Policy on Outsourcing
Policy on Outsourcing
Policy on Outsourcing
HR & IR DEPARTMENT
(ISO 9001:2015 CERTIFIED)
Circular/HO/HR&IR/GF(3)/13/2024-25 July 22, 2024
Outsourcing Policy
KBL/ISMS/POL/005
Ver 3.0 dated 19.06.2024
CONTENTS
A. OUTSOURCING OTHER THAN INFORMATION TECHNOLOGY SERVICES -
CHAPTER – I
B. OUTSOURCING INFORMATION TECHNOLOGY SERVICES - CHAPTER – II
CHAPTER – I
CHAPTER – II
1. Objective
The objective of the Bank’s outsourcing policy is to maintain the security of the
organization’s information and information processing facilities that are accessed,
processed, communicated to, or managed by external parties. It is in alignment with
the Reserve Bank’s supervisory framework and our current priorities projected within
that framework.
2. Scope
This policy is applicable to permanent and contract employees, vendors, and agents
operating on behalf of the Bank. The policy is applicable to all outsourcing
arrangements entered or likely to be entered into by the Bank.
3. Strategy
The policy also covers issues relating to safeguarding the interest of the Bank,
balancing the interest of customers, employees, community and share-holders. The
policy aims at capturing efficiency, cost – effectiveness and risk reduction advantages
that outsourcing will provide. The Bank controls outsourcing activities to ensure
effective management of Strategic Risk, Reputation Risk, Compliance Risk, Legal Risk,
Exit Strategy Risk, Counter Party Risk, Contractual Risk, Access Risk, Concentration
and Systemic Risk.
4. Areas of Outsourcing
However, the Bank would not outsource Core Management functions including
Internal Audit, Compliance function and decision making functions like determining
compliance with KYC norms for opening deposit accounts, according sanction for
loans and Management of Investment portfolio, the information security
group/function itself , information security governance related structures and
activities which cannot be outsourced as per RBI guidelines.
1. For a one time activity, the bank shall consider the following factors:
a) Time and resource required to execute the work, if taken up internally.
b) Skills and expertise required.
c) Time and cost likely to be incurred in preparing the internal resources to
meet this requirement.
d) If the internal resource mobilization (having necessary skills and expertise)
is not expected to meet the requirement in terms of desired quantity/quality,
the bank may outsource such a one-time activity.
2. For an ongoing activity, the bank shall consider the following factors:
a) The dynamics involved.
b) Pace of change of technology.
c) Skills and expertise required if taken up internally.
d) The displacement cost.
e) Training requirements on an ongoing basis.
The Board and Senior Management oversee outsourcing operations and manage risks
inherent in such outsourcing relationships. The activities to be outsourced are referred
to the Outsourcing Committee.
The above committee will conduct due diligence in relation to outsourcing, to consider
all relevant laws, regulations, guidelines and conditions of approval, licensing or
registration.
The Bank may delegate its day-to-day operational duties to a service provider.
Responsibilities for effective due diligence, oversight and management of outsourcing
and accountability for all outsourcing decisions continue to rest with the Bank, Board
and senior management.
Extent of due diligence reviews may vary based on risk inherent in the outsourcing
arrangements. Due diligence undertaken during the selection process will be
documented and re-performed periodically as part of the monitoring and control
processes of outsourcing.
The convener of the said committee will place a review note to the Risk and Capital
Management Committee (RCMC) on a half – yearly basis with the grievances of
the customers, if any, and the action taken will be reported to the Board, preferably
within 2 months from the end of the half – year/financial year.
• Evaluating the risks and materiality of all prospective outsourcing based on the
framework developed by the Board.
• Developing sound outsourcing policies and procedures for implementation by
Line Managers.
• Periodically reviewing the effectiveness of policies and procedures.
• Communicating significant risks in outsourcing to the Board on a periodic basis.
• Ensuring an independent review and audit in accordance with approved policies
and procedures.
• Ensuring contingency plans have been developed and tested adequately.
8. ‘Material’ Outsourcing
Bank will assess the degree of ‘materiality’ inherent in the outsourced functions and
exercise due diligence accordingly.
