1、54/54HYPERLINK /Guidelines on the Risk Management ofCommercial Banks Information TechnologyChapter IGeneral ProvisionsPursuant to the Law of the Peoples Republic of China on Banking Regulation and Supervision, the Law of the Peoples Republic of China on Commercial Banks, the Regulations of the Peopl

2、es Republic of China on Administration of Foreign-funded Banks, and other applicable laws and regulations, the Guidelines on the Risk Management of Commercial Banks Information Technology (hereinafter referred to as the Guidelines) is formulated.The Guidelines apply to all the commercial banks legal

3、ly incorporated within the territory of the Peoples Republic of China.The Guidelines may apply to other banking institutions including policy banks, rural cooperative banks, urban credit cooperatives, rural credit cooperatives, village banks, loan companies, financial asset management companies, tru

4、st and investment companies, finance firms, financial leasing companies, automobile financial companies and money brokers.The term “information technology” stated in the Guidelines shall refer to the system built with computer, communication and software technologies, and employed by commercial bank

5、s to handle business transactions, operation management, and internal communication, collaborative work and controls. The term also include IT governance, IT organization structure and IT policies and procedures.The risk of information technology refers to the operational risk, legal risk and reputa

6、tion risk that are caused by natural factor, human factor, technological loopholes or management deficiencies when using information technology.The objective of information system risk management is to establish an effective mechanism that can identify, measure, monitor, and control the risks of com

7、mercial banks information system, ensure data integrity, availability, confidentiality and consistency, provide the relevant early warning, and thereby enable commercial banks business innovations, uplift their capability in utilizing information technology, improve their core competitiveness and ca

8、pacity for sustainable development.Chapter IIIT governanceThe legal representative of commercial bank should be responsible to ensure compliance of this guideline. The board of directors of commercial banks should have the following responsibilities with respect to the management of information syst

9、ems:Implementing and complying with the national laws, regulations and technical standards pertaining to the management of information systems, as well as the regulatory requirements set by the China Banking Regulatory Commission (hereinafter referred to as the “CBRC”);Periodically reviewing the ali

10、gnment of IT strategy with the overall business strategies and significant policies of the bank, assessing the overall effectiveness and efficiency of the IT organization.Approving IT risk management strategies and policies, understanding the major IT risks involved, setting acceptable levels for th

11、ese risks, and ensuring the implementation of the measures necessary to identify, measure, monitor and control these risks. Setting high ethical and integrity standards, and establishing a culture within the bank that emphasizes and demonstrates to all levels of personnel the importance of IT risk m

12、anagement. Establishing an IT steering committee which consists of representatives from senior management, the IT organization, and major business units, to oversee these responsibilities and report the effectiveness of strategic IT planning, the IT budget and actual expenditure, and the overall IT

13、performance to the board of directors and senior management periodically. Establishing IT governance structure, proper segregation of duty, clear role and responsibility, maintaining check and balances and clear reporting relationship. Strengthening IT professional staff by developing incentive prog

14、ram.Ensuring that there is an effective internal audit of the IT risk management carried out by operationally independent, well-trained and qualified staff. The internal audit report should be submitted directly to the IT audit committee;Submitting an annual report to the CBRC and its local offices

15、on information system risk management that has been reviewed and approved by the board of directors ;Ensuring the appropriating funding necessary for IT risk management works;Ensuring that all employees of the bank fully understand and adhere to the IT risk management policies and procedures approve

16、d by the board of directors and the senior management, and are provided with pertinent training.Ensuring customer information, financial information, product information and core banking system of the legal entity are held independently within the territory, and complying with the regulatory on-site

17、 examination requirements of CBRC and guarding against cross-border risk.Reporting in a timely manner to the CBRC and its local offices any serious incident of information systems or unexpected event, and quickly respond to it in accordance with the contingency plan;Cooperating with the CBRC and its

18、 local offices in the supervisory inspection of the risk management of information systems, and ensure that supervisory opinions are followed up; andPerforming other related IT risk management tasks.The head of the IT organization, commonly known as the Chief Information Officer (CIO) should report

19、directly to the president. Roles and responsibilities of the CIO should include the following:Playing a direct role in key decisions for the business development involving the use of IT in the bank;The CIO should ensure that information systems meet the needs of the bank, and IT strategies, in parti

