Vulnerability and Patch Management Policy - SME

The Vulnerability and Patch Management Policy (P19S) provides a structured framework for identifying, assessing, and mitigating vulnerabilities across the organization’s digital ecosystem. Explicitly tailored as an SME policy, reflected by its designation and the assignment of the General Manager as the ultimate accountable role, the document recognizes the unique resource constraints of small and mid-sized enterprises while ensuring full alignment with major compliance frameworks such as ISO/IEC 27001:2022, GDPR, NIS2, and DORA. The policy's primary objective is to decrease cybersecurity risk exposure by instituting effective, timely, and risk-based remediation processes for all assets, including servers, endpoints, mobile devices, network hardware, and cloud-hosted environments. The policy's scope is broad and inclusive, applying not only to all conventional IT infrastructure components, but also to custom-developed code, vendor-managed platforms, and any third-party administered systems integral to business operations. This comprehensive reach means that both internal IT resources and external service providers are governed under a common standard, ensuring uniform practices regardless of who manages the assets. All systems, whether on-premise or cloud-based, are thus required to adhere to defined processes for vulnerability identification and remediation. A clear division of roles and responsibilities is embedded in the policy: The General Manager is responsible for oversight and risk acceptance, reflecting the simplified management structures typical of SMEs. Patching activities, record keeping, and exception management are typically carried out by either internal IT administrators or contracted IT support providers. Privacy or Security Coordinators, where appointed, are tasked with ensuring that systems handling personal data receive appropriate prioritization, supporting regulatory compliance and reducing the likelihood of privacy breaches. Practical implementation steps are outlined: Critical security patches must be applied within three days of release, especially for externally-facing systems, while all other patches have a 30-day implementation window. Patches should be validated, tested, and logged, with failed updates or rollbacks thoroughly documented and escalated. The policy further mandates the proactive monitoring of vulnerabilities from operating system notifications, vendor bulletins, and reputable global threat advisories. Third-party and custom-developed software must be reviewed regularly for vulnerable components, ensuring the policy’s effectiveness even when dealing with open-source or external resources. Exception handling, audit logging, and compliance review processes are explicitly detailed, demanding that every deviation from standard patching timelines be risk-assessed, approved, and reevaluated on a set schedule. The policy also mandates annual reviews and interim updates following significant security events or changes in the IT environment. Training and awareness programs ensure that all staff are aware of update expectations and capable of flagging potential issues. Overall, the P19S policy balances rigor and practicality, supporting legal and industry obligations while remaining accessible to SMEs lacking dedicated security teams.