The Chairman/Managing Director/Chief Executive Officer
All Primary (Urban) Co-operative Banks
Basic Cyber Security Framework
for Primary (Urban) Cooperative Banks (UCBs)
Use of Information Technology by
banks has grown rapidly and is now an important part of the operational
strategy of banks. The number, frequency and impact of cyber
incidents/attacks have increased manifold in the recent past, more so in
the case of financial sector including banks. There is an urgent need to
put in place a robust cyber security/resilience framework at UCBs to ensure
adequate security of their assets on a continuous basis. It has, therefore,
become essential to enhance the security of the UCBs from cyber threats by
improving the current defences in addressing cyber risks.
2. It is observed that the level
of technology adoption is also different across the banks in this sector –
some banks offering state of the art digital products to its customers and
some banks maintaining their books of account in a standalone computer and
using e-mail for communicating with its customers/supervisors/other banks. Hence,
it has been decided to issue basic cyber security guidelines applicable
to all UCBs. However, any UCB, depending on its Self-Risk
Assessment, complexity of its Information Technology (IT)/ Information
Security (IS) systems, nature of digital products offered, etc. is free to
adopt advanced cyber security norms as decided by their Boards.
3. An indicative but not
exhaustive, basic cyber security framework to be implemented by all the
UCBs is given in Annex I.
4. Need for a Board approved
Cyber Security Policy –
All UCBs should immediately put
in place a Cyber Security policy, duly approved by their
Board/Administrator, giving a framework and the strategy containing a
suitable approach to check cyber threats depending on the level of
complexity of business and acceptable levels of risk. On completion of the
process of policy formulation by the Board, a confirmation shall be sent to
Department of Co-operative Bank Supervision, Central Office, C-9, 1st
Floor, BKC, Mumbai – 400051 by email within
three months from the date of circular. It shall be ensured that the cyber
security policy deals with the following broad aspects, keeping in view the
level of technology adoption and digital products offered to the customers:
4.1. Cyber Security Policy to be
distinct from the IT policy/IS Policy of the UCB
The Cyber Security Policy should
be distinct from the IT/IS policy of the UCB so that it highlights the
risks from cyber threats and the measures to address/reduce these risks.
While identifying and assessing the inherent risks, UCBs should keep in
view the technologies1 adopted, delivery channels2, digital products3 being offered, internal4 and external5 threats etc., and rate each of these risks as Low,
Medium, High and Very High.
4.2. IT Architecture/Framework
should be security compliant
The IT architecture/ framework
which includes network, server, database and application, end user systems,
etc., should take care of security measures at all times and this should be
reviewed by the Board or IT Sub-committee of the Board periodically. For
this purpose, UCBs may carry out the following steps:
weak/vulnerable areas in IT systems and processes,
restricted access to networks, databases and applications wherever
permitted, through well-defined processes and approvals including rationale
for permitting such access,
the cost of impact in case of breaches/failures in these areas and,
place suitable Cyber Security System to address them,
and document clearly the responsibility for each of above steps.
A proper record should be kept
of the entire process to enable supervisory assessment.
4.3. Cyber Crisis Management
4.3.1 Since cyber risk is
different from many other risks, the traditional BCP/DR (Business
Continuity Plan/Disaster Recovery) arrangements may not be adequate and
hence needs to be revisited keeping in view the nature of cyber risk. A
Government of India organisation, CERT-In (Computer Emergency Response Team
– India, a Government entity) has been taking important initiatives in
strengthening Cyber Security by providing proactive/reactive services and guidelines,
threat intelligence and assessment of preparedness of various agencies in
different sectors, including the financial sector. CERT-In also has come
out with National Cyber Crisis Management Plan and Cyber Security
Assessment Framework. UCBs may refer to CERT-In/NCIIPC/RBI/IDRBT guidelines
as reference material for their guidance.
4.3.2 UCBs should promptly
detect any cyber intrusions (unauthorised entries) so as to
respond/recover/contain impact of cyber-attacks. Among other things, UCBs,
especially those offering services such as internet banking, mobile
banking, mobile wallet, RTGS/NEFT/IMPS, SWIFT, debit cards, credit cards
etc., should take necessary detective and corrective measures/steps to
address various types of cyber threats6 viz. denial of service (DoS), distributed denial
of services (DDoS), ransomware/crypto ware, destructive malware, business
email frauds including spam, email phishing, spear phishing, whaling,
vishing frauds, drive-by downloads, browser gateway fraud, ghost
administrator exploits, identity frauds, memory update frauds, password
related frauds, etc.
5. Organisational Arrangements
UCBs should review the
organisational arrangements so that the security concerns are brought to
the notice of suitable/concerned officials to enable quick action.
6. Cyber Security awareness
among Top Management/Board/other concerned parties
Managing cyber risk requires the
commitment of the entire organization to create a cyber-safe environment.
This will require a high level of awareness/familiarisation among staff at
all levels including Board and Top Management. UCBs should actively promote
among their customers, vendors, service providers and other concerned
parties an understanding of its cyber security objectives. Security
awareness among customers, employees, vendors, service providers, etc.
about the potential impact of cyber-attacks helps in cyber security
preparedness of UCBs.
7. Ensuring protection of
UCBs, as owners of customer
sensitive data, should take appropriate steps in preserving the
Confidentiality, Integrity and Availability of the same, irrespective of
whether the data is stored/in transit within themselves or with the third
party vendors; the confidentiality of such custodial information should not
be compromised in any situation. To achieve this, suitable systems and
processes across the data/information lifecycle need to be put in place by
UCBs. As regards customers, UCBs may educate and create awareness among
them with regard to cyber security risks.
8. Supervisory reporting
UCBs should report immediately
all unusual cyber security incidents (whether they were successful or mere
attempts) to Department of Co-operative Bank Supervision, Central Office,
C-9, 1st Floor, BKC, Mumbai – 400051 by email,
giving full details of the incident. A ‘NIL’ report shall be submitted on
quarterly basis in case of no cyber security incidents.
9. A copy of this circular shall be placed before the
Board of Directors/Administrator in its ensuing meeting and a policy on
Cyber Security should be framed by the Board/Administrator immediately.
After framing of the policy, UCBs are advised to implement basic Cyber
Security Controls as indicated in Annex I and
report the same to respective Regional Offices of Department of
Co-operative Bank Supervision on or before March 31, 2019.
(General Manager In - Charge)
Annex I: Basic Cyber
Security Controls for Primary (Urban) Cooperative Banks (UCBs)
Annex II: Description
of some of the cyber security threats
Security incident event management (SIEM), Privilege Identity Management
(PIM), database activity monitoring, etc.
channels: ATM, PoS, IMPS, etc.
products: m-Banking, UPI, e-Wallet, etc.
threats: Critical & sensitive data compromise, password theft, internal
source code review, etc.
threat: DDoS, Ransomware, etc.
6 Refer Annex II for a brief description on the various
type of threats