10. Contract
Agreements with third parties involving accessing, processing, communicating or
managing the organization’s information or information processing facilities, or
Outsourcing Agreement with a service provider will be vetted by the Bank’s panel
advocate and/or by the Legal Department, Head Office on its legal effect and
enforceability. The agreement will also define the nature of legal relationship between
the parties – i.e., whether agent, principal or otherwise as the outsourcing agreement
prefers. Contracts will clearly define the roles and responsibilities of the parties to the
contract and include suitable indemnification clauses. Any ‘limitation of liability’
consideration incorporated by the service provider will be assessed in consultation
with the legal department. It will also briefly cover the following key provisions.
a. The contract will clearly define what activities are going to be outsourced
including appropriate service and performance standards.
c. The Bank must ensure access to the all books, records and information, which
are relevant to the outsourced activity and available with the service provider.
For technology outsourcing, requisite audit trails and logs for administrative
activities will be retained and accessible to the Bank based on approved
requests.
d. The contract will provide for continuous monitoring and assessment of the
service provider by the Bank, so that any necessary corrective measures can be
taken immediately, if the need arises.
g. The contract will provide for the prior approval/consent by the bank for the
use of subcontractors by the service provider for all or part of an outsourced
h. Provide the bank with the right to conduct audits on the service provider either
by its internal or external auditors, or by agents appointed to act on its behalf
and to obtain copies of any audit or review reports and findings made on the
service provider in conjunction with the services performed for the Bank.
l. Contract will include conditions for default termination / early exit option for
contracts. This may include circumstances when the service provider
undergoes a change in ownership, becomes insolvent or goes under
liquidation, received judicial indictment (whether within India or any other
location), or when there has been a breach of confidentiality, security, or
demonstrable deterioration in quality of services rendered.
n. The outsourcing agreement will provide for the preservation of documents and
data by the service provider in accordance with the legal/regulatory obligation
of the bank in this regard.
11.1 While establishing connectivity with vendors/ partners the security measures
at their end will be evaluated to ensure that the Bank is not exposed to security
threats due to the connectivity.
11.2 Access, both physical and logical, when provided to partners shall be
authorized and approved by relevant authorities and shall be on a business
need basis.
11.3 Access provided to partners and vendors shall be logged and monitored.
Rating of the service provider/outsourcing agency including DSAs and BSAs shall be
done by all Offices/Departments as per the template provided by Risk Management
Department, Head Office.
The Final rating of Service provider/outsourcing agency including DSAs and BSAs
shall be done by the Risk Management Department.
It shall be ensured that the security controls, service definitions and delivery levels
included in the third party service delivery agreement are implemented, operated,
and maintained by the third party.
The Bank reports to the regulator, where the scale and nature of functions outsourced
are significant, or extensive data sharing is involved across geographic locations as
part of technology / process outsourcing and when data pertaining to Indian
operations are stored / processed abroad, provided, in the payment ecosystem, all
system providers shall ensure that the entire data relating to payment systems
operated by them are stored in a system only in India. This data should include the
full end-to-end transaction details / information collected / carried / processed as
The Bank monitors the control environment of all service providers that have access
to the Bank systems, records or resources in a multiple service provider relationships
scenario.
19. Sub-contracting
Agreements should specify the resolution process, the event of default, indemnities
involved and the remedies and recourse of the respective parties to the agreement.
The services, reports and records provided by the third party shall be regularly
monitored and reviewed, and audits shall be carried out regularly. Half yearly review
If the vendor service level falls below acceptable levels, it may affect the Bank in
unforeseen ways. Hence it becomes critical for the Bank to define service levels
and ensure vendor adherence to the same.
23.1.2 Appropriate controls are put in place to track and monitor Service Levels
maintained by the vendors.
23.1.3 Penalties for Service Level Agreement violations are clearly defined and
communicated to the vendor and their acceptance of the same shall be obtained
in writing.
23.2.2 While the Bank signs an NDA provided by the partner/ vendor, relevant
department reviews the same. The NDA shall be signed by an authorized
signatory.
