites by browsers for execution.
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3.6.3 In controlling access by third-party personnel (e.g. service
providers) to secure areas, proper approval of access should be required and their activities should be closely monitored. It is also important that proper screening procedures including verification and background checks, especially for sensitive technology-related jobs, are developed for recruitment of permanent and temporary technology staff, and contractors.
4. System development and change management
4.1 Project management
4.1.1 AIs should establish a general framework for
management of major technology-related projects. This framework should, among other things, specify the project management methodology to be adopted and applied to these projects. The methodology should cover, at a minimum, allocation of responsibilities, activity breakdown, budgeting of time and resources, milestones, check points, key dependencies, quality assurance, risk assessment and approvals.
4.2 Project life cycle
4.2.1 AIs should adopt and implement a full project life cycle
methodology governing the process of developing, implementing and maintaining major computer systems. In general, this should involve phases of project initiation, feasibility study, requirement definition, system design, program development, system and acceptance testing, training, implementation, operation and maintenance.
4.2.2 The project life cycle methodology should define clearly
the roles and responsibilities for the project team and the deliverables from each phase. It also needs to contain a process to ensure that appropriate security requirements are identified when formulating business requirements, built during program development, tested and implemented.
4.2.3 An independent party (e.g. the quality assurance function,
the TRM function or the technology audit team), which is not involved in the project development, should conduct a quality assurance review of major technology-related
Supervisory Policy Manual projects, with the assistance of the legal and compliance functions if necessary. This review is to ensure compliance with the project life cycle methodology, other internal policies, control requirements, regulations and applicable laws.
4.2.4 A formal acceptance process should be established to
ensure that only properly tested and approved systems are promoted to the production environment. System and user acceptance testing should be carried out in an environment separated from the production environment. Production data should not be used in development or acceptance testing unless the data has been desensitised (i.e. not disclosing personal or sensitive information) and prior approval from the information owner has been obtained. Performance testing should also be performed before newly developed systems are promoted to the production environment.
4.2.5 Software package acquisition is an alternative to in-house
systems development and should be subject to broadly similar controls as the project life cycle. As inappropriate handling of software licences may expose AIs to a significant risk of patent infringement, and financial and reputation losses, AIs should establish a formal software package acquisition process. In particular, the process should involve detailed evaluation of the software package (e.g. in terms of software licence, functionality, system performance and security requirements) and its supplier (e.g. its financial condition, reputation and technical capabilities).
4.2.6 AIs should ensure that on-going maintenance and
adequate support of software packages are provided by the software vendors and are specified in formal contracts. For mission-critical software packages, AIs may consider including in the contracts an escrow agreement, which allows them to obtain access to the source code of the software packages under certain circumstances, such as when the software vendors cease their business.
Supervisory Policy Manual
4.3 Change management
4.3.1 Change management is the process of planning,
scheduling, applying, distributing and tracking changes to application systems, system software (e.g. operating systems and utilities), hardware, network systems, and other IT facilities and equipment. An effective change management process helps to ensure the integrity and reliability of the production environment. AIs should develop a formal change management process that includes:
Supervisory Policy Manual
4.3.3 Emergency changes should be logged and backed up
(including the previous and changed program versions and data) so that recovery of previous program versions and data files is possible if necessary. Emergency changes need to be reviewed by independent personnel to ensure that the changes are proper and do not have an undesirable impact on the production environment. They should be subsequently replaced by proper fixes through the normal acceptance testing and change management procedures.
5. Information processing
5.1 IT operations management and support
5.1.1 Management of IT functions should ideally formulate a
service level agreement with business units to cover system availability and performance requirements, capacity for growth, and the level of support provided to users. The responsible IT functions should ensure that adequate procedures are in place for managing the delivery of the agreed technology support and services.
5.1.2 Detailed operational instructions such as computer
operator tasks, and job scheduling and execution (e.g. instructions for processing information, scheduling requirements and system housekeeping activities) should be documented in an IT operations manual. The IT operations manual should also cover the procedures and requirements for on-site and off-site back-up of data and software in both the production and development environments (e.g. the frequency, scope and retention periods of back-up).
5.1.3 AIs should have in place a problem management system
to respond promptly to IT operational incidents, to escalate reported incidents to relevant IT management staff and to record, analyse and keep track of all these incidents until rectification of the incidents. A helpdesk function can be set up to provide front-line support to users on all technology-related problems and to relay the problems to relevant IT functions for investigation and resolution.
Supervisory Policy Manual
5.2 Performance monitoring and capacity planning
5.2.1 AIs should implement a process to ensure that the
performance of application systems is continuously monitored and exceptions are reported in a timely and comprehensive manner. The performance monitoring process should include forecasting capability to enable problems to be identified and corrected before they affect system performance. This process should help the preparation of workload forecasts to identify trends and to provide information needed for the capacity plan, taking into account planned business initiatives.