20、cular information system development strategies, comply with the overall business strategies and IT risk management policies of the bank;The CIO should also be responsible for the establishment of an effective and efficient IT organization to carry out the IT functions of the bank. These include the

21、 IT budget and expenditure, IT risk management, IT policies, standards and procedures, IT internal controls, professional development, IT project initiatives, IT project management, information system maintenance and upgrade, IT operations, IT infrastructure, Information security, disaster recovery

22、plan (DRP), IT outsourcing, and information system retirement;Ensuring the effectiveness of IT risk management throughout the organization including all branches.Organizing professional trainings to improve technical proficiency of staff.Performing other related IT risk management tasks.Commercial b

23、anks should ensure that a clear definition of the IT organization structure and documentation of all job descriptions of important positions are always in place and updated in a timely manner. Staff in each position should meet relevant requirements on professional skills and knowledge. The followin

24、g risk mitigation measures should be incorporated in the management program of related staff:Verification of personal information including confirmation of personal identification issued by government, academic credentials, prior work experience, professional qualifications;Ensuring that IT staff ca

25、n meet the required professional ethics by checking character reference; Signing of agreements with employees about understanding of IT policies and guidelines, non-disclosure of confidential information, authorized use of information systems, and adherence to IT policies and procedures; andEvaluati

26、on of the risk of losing key IT personnel, especially during major IT development stage or in a period of unstable IT operations, and the relevant risk mitigation measures such as staff backup arrangement and staff succession plan.Commercial banks should establish or designate a particular departmen

27、t for IT risk management. It should report directly to the CIO and the Chief Risk Officer (or risk management committee), serve as a member of the IT incident response team, and be responsible for coordinating the establishment of policies regarding IT risk management, especially the areas of inform

28、ation security, BCP, and compliance with the CBRC regulations, advising the business departments and IT department in implementing these policies, providing relevant compliance information, conducting on-going assessment of IT risks, and ensuring the follow-up of remediation advice, monitoring and e

29、scalating management of IT threats and non-compliance events. Commercial banks should establish a special IT audit role and responsibility within internal audit function, which should put in place IT audit policies and procedures, develop and execute IT audit plan.Commercial banks should put in plac

30、e policies and procedures to protect intellectual property rights according to laws regarding intellectual properties, ensure purchase of legitimate software and hardware, prevention of the use of pirated software, and the protection of the proprietary rights of IT products developed by the bank, an

31、d ensure that these are fully understood and complied by all employees. Commercial banks should, in accordance with relevant laws and regulations, disclose the risk profile of their IT normatively and timely.Chapter IIIIT Risk ManagementCommercial banks should formulate an IT strategy that aligns wi

32、th the overall business plan of the bank, IT risk assessment plan and an IT operational plan that can ensure adequate financial resources and human resources to maintain a stable and secure IT environment.Commercial banks should put in place a comprehensive set of IT risk management policies that in

33、clude the following areas:Information security classification policySystem development, testing and maintenance policyIT operation and maintenance policyAccess control policyPhysical security policy Personnel security policyBusiness Continuity Planning and Crisis and Emergency Management procedureCo

34、mmercial banks should maintain an ongoing risk identification and assessment process that allows the bank to pinpoint the areas of concern in its information systems, assess the potential impact of the risks on its business, rank the risks, and prioritize mitigation actions and the necessary resourc

35、es (including outsourcing vendors, product vendors and service vendors).Commercial banks should implement a comprehensive set of risk mitigation measures complying with the IT risk management policies and commensurate with the risk assessment of the bank. These mitigation measures should include:A s

36、et of clearly documented IT risk policies, technical standards, and operational procedures, which should be communicated to the staff frequently and kept up to date in a timely manner;Areas of potential conflicts of interest should be identified, minimized, and subject to careful, independent monito

37、ring. Also it requires that an appropriate control structure is set up to facilitate checks and balances, with control activities defined at every business level, which should include:Top level reviews; Controls over physical and logical access to data and system; Access granted on “need to know” an

38、d “minimum authorization” basis;A system of approvals and authorizations; andA system of verification and reconciliation.Commercial banks should put in place a set of ongoing risk measurement and monitoring mechanisms, which should includePre and post-implementation review of IT projects;Benchmarks

39、for periodic review of system performance;Reports of incidents and complaints about IT services;Reports of internal audit, external audit, and issues identified by CBRC; andArrangement with vendors and business units for periodic review of service level agreements (SLAs).The possible impact of new d

