Monitoring

Change Management

Configuration and Asset Management Policy

A Configuration and Asset Management Policy governs configurations for new sensitive systems.

Baseline Configurations

Baseline configurations and codebases for production infrastructure, systems, and applications are securely managed.

Secure Development Policy

A Secure Development Policy defines the requirements for secure software and system development and maintenance.

Change Management Policy

A Change Management Policy governs the documenting, tracking, testing, and approving of system, network, security, and infrastructure changes.

Production Data Use is Restricted

Production data is not used in the development and testing environments, unless required for debugging customer issues.

Segregation of Environments

Development, staging, and production environments are segregated.

Availability

Backup Restoration Testing

Backed-up data is restored to a non-production environment at least annually to validate the integrity of backups.

Uptime and Availability Monitoring

System tools monitor for uptime and availability based on predetermined criteria.

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

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.

Personnel Acknowledge Security Policies

Internal personnel review and accept applicable information security policies at least annually.

Advisor Meetings on Security

Senior management and/or the 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.

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.

Internal Control Monitoring

A continuous monitoring solution monitors internal controls used in the achievement of service commitments and system requirements.

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.

Security Awareness Training

Internal personnel complete annual training programs for information security to help them understand their obligations and responsibilities related to security.

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.

Performance Reviews

Internal personnel are evaluated via a formal performance review at least annually.

Cybersecurity Insurance

Cybersecurity insurance has been procured to help minimize the financial impact of cybersecurity loss events.

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.

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.

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.

Confidentiality

Data Classification Policy

A Data Classification Policy details the security and handling protocols for sensitive data.

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

Vulnerability and Patch Management Policy

A Vulnerability Management and Patch Management Policy outlines the processes to efficiently respond to identified vulnerabilities.

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.

Incident Response

Lessons Learned

After any identified security incident has been resolved, management provides a "Lessons Learned" document to the team 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.

Incident Response Plan

An Incident Response Plan outlines the process of identifying, prioritizing, communicating, assigning, and tracking confirmed incidents through to resolution.

Risk Assessment

Vendor Due Diligence Review

Vendor SOC 2 reports (or equivalent) are collected and reviewed on at least an annual basis.

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 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.

Vendor Risk Management Policy

A Vendor Risk Management Policy defines a framework for the onboarding and management of the vendor relationship lifecycle.

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 Assessment

New vendors are assessed in accordance with the Vendor Risk Management Policy prior to engaging with the vendor. Reassessment occurs at least annually.

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.

Network Security Policy

A Network Security Policy identifies the requirements for protecting information and systems within and across networks.

Access Security

Unique Access IDs

Personnel are assigned unique IDs to access sensitive systems, networks, and information.

Encryption-in-Transit

Service data transmitted over the internet is encrypted-in-transit.

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.

Administrative Access is Restricted

Administrative access to production infrastructure is restricted based on the principle of least privilege.

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.

Access Control and Termination Policy

An Access Control and Termination Policy governs authentication and access to applicable systems, data, and networks.

Access to Product is Restricted

Non-console access to production infrastructure is restricted to users with a unique SSH key or access key.

Physical Security

Physical Access Reviews

Processes are in place to periodically review physical access to ensure consistency with job responsibilities.

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 an individual.

Physical Security Policy

A Physical Security Policy that details physical security requirements for the company facilities is in place.

Visitor Control

Production facilities require all visitors to formally sign in, unless preauthorization for the visitor exists.

Communications

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.

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.

Confidential Reporting Channel

A confidential reporting channel is made available to internal personnel and external parties to report security and other identified concerns.

Terms of Service

Terms of Service or the equivalent are published or shared with external users.