System changes are approved by at least 1 independent person prior to deployment into production.
Secure Development Policy
A Secure Development Policy defines the requirements for secure software and system development and maintenance.
Configuration and Asset Management Policy
A Configuration and Asset Management Policy governs configurations for new sensitive systems
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.
Backup Restoration Testing
Backed-up data is restored to a non-production environment at least annually to validate the integrity of backups.
Organizational Management
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.
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.
Roles and Responsibilities
Information security roles and responsibilities are outlined for personnel responsible for the security, availability, and confidentiality of the system.
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.
Background Checks
Background checks or their equivalent are performed before or promptly after a new hires start date, as permitted by local laws.
Confidentiality
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.
Data Classification Policy
A Data Classification Policy details the security and handling protocols for sensitive data.
Vulnerability Management
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
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.
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
An Incident Response Plan outlines the process of identifying, prioritizing, communicating, assigning and tracking confirmed incidents through to resolution.
Risk Assessment
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 Risk Management Policy
A Vendor Risk Management Policy defines a framework for the onboarding and management of the vendor relationship lifecycle.
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 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 Due Diligence Review
Vendor SOC 2 reports (or equivalent) are collected and reviewed on at least an annual basis.
Access Security
Removal of Access
Upon termination or when internal personnel no longer require access, system access is removed, as applicable.
Complex Passwords
Personnel are required to use strong, complex passwords and a second form of authentication to access sensitive systems, networks, and information
Least Privilege in Use
Users are provisioned access to systems based on principle of least privilege.
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.
Asset Inventory
A list of system assets, components, and respective owners are maintained and reviewed at least annually
Unique Access IDs
Personnel are assigned unique IDs to access sensitive systems, networks, and information
Communications
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.