5.2.2 Capacity planning should be extended to cover back-up
systems and related facilities in addition to the production environment.
5.3 IT facilities and equipment maintenance
5.3.1 To ensure the continued availability of AIs’ technologyrelated services, AIs should maintain and service IT
facilities and equipment (e.g. computer hardware, network devices, electrical power distribution, UPS and airconditioning units) in accordance with the industry practice, and suppliers’ recommended service intervals and specifications. Proper record keeping (including suspected or actual faults, and preventive and corrective maintenance records) is necessary for effective facility and equipment maintenance. A hardware and facility inventory should be kept to control and track all hardware and software purchased and leased. These records can also be used for regular inventory taking.
5.4 Disaster recovery planning
5.4.1 AIs should develop an IT disaster recovery plan to ensure
that critical application systems and technology services can be resumed in accordance with the business recovery requirements. Please refer to TM-G-2 “Business Continuity Planning” on how to develop detailed recovery procedures of application systems and technology services, and ensure adequate insurance coverage of IT resources.
Supervisory Policy Manual
6. Communications networks
6.1 Network management
6.1.1 Communications networks convey information and
provide a channel of access to application systems and systems resources. Given their technical complexity, communications networks can be highly vulnerable to disruption and abuse. Safeguarding communications networks requires robust network design, well-defined network services and sound discipline to be observed in managing networks.
6.1.2 Overall responsibility for network management should be
clearly assigned to individuals who are equipped with the know-how, skills and resources to fulfil their duties. Network standards, design, diagrams and operating procedures should be formally documented, kept up-todate, communicated to all relevant network staff and reviewed periodically.
6.1.3 Communications facilities that are critical to continuity of
network services should be identified. Single points of failure should be minimised by automatic re-routing of communications through alternate routes should critical nodes or links fail (e.g. routing critical links to more than one external exchange or switching centre, and prearranging services with alternate telecommunications service providers).
6.1.4 The network should be monitored on a continuous basis.
This would reduce the likelihood of network traffic overload and detect network intrusions. Monitoring activities include:
Supervisory Policy Manual and detecting potential or actual intrusions. These powerful network tools should be protected from unauthorized usage (e.g. viewing of unencrypted sensitive information). The use of network tools should also be tightly restricted to authorized staff only and be subject to stringent approval and review procedures.
6.2 Network security and certification
6.2.1 To prevent insecure connections to an AI’s network,
procedures concerning the use of networks and network services need to be established and enforced. These should cover:
Supervisory Policy Manual
6.2.4 Network certification11 should be conducted when
requesting local area network (LAN)/wide area network (WAN) additions or changes to AIs’ corporate network. The additions or changes cover dial-in/out ports, switches, terminal servers, gateways/servers, routers, extranets and the public internet. The network certification process includes gathering data about the network environment, analysing any points of vulnerability and associated controls, and documenting whether approval is given or what additional controls are required for approval of connectivity.
6.3 Wireless local area network
6.3.1 If wireless local area networks (WLANs) are to be
deployed, AIs should develop policies and procedures for approval, installation, operation and administration of WLANs. A risk assessment process for evaluating the sensitivity of information to be accessible via a WLAN should be formulated before a WLAN can be implemented. AIs should also develop a standard security configuration for WLAN products and follow the network certification process to ensure that WLANs are implemented in a secure manner so that they do not expose the corporate network to unmanaged risks.
6.3.2 Additional security measures may be needed between the
wireless workstations and the wired network to provide stronger encryption and mutual authentication. WLANs should be segregated from the corporate network (e.g. by firewalls) to prevent any unauthorized access to the corporate network via WLANs.
7. Management of technology service providers
7.1 Management of technology outsourcing
7.1.1 While AIs are expected to take into account the general
guidance specified in SA-2 “Outsourcing” when managing
11 Network certification refers to an assessment process which aims to ensure that additions or changes to network devices and infrastructure do not impose points of vulnerability to other parts of the corporate network. Network certification may form part of the network change management process.
Supervisory Policy Manual technology outsourcing12, they should also have regard to the following controls:
12 In line with SA-2 “Outsourcing”, “technology outsourcing” refers to an arrangement under which another party undertakes to provide to an AI a technology service previously carried out by the AI itself or a new technology service to be launched by the AI. Technology outsourcing can be to a service provider in Hong Kong or overseas and the service provider may be a unit of the same AI (e.g. the head office or an overseas branch), an affiliated company of the AI’s group or an independent third party. 13 These may include the obligations of the technology service provider in ensuring confidentiality of the AI’s information obtained by the provider’s staff or agents and complying with the AI’s relevant IT control policies and procedures.
Supervisory Policy Manual
14 The service provider may become insolvent or have other difficulty to continue provision of the services and support.
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Source: Hong Kong Monetary Authority — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works
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