Identify 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.

Multi-factor Authentication

Entity requires that all staff members with access to any critical system be protected with a secure login mechanism such as Multifactor-authentication.

Encrypting Data At Rest

Entity has set up cryptographic mechanisms to encrypt all production database[s] that store customer data at rest.

Data Backups

Entity backs up relevant user and system data regularly to meet recovery time and recovery point objectives and verifies the integrity of these backups.

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

External System Connections

Every Production host is protected by a firewall with a deny-by-default rule. Deny by default rule set is a default on the Entity's cloud provider.

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

Centralized Collection of Security Event Logs

Entity's infrastructure is configured to generate audit events for actions of interest related to security for all critical systems.

Conspicuous Link To Privacy Notice

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

Approval of Changes

Entity has established procedures for approval when implementing changes to the 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.

Full Device or Container-based Encryption

Where applicable, Entity ensures that endpoints with access to critical servers or data must be encrypted to protect from unauthorized access.

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.

Endpoints Encryption

Entity requires that all critical endpoints are encrypted to protect them from unauthorized access.

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.

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.

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.

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

EU Representative

Entity appoints a EU Representative to serve as a point of contact between EU authorities, data subjects and the organization

Testing

Entity has procedures to conduct regular tests and exercises that determine the effectiveness and the readiness to execute the contingency plan.

Chief Privacy Officer (CPO)

Entity appoints a Privacy Officer to assess and facilitate the entity's compliance with relevant regulatory requirements.

Asset Ownership Assignment

Entity has set up mechanisms to assign and manage asset ownership responsibilities and establish a common understanding of asset protection requirements.

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.