40、evelopment of technology and new threats to software deployed.Timely review of operational risk and management controls in operation area.Assess the risk profile on IT outsourcing projects periodically.Chinese commercial banks operating offshore and the foreign commercial banks in China should compl

41、y with the relevant regulatory requirements on information systems in and outside the Peoples Republic of China.Chapter IVInformation SecurityInformation technology department of commercial banks should oversee the establishment of an information classification and protection scheme. All employees o

42、f the bank should be made aware of the importance of ensuring information confidentiality and provided with the necessary training to fully understand the information protection procedures within their responsibilities.Commercial banks should put in place an information security management function

43、to develop and maintain an ongoing information security management program, promote information security awareness, advise other IT functions on security issues, serve as the leader of IT incident response team, and report the evaluation of the information security of the bank to the IT steering com

44、mittee periodically. The Information security management program should include Information security standards, strategy, an implementation plan, and an ongoing maintenance plan.Information security policy should include the following areas:IT security policy managementOrganization information secur

45、ityAsset managementPersonnel securityPhysical and environment securityCommunication and operation securityAccess control and authenticationAcquirement, development and maintenance of information systemInformation security event managementBusiness continuity managementComplianceCommercial banks shoul

46、d have an effective process to manage user authentication and access control. Access to data and system should be strictly limited to authorized individuals whose identity is clearly established, and their activities in the information systems should be limited to the minimum required for their legi

47、timate business use. Appropriate user authentication mechanism commensurate with the classification of information to be accessed should be selected. Timely review and removal of user identity from the system should be implemented when user transfers to a new job or leave the commercial bank.Commerc

48、ial banks should ensure all physical security zones, such as computer centers or data centers, network closets, areas containing confidential information or critical IT equipment, and respective accountabilities are clearly defined, and appropriate preventive, detective, and recuperative controls ar

49、e put in place.Commercial banks should divide their networks into logical security domains (hereinafter referred to as the “domain”) with different levels of security. The following security factors have to be assessed in order to define and implement effective security controls, such as physical or

50、 logical segregation of network, network filtering, logical access control, traffic encryption, network monitoring, activity log, etc., for each domain and the whole network.criticality of the applications and user groups within the domain;Access points to the domain through various communication ch

51、annels;Network protocols and ports used by the applications and network equipment deployed within the domain;Performance requirement or benchmark;Nature of the domain, i.e. production or testing, internal or external;Connectivity between various domains; andTrustworthiness of the domain.Commercial b

52、anks should secure the operating system and system software of all computer systems byDeveloping baseline security requirement for each operating system and ensuring all systems meet the baseline security requirement;Clearly defining a set of access privileges for different groups of users, namely,

53、end-users, system development staff, computer operators, and system administrators and user administrators;Setting up a system of approval, verification, and monitoring procedures for using the highest privileged system accounts;Requiring technical staff to review available security patches, and rep

54、ort the patch status periodically; andRequiring technical staff to include important items such as unsuccessful logins, access to critical system files, changes made to user accounts, etc. in system logs, monitors the systems for any abnormal event manually or automatically, and report the monitorin

55、g periodically.Commercial banks should ensure the security of all the application systems byClearly defining the roles and responsibilities of end-users and IT staff regarding the application security;Implementing a robust authentication method commensurate with the criticality and sensibility of th

56、e application system;Enforcing segregation of duties and dual control over critical or sensitive functions;Requiring verification of input or reconciliation of output at critical junctures;Requiring the input and output of confidential information are handled in a secure manner to prevent theft, tam

57、pering, intentional leakage, or inadvertent leakage; Ensuring system can handle exceptions in a predefined way and provide meaningful message to users when the system is forced to terminate; andMaintaining audit trail in either paper or electronic format.Requiring user administrator to monitor and r

58、eview unsuccessful logins and changes to users accounts.Commercial banks should have a set of policies and procedures controlling the logging of activities in all production systems to support effective auditing, security forensic analysis, and fraud prevention. Logging can be implemented in differe

59、nt layers of software and on different computer and networking equipment, which falls into two broad categories:Transaction journals. They are generated by application software and database management system, and contain authentication attempts, modification to data, error messages, etc. Transaction

60、 journals should be kept according to the national accounting policy.System logs. They are generated by operating systems, database management system, firewalls, intrusion detection systems, and routers, etc., and contain authentication attempts, system events, network events, error messages, etc. S