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Compliance Guide
DORA Ready: An Identity Governance Playbook for Financial Services
Who should read this:
Banks, insurers, payment institutions, fintechs, ICT risk leaders, and operational resilience teams.
Immediate Takeaways
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Make identity a control layer inside the ICT risk management framework, not a side process.
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Maintain a register of critical application owners, privileged roles, service accounts, and third-party ICT access.
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Use access reviews and SoD controls as repeatable evidence for resilience testing.
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Tie incident playbooks to account compromise, privilege escalation, and third-party access failure scenarios.
Action Plan
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30 days: inventory critical ICT services and map privileged access paths.
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60 days: automate reviews for critical roles, third parties, and admin groups.
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90 days: run tabletop testing and produce board-ready evidence for control effectiveness.
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Ongoing: monitor orphaned access, toxic combinations, stale privileges, and concentration risk.
Control Checklist
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Critical ICT access map across employees, contractors, vendors, service accounts, and APIs.
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Access certification linked to critical or important functions.
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Third-party access expiry and review tied to the ICT third-party register.
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Incident runbooks for credential compromise and privileged access abuse.
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Metrics: review completion, emergency access use, orphaned accounts, privilege drift, and unresolved exceptions.