Software changes are tested prior to being deployed into production.
Segregation of Environments
Development, staging, and production environments are segregated.
Approval for System Changes
System changes are approved by at least 1 independent person prior to deployment into production.
Baseline Configurations
Baseline configurations and codebases for production infrastructure, systems, and applications are securely managed.
Availability
High Availability Configuration
The system is configured for high availability to support continuous availability, when applicable.
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.
Automated Backup Process
Full backups are performed and retained in accordance with the Business Continuity and Disaster Recovery Policy.
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.
Organizational Management
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.
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.
Security Awareness Training
Internal personnel complete annual training programs for information security to help them understand their obligations and responsibilities related to security.
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
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.
Performance Review Policy
A Performance Review Policy provides personnel context and transparency into their performance and career development processes.
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.
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.
Internal Control Monitoring
A continuous monitoring solution monitors internal controls used in the achievement of service commitments and system requirements.
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.
Confidentiality
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.
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.
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.
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.
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.
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.
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.
Network Security
Automated Alerting for Security Events
Alerting software is used to notify impacted teams of potential security events.
Logging and Monitoring for Threats
Logging and monitoring software is used to collect data from infrastructure to detect potential security threats, unusual system activity, and monitor system performance, as applicable.
Network Traffic Monitoring
Security tools are implemented to provide monitoring of network traffic to the production environment.
Access Security
Administrative Access is Restricted
Administrative access to production infrastructure is restricted based on the principle of least privilege.
Unique Access IDs
Personnel are assigned unique IDs to access sensitive systems, networks, and information
Least Privilege in Use
Users are provisioned access to systems based on principle of least privilege.
Encryption-in-Transit
Service data transmitted over the internet is encrypted-in-transit.
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 to Product is Restricted
Non-console access to production infrastructure is restricted to users with a unique SSH key or access key
Communications
Privacy Policy
A Privacy Policy to both external users and internal personnel. This policy details the company's privacy commitments.
Communication of Security Commitments
Security commitments and expectations are communicated to both internal personnel and external users via the company's website.
Description of Services
Descriptions of the company's services and systems are available to both internal personnel and 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.
Terms of Service
Terms of Service or the equivalent are published or shared to external users.
