G u i d e l i n e s o n t h e R i s k M a n a g e m e n t o f
Commercial Banks’ Information Technology
Chapter I General Provisions
Article 1. Pursuant to the Law of the People’s Republic of China on Banking Regulation and Supervision, the Law of the People's Republic of China on Commercial Banks, the Regulations of the People’s 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.
Article 2. The Guidelines apply to all the commercial banks legally incorporated within the territory of the People’s 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, trust and investment companies, finance firms, financial leasing companies, automobile financial companies and money brokers. Article 3. The term “information technology” stated in the Guidelines shall refer to the system built with computer,
communication and software technologies, and employed by commercial banks 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.
Article 4. The risk of information technology refers to the operational risk, legal risk and reputation risk that are caused by natural factor, human factor, technological loopholes or management deficiencies when using information technology.
Article 5. The objective of information system risk management is to establish an effective mechanism that can identify, measure, monitor, and control the risks of commercial banks’ information system, ensure data integrity, availability, confidentiality and consistency, provide the relevant early warning, and thereby enable commercial bank s’ business innovations, uplift their capability in utilizing information technology, improve their core competitiveness and capacity for sustainable development.
Chapter II IT governance
Article 6. The legal representative of commercial bank should be responsible to ensure compliance of this guideline.
Article 7. The board of directors of commercial banks should have the following responsibilities with respect to the management of information systems:
(1)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”);
(2)Periodically reviewing the alignment of IT strategy with the overall business strategies and significant policies of the bank, assessing the overall effectiveness and efficiency of the IT organization.
(3)Approving IT risk management strategies and policies, understanding the major IT risks involved, setting acceptable levels for these risks, and ensuring the implementation of the measures necessary to identify, measure, monitor and control these risks.
(4)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 management.
(5)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 performance to the board of directors and senior management periodically.
(6)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 program.
(7)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; (8)Submitting an annual report to the CBRC and its local offices on information system risk management that has been reviewed and approved by the board of directors ;
(9)Ensuring the appropriating funding necessary for IT risk management works;
(10)Ensuring that all employees of the bank fully understand and adhere to the IT risk management policies and procedures approved by the board of directors and the senior management,
and are provided with pertinent training.
(11)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 examination requirements of CBRC and guarding against cross-border risk.
(12)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;
(13)Cooperating with the CBRC and its local offices in the supervisory inspection of the risk management of information systems, and ensure that supervisory opinions are followed up; and
(14)Performing other related IT risk management tasks. Article 8. The head of the IT organization, commonly known as the Chief Information Officer (CIO) should report directly to the president. Roles and responsibilities of the CIO should include the following:
(1)Playing a direct role in key decisions for the business development involving the use of IT in the bank;
(2)The CIO should ensure that information systems meet the
needs of the bank, and IT strategies, in particular information system development strategies, comply with the overall business strategies and IT risk management policies of the bank;
(3)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 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 plan (DRP), IT outsourcing, and information system retirement;
(4)Ensuring the effectiveness of IT risk management throughout the organization including all branches.
(5)Organizing professional trainings to improve technical proficiency of staff.
(6)Performing other related IT risk management tasks. Article 9. Commercial banks 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 following risk mitigation measures should be incorporated in the management program of related staff: (1)Verification of personal information including
confirmation of personal identification issued by government, academic credentials, prior work experience, professional qualifications;
(2)Ensuring that IT staff can meet the required professional
ethics by checking character reference;
(3)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; and (4)Evaluation 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.
Article 10. Commercial banks should establish or designate a particular department 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 information 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 escalating management of IT threats and non-compliance events.
Article 11. 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.
Article 12. Commercial banks should put in place 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, and ensure that these are fully understood and complied by all employees. Article 13. Commercial banks should, in accordance with relevant laws and regulations, disclose the risk profile of
their IT normatively and timely.
Chapter III IT Risk Management
Article 14. Commercial banks should formulate an IT strategy that aligns with 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.
Article 15. Commercial banks should put in place a comprehensive set of IT risk management policies that include the following areas:
(1)Information security classification policy
(2)System development, testing and maintenance policy
(3)IT operation and maintenance policy
(4)Access control policy
(5)Physical security policy
(6)Personnel security policy
(7)Business Continuity Planning and Crisis and
Emergency Management procedure
Article 16. Commercial 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 resources (including outsourcing vendors, product vendors and service vendors).
Article 17. 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:
(1)A set 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;
(2)Areas of potential conflicts of interest should be
identified, minimized, and subject to careful,
independent monitoring. 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” and “minimum
authorization” basis;
-A system of approvals and authorizations; and
-A system of verification and reconciliation. Article 18. Commercial banks should put in place a set of ongoing risk measurement and monitoring mechanisms, which should include
(1)Pre and post-implementation review of IT projects;
(2)Benchmarks for periodic review of system
performance;
(3)Reports of incidents and complaints about IT
services;
(4)Reports of internal audit, external audit, and issues
identified by CBRC; and
(5)Arrangement with vendors and business units for
periodic review of service level agreements (SLAs).
(6)The possible impact of new development of technology
and new threats to software deployed.
(7)Timely review of operational risk and management
controls in operation area.
(8)Assess the risk profile on IT outsourcing projects
periodically.
Article 19. Chinese commercial banks operating offshore
and the foreign commercial banks in China should comply with the relevant regulatory requirements on information systems in and outside the People’s Republic of China.
