The Ministry of Electronics and Information Technology in May 2018 notified the Information Technology (Information Security Practices and Procedures for Protected System) Rules, 2018, (hereinafter referred to as “the Rules”).
In the wake of global-level sensitization to the threat of data/ information misuse and cyber terrorism, these Rules were long awaited. The Rules prescribe a detailed infrastructure of what is defined therein as a ‘Protected System’ for implementation of security practices and protective measures required to be taken towards highly sensitive data or data collection centre.
What is a Protected System?
According to the Rules a Protected System is any computer, computer system or computer network of any Organization as notified under Section 70 of the Information Technology Act, 2000, in the official gazette by the appropriate Government.
Information Security Steering Committee
The Rules define an ‘Information Security Steering Committee’ to mean ‘the committee comprising higher
management officials of an organization, responsible for continuously improving and strengthening the cyber security posture of the Protected System and also plan, develop, review remedial actions to mitigate and recover from malicious cyber incidents.’
As per Rule 3 of the Rules, every organization having ‘Protected System’ shall constitute an Information Security Steering Committee under the chairmanship of CEO/ MD or Secretary of the organization.
The composition of the Committee is required to include the IT Head or equivalent; Chief Information Security Officer (“CISO”); Financial Advisor or equivalent; Representative of National Critical Information Infrastructure Protection Centre (“NCIIPC”); any other expert(s) to be nominated by the organization.
Roles and Responsibilities of the Information Security Steering Committee
The Rules prescribe the vital roles and responsibilities of the Information Security Steering Committee the significant ones of which are as follows: -
- To approve all the Information Security Policies of the ‘Protected System’ any significant changes in network configuration impacting the “Protected System” or any significant change in application of the “Protected System”.
- To establish mechanism for timely communication of cyber incident(s) related to “Protected System” to Information Security Steering Committee. A detailed definition as to what comprises of a cyber incident is mentioned in the Rules as an adverse incident that may result in impairing the confidentiality, integrity, or availability of electronic information, systems, services or networks resulting in unauthorised access, denial of service or disruption, unauthorised use of a computer resource, changes to data or information without authorization or threaten interests of public at large.
- To establish mechanism for sharing of results of all information security audits and compliance of “Protected System” to Information Security Steering Committee.
- To assess validation of “Protected System” after every two years.
The Rules prescribe certain mandatory practices and infrastructural compliances to be followed by any organization having a Protected System.
Nomination of Chief Information Security Officer (CISO):
A “Chief Information Security Officer” means a designated employee of Senior management, directly reporting to MD/ CEO etc. of the organisation, having knowledge of information security and related issues. The CISO is responsible for cyber security efforts and initiatives including planning, developing, maintaining, reviewing and implementation of Information Security Policies.
Every organization designated as a “Protected System” is required to nominate a CISO whose roles and responsibilities have been enumerated in “Guidelines for Protection of Critical Information Infrastructure” and “Roles and Responsibilities of Chief Information Security Officers (CISOs) of Critical Sectors in India” released by NCIIPC.
Some of the CISO’s main responsibilities include establishing ISMS, documenting network architecture, ensuring stability, resilience and scalability of the systems, conducting Vulnerability/Threat/Risk (V/T/R) Analysis for the cyber security architecture, Establishing and developing a Cyber Crisis Management Plan, conducting internal and external Information Security audits and documenting process for IT Security Service Level Agreements (SLAs) while entering into agreements with service providers etc.
Cyber Security Operation Center (“C-SOCs”) and Network Operation Center (“NOCs”)
Organizations with Protected Systems have to establish a C-SCO and NOCs with the aim of implementing preventive, detective and corrective controls to secure against advanced and emerging cyber threats, threats of unauthorized access and ensure continuity in network availability.
The Rules also prescribe in detail the roles and responsibilities of CISO of the “Protected System(s)” towards NCIIPC