The agreement with the service provider shall invariably incorporate the
following clauses (apart from the regular clauses as approved by the legal
department):
23.3.1 The Bank shall have access to all books, records and information
relevant to the outsourced activity available with the service provider.
23.3.2 The Bank shall exercise the right to audit the activities of the service
provider by engaging internal or external auditors and to obtain copies of audit
or review reports and finding made on the service provider in conjunction with
the services performed for the bank.
23.3.3 The service provider shall allow the Reserve Bank of India or persons
authorized by it to access the Bank’s documents, records of transactions, and
other necessary information given to, stored or processed by the service provider
within a reasonable time.
23.3.4 The service provider shall recognize the right of the Reserve Bank of
India to cause an inspection to be made of a service provider and its books and
account by one or more of its officers or employees or other persons.
23.5.1 The Bank shall reserve the right to interview and reject staff being
deployed by vendors/ partners for carrying out the responsibilities associated
with the Bank.
23.5.2 The Bank shall reserve the right of enforcing its employee selection
criteria and procedures to employees of the vendor who are to be deployed for
carrying out responsibilities associated with the Bank.
23.5.3 Staff of the vendors and partners shall undergo an induction program
detailing the operational procedures of the Bank, which they would be expected
to follow. A written acceptance stating their willingness to adhere to these shall
be obtained in writing.
Innovations or developments may come about during the course of any contract.
The rights to such innovations/ developments in terms of who can use/ patent/
market the same shall be discussed and documented before commencing work.
The Bank will evaluate the adequacy of internal controls environment offered by the
service provider.
The Bank shall conduct pre and post outsourcing implementation reviews. The Bank
shall also review its outsourcing arrangements periodically to ensure that its
outsourcing risk management policies and procedures, and the Guidelines, are
effectively complied with. The Bank shall at least on an annual basis, review the
financial and operational condition of the service provider to assess its ability to
continue to meet outsourcing obligations. Such due diligence reviews, which can be
based on all available information about the service provider including reports by the
service provider’s external auditors, should highlight any deterioration or breach in
performance standards, confidentiality and security, and in business continuity
preparedness.
The Bank shall also periodically commission independent audit and expert
assessments on the security and control environment of the service provider. Such
assessments and reports on the service provider may be performed and prepared by
the institution’s internal or external auditors, or by agents appointed by the
institution.
1. Background
IT outsourcing policy is crucial, given the technological innovation and ideations that
have inched into the Indian Financial system in recent times. Banks rely heavily on
technology to deliver their products and services to customers. Technology has
become the core component of every activity and operation in the banking system
today. Technology not being the core expertise of the Banking system, it is sometimes
necessary for the Banks to rely on the expertise residing outside the banking system
to deliver value and growth to the Banking sector.
2. Objective
Bank, in its current helm of growth trajectory, continues to outsource the technology
services to support its strategic goals. The Bank, on one hand, benefits from IT
outsourcing regarding Cost Efficiency, time to market, efficiency in delivery,
Optimization of costs by leveraging the expertise and resources of service providers
and reducing bank’s operational costs / specialised skills, Enhanced Quality of Service
& Performance, and at the same time faces the risk associated with such outsourcing.
This necessitates, the Bank to formulate and implement a strong governance
framework around the IT outsourcing. The objective of this policy is to ensure that IT
outsourcing activities by Bank are managed in a controlled and secure manner,
aligning with business objectives, minimising risks, and maximising the benefits
derived from outsourcing.
The above service providers of the Bank will hereafter be referred as IT Outsourcing
service provider in this Policy. The scope of policy will also covers the activities that
may be classified as material outsourcing by the regulatory bodies.
4. Definitions
For the purpose of this policy, Material outsourcing of IT services is those which:
If disrupted or compromised, shall have the potential to impact the Bank's business
operations significantly; or,
May have a material impact on the Bank's customers in the event of any unauthorised
access, loss, or theft of customer information.
The Bank shall evaluate the need for Outsourcing IT Services based on a
comprehensive assessment, including the potential benefits, risks, and controls to
manage those risks. Bank shall inter-alia consider the following:
The Bank shall ensure that the outsourcing does not impede RBI in its supervisory
functions and objectives.
