Page 32 - Insurance Times February 2022
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Such risks can arise due to-                         6. Operational Risk Management
         Y   Insufficient knowledge of banking business process  Operational Risk Management is a continuous process of risk

         Y   Lack of adequate training                        identification, risk assessment, providing risk treatment,
                                                              monitoring and review.
         Y   Third party practices not in line with bank practices
         Y   Incompetent or under qualified or inexperienced staff  Operational Risk Management (ORM) is at the core of
             deployed by service provider                     bank's operations. ORM framework supports in aligning the
                                                              business control environment with the bank's strategy by
         Y   Unavailability of required technology competence
                                                              measuring and mitigating risk exposure, contributing to
         Y   Use of sub-standard technology by the service provider  optimal return for stakeholders.

         Y   Use of unlicensed software
         Y   Non adherence to the SLA by service provider     7.1. Risk management framework in
         Y   Unavailability or Inadequate BCP/DRP plans with service outsourcing activities
             provider                                         Risk management framework must follow an approach to

         Y   Failure or insufficient internal controls at service  identify potential risks and should provide for controls that
                                                              are in line with the level of risk present in outsourced
             provider
                                                              activities. Special attention should be given to activities that
         Y   Lack of awareness of different IT Laws applicable around
                                                              may have a substantial impact on the bank's core functions
             data protection                                  and those that are subject to material compliance, legal and
                                                              cyber risks.
         Some examples of Operational risks in
         outsourcing activities:                              The objectives of operation risk management
                                                              framework in outsourcing activities are to-
           Sr No.    Risks
                                                              Y  Identify key risks associated with outsourced activities
             1       Risk of unavailability of banking services or
                                                                 at the time of on-boarding of service provider to ensure
                     interrupted services to the customers
                                                                 effective implementation of relevant applicable controls
             2       Risk of data leakage or breach of data      and to provide assurance on effectiveness of the control
                     confidentiality                             design and operation.
             3       Risk of inadequate data back up and potential  Y  To conduct performance evaluation on key performance
                     data loss                                   indicators or metrics.
             4       Risk of cyber threats including identity theft
                     or installation of ransomware            7.2. Following approach can be adopted
             5       Hindrance to software development or     in managing the outsourcing risk
                     system development
                                                              a. Risk Assessment:
             6       Vendor's system and applications may be
                                                                 It is important to carry out risk assessment of the activity
                     vulnerable to external threats
                                                                 prior to engaging in outsourcing activity with external
             7       Risk of delay in project deliveries         party.
             8       Excessive / Uncontrolled access to shared   A comprehensive checklist can be developed for risk
                     folders or right to manage shared folders   assessment to ensure adequate controls are in place to

             9       Physical or logical access by unauthorised  mitigate probable risk associated with the outsourced
                     personnel                                   activities and recommendation of new controls if
                                                                 current controls are insufficient to mitigate the risk.
             10      Sub-contract by the vendor or operator
                                                                 Further, risk assessment exercise can be done a regular
                     without adequate approval from the bank
                                                                 basis to scale up (or scale down) the risk mitigation
             11      Threat of infringement of IPR
                                                                 plans, if appropriate.
          32  The Insurance Times, February 2022
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