- Code of Business Conduct
- Entity has a documented policy to define behavioral standards and acceptable business conduct.
- Competency Screening
- Entity has procedures to ensure that all security-related positions are staffed by qualified individuals who have the necessary skill set.
- Personnel Screening
- Entity has established procedures to perform security risk screening of individuals before authorizing access.
- Security & Privacy Awareness
- Entity provides information security and privacy training to staff that is relevant to their job function.
- Performance Review
- Entity requires that all employees in client serving, IT, Engineering, and Information Security roles are periodically evaluated regarding their job responsibilities.
- Automated Reporting
- Entity has provided information to employees, via various Information Security Policies/procedures, on how to report failures, incidents, concerns, or other complaints related to the services or systems provided by the entity in the event there are problems.
- Incident Reporting Assistance
- Entity has provided information to customers on how to report failures, incidents, concerns, or other complaints related to the services or systems provided by the Entity in the event there are problems.
- Risk Framing
- Entity performs a formal risk assessment exercise annually, as per documented guidelines and procedures, to identify threats that could impair systems' security commitments and requirements.
- Risk Assessment
- Each risk is assessed and given a risk score in relation to the likelihood of it occurring and the potential impact on the security, availability, and confidentiality of the Company platform. Risks are mapped to mitigating factors that address some or all of the risk.
- Fraud
- Entity considers the potential for fraud when assessing risks. This is an entry in the risk matrix.
- Third-Party Criticality Assessments
- Entity performs a formal vendor risk assessment exercise annually to identify vendors that are critical to the systems' security commitments and requirements.
- Assigned Cybersecurity & Privacy Responsibilities
- Entity's Senior Management assigns the role of Information Security Officer who is delegated to centrally manage, coordinate, develop, implement, and maintain an enterprise-wide cybersecurity and privacy program.
- Internal Audit using Sprinto
- Entity uses Sprinto, a continuous monitoring system, to track and report the health of the information security program to the Information Security Officer and other stakeholders.
- Periodic Review & Update of Cybersecurity & Privacy Program
- Entity's Senior Management reviews and approves the state of the Information Security program including policies, standards, and procedures, at planned intervals or if significant changes occur to ensure their continuing suitability, adequacy, and effectiveness.
- Management Review of Org Chart
- Entity's Senior Management reviews and approves the Organizational Chart for all employees annually.
- Management Review of Risks
- Entity's Senior Management reviews and approves the "Risk Assessment Report" annually.
- Management Review of Third-Party Risks
- Entity's Senior Management reviews and approves the "Vendor Risk Assessment Report" annually.
- Subservice organization evaluation
- Entity reviews and evaluates all subservice organizations periodically, to ensure commitments to Entity's customers can be met.
- Subprocessor Requirements
- Entity ensures that appropriate remediation measures are in place when personal data is shared with vendors as a part of its processing activities
- Data Protection Impact Assessment (DPIA)
- Entity conducts Data Protection Impact Assessments periodically in order to assess the regulatory risks associated with the processing of personal data
- Testing
- Entity has procedures to conduct regular tests and exercises that determine the effectiveness and the readiness to execute the contingency plan.
- Customer Obligations
- Entity maintains a list of all contractual obligations based on customer contracts.
- Retention of Policies
- Entity ensures that all policy documents are retained for at least (6) years from creation.
- Chief Privacy Officer (CPO)
- Entity appoints a Privacy Officer to assess and facilitate the entity's compliance with relevant regulatory requirements.
- Privacy Act Statements
- Entity includes Privacy Act statements on forms that collect information that will be maintained in a Privacy Act system of records, or provide Privacy Act statements on separate forms that can be retained by individuals.
- Asset Ownership Assignment
- Entity has set up mechanisms to assign and manage asset ownership responsibilities and establish a common understanding of asset protection requirements.
- Data Governance
- Entity maintains a list of legal, statutory, and regulatory requirements relevant to information security.
- Updates During Installations / Removals
- Entity periodically updates and reviews the inventory of systems as a part of installations, removals, and system updates.