A Change Management Policy governs the documenting, tracking, testing, and approving of system, network, security, and infrastructure changes.
Configuration and Asset Management Policy
A Configuration and Asset Management Policy governs configurations for new sensitive systems
Segregation of Environments
Development, staging, and production environments are segregated.
Secure Development Policy
A Secure Development Policy defines the requirements for secure software and system development and maintenance.
Production Data Use is Restricted
Production data is not used in the development and testing environments, unless required for debugging customer issues.
Availability
Testing the Business Continuity and Disaster Recovery Plan
The Business Continuity and Disaster Recovery Plan is periodically tested via tabletop exercises or equivalents. When necessary, Management makes changes to the Business Continuity and Disaster Recovery Plan based on the test results.
High Availability Configuration
The system is configured for high availability to support continuous availability, when applicable.
Business Continuity and Disaster Recovery Policy
Business Continuity and Disaster Recovery Policy governs required processes for restoring the service or supporting infrastructure after suffering a disaster or disruption.
Backup Restoration Testing
Backed-up data is restored to a non-production environment at least annually to validate the integrity of backups.
Organizational Management
New Hire Screening
Hiring managers screen new hires or internal transfers to assess their qualifications, experience, and competency to fulfill their responsibilities. New hires sign confidentiality agreements or equivalents upon hire.
Background Checks
Background checks or their equivalent are performed before or promptly after a new hires start date, as permitted by local laws.
Information Security Policy
An Information Security Policy establishes the security requirements for maintaining the security, confidentiality, integrity, and availability of applications, systems, infrastructure, and data.
Performance Review Policy
A Performance Review Policy provides personnel context and transparency into their performance and career development processes.
Internal Control Policy
An Internal Control Policy identifies how a system of controls should be maintained to safeguard assets, promote operational efficiency, and encourage adherence to prescribed managerial policies.
Acceptable Use Policy
An Acceptable Use Policy defines standards for appropriate and secure use of company hardware and electronic systems including storage media, communication tools and internet access.
Disciplinary Action
Personnel who violate information security policies are subject to disciplinary action and such disciplinary action is clearly documented in one or more policies.
Organizational Chart
Management maintains a formal organizational chart to clearly identify positions of authority and the lines of communication, and publishes the organizational chart to internal personnel.
Security Awareness Training
Internal personnel complete annual training programs for information security to help them understand their obligations and responsibilities related to security.
Information Security Program Review
Management is responsible for the design, implementation, and management of the organization’s security policies and procedures. The policies and procedures are reviewed by management at least annually.
Roles and Responsibilities
Information security roles and responsibilities are outlined for personnel responsible for the security, availability, and confidentiality of the system.
Personnel Acknowledge Security Policies
Internal personnel review and accept applicable information security policies at least annually.
Internal Control Monitoring
A continuous monitoring solution monitors internal controls used in the achievement of service commitments and system requirements.
Cybersecurity Insurance
Cybersecurity insurance has been procured to help minimize the financial impact of cybersecurity loss events.
Performance Reviews
Internal personnel are evaluated via a formal performance review at least annually
Code of Conduct
A Code of Conduct outlines ethical expectations, behavior standards, and ramifications of noncompliance.
Confidentiality
Data Classification Policy
A Data Classification Policy details the security and handling protocols for sensitive data.
Disposal of Customer Data
Upon customer request, Company requires that data that is no longer needed from databases and other file stores is removed in accordance with agreed-upon customer requirements.
Data Retention and Disposal Policy
A Data Retention and Disposal Policy specifies how customer data is to be retained and disposed of based on compliance requirements and contractual obligations.
Vulnerability Management
Third-Party Penetration Test
A 3rd party is engaged to conduct a network and application penetration test of the production environment at least annually. Critical and high-risk findings are tracked through resolution.
Vulnerability and Patch Management Policy
A Vulnerability Management and Patch Management Policy outlines the processes to efficiently respond to identified vulnerabilities.
Incident Response
Incident Response Plan
An Incident Response Plan outlines the process of identifying, prioritizing, communicating, assigning and tracking confirmed incidents through to resolution.
Lessons Learned
After any identified security incident has been resolved, management provides a "Lessons Learned" document to the team in order to continually improve security and operations.
Incident Response Plan Testing
The Incident Response Plan is periodically tested via tabletop exercises or equivalents. When necessary, Management makes changes to the Incident Response Plan based on the test results.
Tracking a Security Incident
Identified incidents are documented, tracked, and analyzed according to the Incident Response Plan.
Risk Assessment
Vendor Due Diligence Review
Vendor SOC 2 reports (or equivalent) are collected and reviewed on at least an annual basis.
Vendor Risk Assessment
New vendors are assessed in accordance with the Vendor Risk Management Policy prior to engaging with the vendor. Reassessment occurs at least annually.
Risk Register
A risk register is maintained, which records the risk mitigation strategies for identified risks, and the development or modification of controls consistent with the risk mitigation strategy.
Risk Assessment
Formal risk assessments are performed, which includes the identification of relevant internal and external threats related to security, availability, confidentiality, and fraud, and an analysis of risks associated with those threats.
Risk Assessment and Treatment Policy
A Risk Assessment and Treatment Policy governs the process for conducting risk assessments to account for threats, vulnerabilities, likelihood, and impact with respect to assets, team members, customers, vendors, suppliers, and partners. Risk tolerance and strategies are also defined in the policy.
Vendor Risk Management Policy
A Vendor Risk Management Policy defines a framework for the onboarding and management of the vendor relationship lifecycle.
Network Security
Automated Alerting for Security Events
Alerting software is used to notify impacted teams of potential security events.
Network Security Policy
A Network Security Policy identifies the requirements for protecting information and systems within and across networks.
Access Security
Removal of Access
Upon termination or when internal personnel no longer require access, system access is removed, as applicable.
User Access Reviews
System owners conduct scheduled user access reviews of production servers, databases, and applications to validate internal user access is commensurate with job responsibilities.
Unique Access IDs
Personnel are assigned unique IDs to access sensitive systems, networks, and information
Asset Inventory
A list of system assets, components, and respective owners are maintained and reviewed at least annually
Administrative Access is Restricted
Administrative access to production infrastructure is restricted based on the principle of least privilege.
Encryption-in-Transit
Service data transmitted over the internet is encrypted-in-transit.
Access Control and Termination Policy
An Access Control and Termination Policy governs authentication and access to applicable systems, data, and networks.
Physical Security
Physical Security Policy
A Physical Security Policy that details physical security requirements for the company facilities is in place.
Physical Access Restrictions
Processes are in place to create, modify or remove physical access to facilities such as data centers, office spaces, and work areas based on the needs of such individual.
Communications
Privacy Policy
A Privacy Policy to both external users and internal personnel. This policy details the company's privacy commitments.
Terms of Service
Terms of Service or the equivalent are published or shared to external users.
Description of Services
Descriptions of the company's services and systems are available to both internal personnel and external users.
Communication of Security Commitments
Security commitments and expectations are communicated to both internal personnel and external users via the company's website.
Communication of Critical Information
Critical information is communicated to external parties, as applicable.
Confidential Reporting Channel
A confidential reporting channel is made available to internal personnel and external parties to report security and other identified concerns.
