A Change Management Policy governs the documenting, tracking, testing, and approving of system, network, security, and infrastructure changes.
Approval for System Changes
System changes are approved by at least 1 independent person prior to deployment into production.
Software Change Testing
Software changes are tested prior to being deployed into production.
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.
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.
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.
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.
Organizational Management
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.
Code of Conduct
A Code of Conduct outlines ethical expectations, behavior standards, and ramifications of noncompliance.
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.
Background Checks
Background checks or their equivalent are performed before or promptly after a new hires start date, as permitted by local laws.
Internal Control Monitoring
A continuous monitoring solution monitors internal controls used in the achievement of service commitments and system requirements.
Performance Reviews
Internal personnel are evaluated via a formal performance review at least annually
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.
Roles and Responsibilities
Information security roles and responsibilities are outlined for personnel responsible for the security, availability, and confidentiality of the system.
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.
Cybersecurity Insurance
Cybersecurity insurance has been procured to help minimize the financial impact of cybersecurity loss events.
Independent Advisor
The board of directors or equivalent entity function includes senior management and external advisors, who are independent from the company's operations. An information security team has also been established to govern cybersecurity.
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.
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.
Security Awareness Training
Internal personnel complete annual training programs for information security to help them understand their obligations and responsibilities related to security.
Advisor Meetings on Security
Senior management and/or board of directors meets at least annually to review business goals, company initiatives, resource needs, risk management activities, and other internal/external matters. The information security team meets at least annually to discuss security risks, roles & responsibilities, controls, changes, audit results and/or other matters as necessary.
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.
Access to Customer Data is Restricted
Access to, erasure of, or destruction of customer data is restricted to personnel that need access based on the principle of least privilege.
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 Scanning
Vulnerability scanning is performed on production infrastructure systems, and identified deficiencies are remediated on a timely basis.
Vulnerability and Patch Management Policy
A Vulnerability Management and Patch Management Policy outlines the processes to efficiently respond to identified vulnerabilities.
Incident Response
Tracking a Security Incident
Identified incidents are documented, tracked, and analyzed according to the Incident Response Plan.
Incident Response Plan
An Incident Response Plan outlines the process of identifying, prioritizing, communicating, assigning and tracking confirmed incidents through to resolution.
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.
Risk Assessment
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.
Vendor Due Diligence Review
Vendor SOC 2 reports (or equivalent) are collected and reviewed on at least an annual basis.
Vendor Risk Management Policy
A Vendor Risk Management Policy defines a framework for the onboarding and management of the vendor relationship lifecycle.
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 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.
Network Security
Network Traffic Monitoring
Security tools are implemented to provide monitoring of network traffic to the production environment.
Automated Alerting for Security Events
Alerting software is used to notify impacted teams of potential security events.
Endpoint Security
Company endpoints are managed and configured with a strong password policy, anti-virus, and hard drive encryption
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.
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
Access Control and Termination Policy
An Access Control and Termination Policy governs authentication and access to applicable systems, data, and networks.
Least Privilege in Use
Users are provisioned access to systems based on principle of least privilege.
Administrative Access is Restricted
Administrative access to production infrastructure is restricted based on the principle of least privilege.
Access to Product is Restricted
Non-console access to production infrastructure is restricted to users with a unique SSH key or access key
Encryption and Key Management Policy
An Encryption and Key Management Policy supports the secure encryption and decryption of app secrets, and governs the use of cryptographic controls.
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.
Physical Security
Physical Security Policy
A Physical Security Policy that details physical security requirements for the company facilities is in place.
Communications
Description of Services
Descriptions of the company's services and systems are available to both internal personnel and external users.
Terms of Service
Terms of Service or the equivalent are published or shared to external users.
Confidential Reporting Channel
A confidential reporting channel is made available to internal personnel and external parties to report security and other identified concerns.
Communication of Security Commitments
Security commitments and expectations are communicated to both internal personnel and external users via the company's website.
Privacy Policy
A Privacy Policy to both external users and internal personnel. This policy details the company's privacy commitments.
Communication of Critical Information
Critical information is communicated to external parties, as applicable.