The Bank shall ensure that the service provider, if not a group company, shall not be
owned or controlled by any director, key managerial personnel, or approver of the
outsourcing arrangement of the Bank or their relatives. The Bank shall ensure that
there is no conflict of interest arising out of third-party engagements.
All data collected, stored and processed for the services provided to the Bank shall be
from systems in India.
Only MeitY - Ministry of Electronics and Information Technology, Government of
India approved Cloud Service Providers and data centers (for cloud) shall be used by
the Bank. Further, cloud controls dealt in Cloud policy (Policy on IT Chapter 6) in
respect of usage of cloud computing services and outsourcing of security operations,
guidelines as outlined by RBI as indicated in Appendix - I and modified from time to
time shall be adhered to.
The Bank shall create an inventory of the IT outsourcing service providers covering
all basic elements of contractual terms, key entities involved in their supply chains,
and Risk categorisation.
Bank shall consider all relevant laws, regulations, rules, guidelines and conditions of
approval, licensing, or registration when performing its due diligence in relation to
outsourcing of IT services.
The responsibilities of the IT Function of the Bank shall, inter alia, include:
Bank may outsource any IT activity / IT-enabled service within its business
group/conglomerate provided such an arrangement shall be backed by appropriate
service level arrangements/agreements with its group entities and shall maintain
arm's length relationship in dealings with group entities. Risk management practices
being adopted by the Bank while outsourcing to a group entity will be identical to
those specified for a non-related party.
In case the Bank engages a service provider outside the Jurisdiction of India, the
additional requirements for cross-border outsourcing, as enunciated by RBI and other
statutory authorities from time to time, will be complied with.
The terms and conditions shall be vetted by the Legal Dept of the Bank. The formal
Contract for IT outsourcing shall cover the following mandatory clauses:
Service level agreement signed between the Bank and the service providers shall be
part of the legally binding Contract with the Outsourced Service Providers.
All documents and information that may be provided to the Outsourcing Services
provider shall be noted and reviewed by the Concerned IT Function. The document and
information must be returned to Bank on contract expiry or termination. Also, any soft
copy document maintained on mobile computing device of the Outsourcing Services
provider must be destroyed on contract expiry or termination. No part of the
document, or information provided may be copied without the prior explicit
Outsourced Service Provider shall notify any type of security violation or security
incident which may potentially affect Bank's computing environment within mutual
agreed duration. Outsourced Service Provider shall have documented recovery
procedures for the services provided to the Bank as per service level agreement with
Bank.
During the period of the Contract, it shall be the responsibility of the Outsourcing
Services provider to protect any document or information provided to them against
loss, theft, or misuse. Any such incident shall be reported immediately to the CISO
Office who in-turn shall immediately report to senior management. The personnel
must be familiar with the requirements of the outsourced activities and the Bank. They
shall adhere to the policies, standards, and procedures as per governed by
organization. Bank shall verify that Outsourced Service Providers have appropriate
security program to train their personnel for security related issues and for their
assigned roles.
Security Assessments shall be carried out periodically to review and assess the risks
to the Bank and security controls implemented by the Outsourced Service Provider.
The Bank shall also periodically commission independent audit and expert
assessments on the security & controls implemented by the service provider.
Banks shall carefully evaluate the need for outsourcing critical processes and selection
of Outsourced Service Provider/partner based on comprehensive risk assessment. In
negotiating / renewing an Outsourcing arrangement, due diligence will be performed
to assess the capability of the technology service provider to comply with obligations
in the outsourcing agreement. Due diligence will involve an evaluation of all
information about the service provider including qualitative, quantitative, financial,
operational, and reputational factors, as follows:
Bank shall device varied due diligence based on the inherent risk in the outsourcing
arrangements. Due diligence undertaken during the selection process will be
Review meetings shall be conducted with the Outsourcing Services Provider to assess
the performance and SLA Compliance.
9.2 Review
All Materially critical outsourcing services shall be subject to half yearly review by
Outsourcing committee. The objective of this review is to assure to the management
The Bank shall insist and evidence during the review that the service provider isolate
Bank's information, data, records of transactions, documents and assets of the Bank
are identifiable so as to ensure deletion, destruction or rendered unusable in the event
of termination. Review and maintenance of inventory for Outsourced service provider
is part of Annual review.
