Monitoring

Change Management Policy

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.

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.

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.

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 monitors for uptime and availability based on predetermined criteria.

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.

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.

Automated Backup Process

Full backups are performed and retained in accordance with the Business Continuity and Disaster Recovery Policy.

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.

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.

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.

Performance Reviews

Internal personnel are evaluated via a formal performance review 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.

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.

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.

Background Checks

Background checks or their equivalent are performed before or promptly after a new hires start date, as permitted by local laws.

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.

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.

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.

Performance Review Policy

A Performance Review Policy provides personnel context and transparency into their performance and career development processes.

Roles and Responsibilities

Information security roles and responsibilities are outlined for personnel responsible for the security, availability, and confidentiality of the system.

Cybersecurity Insurance

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

Code of Conduct

A Code of Conduct outlines ethical expectations, behavior standards, and ramifications of noncompliance.

Retention of Customer Data

Procedures are in place to retain customer data based on agreed-upon customer requirements or in line with information security policies.

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 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.

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.

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.

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 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.

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.

Network Security Policy

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

Removal of Access

Upon termination or when internal personnel no longer require access, system access is removed, as applicable.

Access Control and Termination Policy

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

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.

Access to Product is Restricted

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

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.

Encryption-in-Transit

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

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

Communication of Critical Information

Critical information is communicated to external parties, as applicable.

Communication of Security Commitments

Security commitments and expectations are communicated to both internal personnel and external users via the company’s website.

Confidential Reporting Channel

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

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.

Privacy Policy

A Privacy Policy to both external users and internal personnel. This policy details the company’s privacy commitments.