Chapter IV Information Security
Article 20. Information technology department of commercial banks should oversee the establishment of an information classification and protection scheme. All employees of 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.
Article 21. Commercial banks should put in place an information security management function 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 committee 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:
(1)IT security policy management
(2)Organization information security
(3)Asset management
(4)Personnel security
(5)Physical and environment security
(6)Communication and operation security
(7)Access control and authentication
(8)Acquirement, development and maintenance of
information system
(9)Information security event management
(10)Business continuity management
(11)Compliance
Article 22. Commercial banks should 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 legitimate 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.
Article 23. Commercial 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 are put in place.
Article 24. 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 logical segregation of network, network filtering, logical access control, traffic encryption, network monitoring, activity log, etc., for each domain and the whole network.
(1)criticality of the applications and user groups
within the domain;
(2)Access points to the domain through various
communication channels;
(3)Network protocols and ports used by the applications
and network equipment deployed within the domain;
(4)Performance requirement or benchmark;
(5)Nature of the domain, . production or testing,
internal or external;
(6)Connectivity between various domains; and
(7)Trustworthiness of the domain.
Article 25. Commercial banks should secure the operating system and system software of all computer systems by
(1)Developing baseline security requirement for each
operating system and ensuring all systems meet the
baseline security requirement;
(2)Clearly defining a set of access privileges for
different groups of users, namely, end-users, system
development staff, computer operators, and system
administrators and user administrators;
(3)Setting up a system of approval, verification, and
monitoring procedures for using the highest
privileged system accounts;
(4)Requiring technical staff to review available
security patches, and report the patch status
periodically; and
(5)Requiring 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
monitoring periodically.
Article 26. Commercial banks should ensure the security of all the application systems by
(1)Clearly defining the roles and responsibilities of
end-users and IT staff regarding the application
security;
(2)Implementing a robust authentication method
commensurate with the criticality and sensibility of
the application system;
(3)Enforcing segregation of duties and dual control over
critical or sensitive functions;
(4)Requiring verification of input or reconciliation of
output at critical junctures;
(5)Requiring the input and output of confidential
information are handled in a secure manner to prevent
theft, tampering, intentional leakage, or
inadvertent leakage;
(6)Ensuring system can handle exceptions in a predefined
way and provide meaningful message to users when the
system is forced to terminate; and
(7)Maintaining audit trail in either paper or electronic
format.
(8)Requiring user administrator to monitor and review
unsuccessful logins and changes to users accounts. Article 27. 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 different layers of software and on different computer and networking equipment, which falls into two broad categories:
(1)Transaction journals. They are generated by
application software and database management system,
and contain authentication attempts, modification to
data, error messages, etc. Transaction journals
should be kept according to the national accounting
policy.
(2)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. System logs should be
kept for a period scaled to the risk classification,
but no less than one year.
Banks should ensure that sufficient items be included in the logs to facilitate effective internal controls, system troubleshooting, and auditing while taking appropriate measures to ensure time synchronization on all logs. Sufficient disk space should be allocated to prevent logs from being overwritten. System logs should be reviewed for any exception. The review frequency and retention period for transaction logs or database logs should be determined jointly by IT organization and pertinent business lines, and approved by the IT steering committee.
Article 28. Commercial banks should have the capacity to employ encryption technologies to mitigate the risk of losing confidential information in the information systems or during its transmission. Appropriate management processes of the encryption facilities should be put in place to ensure that
(1)Encryption facilities in use should meet national
security standards or requirements;
(2)Staff in charge of encryption facilities are well
trained and screened;
(3)Encryption strength is adequate to protect the
confidentiality of the information; and
(4)Effective and efficient key management procedures,
especially key lifecycle management and certificate
lifecycle management, are in place.
Article 29. Commercial banks should put in place an effective and efficient system of securing all end-user computing equipment which include desktop personal computers (PCs), portable PCs, teller terminals, automatic teller machines (ATMs), passbook printers, debit or credit card readers, point of sale (POS) terminals, personal digital assistant (PDAs), etc and conduct periodic security checks on all equipments.
Article 30. Commercial banks should put in place a set of policies and procedures to govern the collection, processing, storage, transmission, dissemination, and disposal of customer information.
Article 31. All employees, including contract staff, should be provided with the necessary trainings to fully understand these policies procedures and the consequences of their violation. Commercial banks should adopt a zero tolerance policy against security violation.
Chapter V Application System Development, Testing and Maintenance Article 32. Commercial banks should have the capability to identify, plan, acquire, develop, test, deploy, maintain, upgrade, and retire information systems. Policies and procedures should be in place to govern the initiation, prioritization, approval, and control of IT projects. Progress reports of major IT projects should be submitted to and reviewed by the IT steering committee periodically. Decisions involving significant change of schedule, change of key personnel, change of vendors, and major expenditures should be included in the progress report.
Article 33. Commercial banks should recognize the risks associated with IT projects, which include the possibilities of incurring various kinds of operational risk, financial losses, and opportunity costs stemming from ineffective project planning or inadequate project management controls of the bank. Therefore, appropriate project management methodologies should be adopted and implemented to control the risks associated with IT projects.
Article 34. Commercial banks should adopt and implement a system development methodology to control the life cycle of Information systems. The typical phases of system life cycle