Controls
Here are the controls implemented at undefined to ensure compliance, as a part of our security program.
Data security (5)
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.
Inventory of Infrastructure Assets
Entity develops, documents, and maintains an inventory of organizational infrastructure systems, including all necessary information to achieve accountability.
Choice & Consent
Entity ensures regulatory requirements regarding user consent are met prior to processing personal data
Data Subject Access
Entity ensures that Subject Access Requests are being honored in accordance with the Privacy Policy
Network security (5)
Impact analysis
Entity systems generate information that is reviewed and evaluated to determine impacts on the functioning of internal controls.
Limit Network Connections
Entity ensures that the production databases access and Secure Shell access to infrastructure entities are protected from public internet access.
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
Data used in Testing
Entity ensures that customer data used in non-Production environments requires the same level of protection as the production environment.
App security (1)
Conspicuous Link To Privacy Notice
Entity displays the most current information about its services on its website, which is accessible to its customers.
Corporate security (26)
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.
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.
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.
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
Data Protection Officer (DPO)
Entity appoints a Data Protection Officer to assess and facilitate the entity's compliance with the provisions of the GDPR
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.
Infosec training ack
Entity requires that all staff members complete Information Security Awareness training annually.
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.
Inventory of Endpoint Assets
Entity develops, documents, and maintains an inventory of organizational endpoint systems, including all necessary information to achieve accountability.
