Situational Awareness For Incidents

Entity maintains a record of information security incidents, its investigation, and the response plan that was executed in accordance with the policy and procedure defined to report and manage incidents.

Vulnerability Remediation Process

Entity identifies vulnerabilities on the Company platform through the execution of regular vulnerability scans.

Centralized Management of Flaw Remediation Processes

Entity tracks all vulnerabilities and remediates them as per the policy and procedure defined to manage vulnerabilities.

Identity Validation

Entity ensures that logical access provisioning to critical systems requires approval from authorized personnel on an individual need or for a predefined role.

Termination of Employment

Entity ensures logical access that is no longer required in the event of termination is made inaccessible in a timely manner.

Testing for Reliability and Integrity

Entity tests backup information periodically to verify media reliability and information integrity.

Transfer of PII

Entity ensures appropriate procedures are in place to ensure compliance with regulatory requirements related to transfer of personal data outside of the region from which it is collected

Transmission Confidentiality

Entity has set up processes to utilize standard encryption methods, including HTTPS with the TLS algorithm, to keep transmitted data confidential.

Anomalous Behavior

Entity's infrastructure is configured to review and analyze audit events to detect anomalous or suspicious activity and threats

Conspicuous Link To Privacy Notice

Entity displays the most current information about its services on its website, which is accessible to its customers.

Secure system modification

Entity has procedures to govern changes to its operating environment.

Malicious Code Protection (Anti-Malware)

Where applicable, Entity ensures that endpoints with access to critical servers or data must be protected by malware-protection software.

Endpoint Security Validation

Entity has set up measures to perform security and privacy compliance checks on the software versions and patches of remote devices prior to the establishment of the internal connection.

Session Lock

Entity ensures that endpoints with access to critical servers or data are configured to auto-screen-lock after 15 minutes of inactivity.

Code of Business Conduct

Entity has a documented policy to define behavioral standards and acceptable business conduct.

Organizational Structure

Entity maintains an organizational structure to define authorities, facilitate information flow and establish responsibilities.

Roles & Responsibilities

Entity has established procedures to communicate with staff about their roles and responsibilities.

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.

New Hire Policy Acknowledgement

Entity has established procedures for new staff to acknowledge applicable company policies as a part of their onboarding.

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.

Periodic Policy Acknowledgement

Entity has established procedures for staff to acknowledge applicable company policies periodically.

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.

Segregates Roles and Responsibilities

Entity's Senior Management segregates responsibilities and duties across the organization to mitigate risks to the services provided to its customers.

Subpprocessor 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.

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.

New Hire Security & Privacy Training Records

Entity has established procedures for new staff to complete security and privacy literacy training as a part of their onboarding.

Periodic Security & Privacy Training Records

Entity documents, monitors, and retains individual training activities and records.

Updates During Installations / Removals

Entity periodically updates and reviews the inventory of systems as a part of installations, removals, and system updates.

Inventory of Endpoint Assets

Entity develops, documents, and maintains an inventory of organizational endpoint systems, including all necessary information to achieve accountability.