9.3 Audit
Audit and Assurance: The audit / periodic review / third-party certifications should
cover, as per applicability and cloud usage, inter alia, aspects such as roles and
responsibilities of both Bank and CSP in cloud governance, access and network
controls, configurations, monitoring mechanism, data encryption, log review, change
management, incident response, and resilience preparedness and testing, etc.
The annual risk review shall cover the readiness of the Bank detailing the alternatives
of the Bank to switch to another service provider or bring the services in house in the
eventuality of disruption at the current service providers delivery. This shall be
detailed covering the cost, time, and other relevant resources to manage the BCP.
11.Exit Strategy
Bank shall assess and recommend exiting the relationship with the outsourcing
service provider under the following scenarios.
Obligation of the service provider to comply with directions issued by the RBI in
relation to the activities outsourced to the service provider, through specific
contractual terms and conditions specified by the Bank.
• Clauses requiring prior approval/ consent of the Bank for use of sub-
contractors by the service provider for all or part of an outsourced activity.
There are several cloud deployment and service models that have emerged over time.
These are generally based on the extent of technology stack that is proposed to be
adopted by the consuming entity. Each of these models come with corresponding
service, business benefit and risk profiles.
In addition to the Outsourcing of IT Services controls prescribed in the policy, Bank will
adopt the following requirements for storage, computing, and movement of data in
cloud environments:
2. In engaging cloud services, Bank will ensure, inter alia, that the
Outsourcing of IT Services policy addresses the entire lifecycle of data, i.e.,
covering the entire span of time from generation of the data, its entry into
the cloud, till the data is permanently erased / deleted. The Bank will
ensure that the procedures specified are consistent with business needs and
legal and regulatory requirements.
3. In adoption of cloud services, Bank will consider the cloud service specific
factors, viz., multi-tenancy, multi-location storing / processing of data, etc.,
and attendant risks, while establishing appropriate risk management
framework. Cloud security is a shared responsibility between the Bank and
the Cloud Service Provider (CSP). Bank may refer to some of the cloud
security best practices, for implementing necessary controls, as per
applicability of the shared responsibility model in the adoption of cloud
services.
b) Identity and Access Management (IAM): IAM shall be agreed upon with
the CSP and ensured for providing role-based access to the cloud hosted
applications, in respect of user-access and privileged-access. Stringent
access controls, as applicable for an on-premises application, may be
established for identity and access management to cloud-based
applications. Segregation of duties and role conflict matrix should be
implemented for all kinds of user-access and privileged-access roles in the
cloud-hosted application irrespective of the cloud service model. Access
provisioning should be governed by principles of 'need to know' and 'least
CSP can maintain its information / cyber security capability with respect
to changes in vulnerabilities and threats, including those resulting from
changes to information assets or its business environment;
Appropriate integration of logs, events from the CSP into the Bank's SOC,
wherever applicable and / or retention of relevant logs in cloud shall be
Bank will ensure that the CSP puts in place demonstrative capabilities for
preparedness and readiness for cyber resilience as regards cloud services in
use by them. This should be systematically ensured, inter alia, through robust
incident response and recovery practices including conduct of Disaster
Recovery (DR) drills at various levels of cloud services including necessary
stakeholders.
the exit strategy and service level stipulations in the SLA shall factor in, inter
alia,
agreed processes and turnaround times for returning the Bank's service
collaterals and data held by the CSP;
c) contractually agreed exit / termination plans should specify how the cloud-
hosted service(s) and data will be moved out from the cloud with minimal
impact on continuity of the Bank's business, while maintaining integrity and
security.
Audit and Assurance: The audit / periodic review / third-party certifications should
cover, as per applicability and cloud usage, inter alia, aspects such as roles and
responsibilities of both Bank and CSP in cloud governance, access and network controls,
configurations, monitoring mechanism, data encryption, log review, change
management, incident response, and resilience preparedness and testing, etc.
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CISO-Signature