Controls
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Infrastructure Security
| Control | Status |
|---|---|
| Service infrastructure
maintained
The company has infrastructure supporting the service patched as a part of routine maintenance and as a result of identified vulnerabilities to help ensure that servers supporting the service are hardened against security threats. |
|
| Production data backups
conducted
The company performs periodic backups for production data. Data is backed up to a different location than the production system. |
|
| Database replication
utilized
The company's databases are replicated to a secondary cloud in real-time. Alerts are configured to notify administrators if replication fails. |
|
| Remote access MFA
enforced
The company's production systems can only be remotely accessed by authorized employees possessing a valid multi-factor authentication (MFA) method. |
|
| Unique production database
authentication enforced
The company requires authentication to production datastores to use authorized secure authentication mechanisms, such as unique SSH key. |
|
| Remote access encrypted
enforced
The company's production systems can only be remotely accessed by authorized employees via an approved encrypted connection. |
|
| Production data
segmented
The company prohibits confidential or sensitive customer data, by policy, from being used or stored in non-production systems/environments. |
|
| Network segmentation
implemented
The company's network is segmented to prevent unauthorized access to customer data. |
|
| Unique network system
authentication enforced
The company requires authentication to the "production network" to use unique usernames and passwords or authorized Secure Socket Shell (SSH) keys. |
|
| Segregation in virtual computing
environments
A cloud service customer's virtual environment running on a cloud service should be protected from other cloud service customers and unauthorized persons. |
|
| Production multi-availability
zones established
The company has a multi-location strategy for production environments employed to permit the resumption of operations at other company cloud locations in the event of loss of a facility. |
Organizational Security
| Control | Status |
|---|---|
| Employee background checks
performed
The company performs background checks on new employees. |
|
| Security awareness training
implemented
The company requires employees to complete security awareness training within thirty days of hire and annually thereafter. |
|
| Confidentiality Agreement
acknowledged by contractors
The company requires contractors to sign a confidentiality agreement at the time of engagement. |
|
| Production inventory
maintained
The company maintains a formal inventory of production system assets. |
|
| Asset disposal procedures
utilized
The company has electronic media containing confidential information purged or destroyed in accordance with best practices, and certificates of destruction are issued for each device destroyed. |
|
| Whistleblower policy
established
The company has established a formalized whistleblower policy, and an anonymous communication channel is in place for users to report potential issues or fraud concerns. |
Internal Security Procedures
| Control | Status |
|---|---|
| Continuity and disaster recovery
plans tested
The company has a documented business continuity/disaster recovery (BC/DR) plan and tests it at least annually. |
|
| Incident response plan
tested
The company tests their incident response plan at least annually. |
|
| Backup processes
established
The company's data backup policy documents requirements for backup and recovery of customer data. |
|
| Vendor management program
established
The company has a vendor management program in place. Components of this program include:
|
|
| Incident response policies
established
The company has security and privacy incident response policies and procedures that are documented and communicated to authorized users. |
|
| Configuration management system
established
The company has a configuration management procedure in place to ensure that system configurations are deployed consistently throughout the environment. |
|
| Management roles and
responsibilities defined
The company management has established defined roles and responsibilities to oversee the design and implementation of information security controls. |
|
| Service description
communicated
The company provides a description of its products and services to internal and external users. |
|
| Security policies established and
reviewed
The company's information security policies and procedures are documented and reviewed at least annually. |
|
| Support system available
The company has an external-facing support system in place that allows users to report system information on failures, incidents, concerns, and other complaints to appropriate personnel. |
|
| Roles and responsibilities
specified
Roles and responsibilities for the design, development, implementation, operation, maintenance, and monitoring of information security controls are formally assigned in job descriptions and/or the Roles and Responsibilities policy. |
|
| Third-party agreements
established
The company has written agreements in place with vendors and related third-parties. These agreements include confidentiality and privacy commitments applicable to that entity. |
|
| Incident management procedures
followed
The company's security and privacy incidents are logged, tracked, resolved, and communicated to affected or relevant parties by management according to the company's security incident response policy and procedures. |
|
| Development lifecycle
established
The company has a formal systems development life cycle (SDLC) methodology in place that governs the development, acquisition, implementation, changes (including emergency changes), and maintenance of information systems and related technology requirements. |
|
| Continuity and Disaster Recovery
plans established
The company has Business Continuity and Disaster Recovery Plans in place that outline communication plans in order to maintain information security continuity in the event of the unavailability of key personnel. |
AI Security & Compliance
| Control | Status |
|---|---|
| AI system impact
assessment
The organization shall perform AI system impact assessments according to 6.1.4 at planned intervals or when significant changes are proposed to occur. The organization shall retain documented information of the results of all AI system impact assessments. |
|
| Determining the scope of the AI
management system
The organization shall determine the boundaries and applicability of the AI management system to establish its scope. The scope shall be available as documented information. |
|
| AI objectives and
planning
The organization shall establish AI objectives at relevant functions and levels. The AI objectives shall be consistent with the AI policy, be measurable (if practicable), take into account applicable requirements, be monitored, communicated, and updated as appropriate. |
|
| Monitoring, measurement,
analysis
The organization shall determine what needs to be monitored and measured, the methods for monitoring, measurement, analysis and evaluation, when they shall be performed, and when results shall be analysed and evaluated. The organization shall evaluate the performance and effectiveness of the AI management system. |
|
| General - Audit
The organization shall conduct internal audits at planned intervals to provide information on whether the AI management system conforms to the organization's own requirements and the requirements of this document, and is effectively implemented and maintained. |
|
| Nonconformity and corrective
action
When a nonconformity occurs, the organization shall react to it, evaluate the need for action to eliminate the cause(s), implement any action needed, review the effectiveness of any corrective action taken, and make changes to the AI management system if necessary. |
|
| AI policy
The organization should document a policy for the development or use of AI systems. |
|
| External reporting
The organization should provide capabilities for interested parties to report adverse impacts of the system. |
|
| Communication of
incidents
The organization should determine and document a plan for communicating incidents to users of the system. |
|
| Information for interested
parties
The organization should determine and document its obligations to reporting information about the AI system to interested parties. |
|
| Processes for responsible use of
AI
The organization should define and document the processes for the responsible use of AI systems. |
|
| Objectives for responsible use of
AI
The organization should identify and document objectives to guide the responsible use of AI systems. |
|
| Intended use of the AI
system
The organization should ensure that the AI system is used according to the intended uses of the AI system and its accompanying documentation. |
|
| Understanding the organization
and its context
The organization shall determine external and internal issues that are relevant to its purpose and that affect its ability to achieve the intended result(s) of its AI management system. |
|
| Understanding the needs and
expectations of interested
The organization shall determine the interested parties that are relevant to the AI management system, their relevant requirements, and which of these requirements will be addressed through the AI management system. |
|
| AI management system
The organization shall establish, implement, maintain, continually improve and document an AI management system, including the processes needed and their interactions, in accordance with the requirements of this document. |
|
| Leadership and
commitment
Top management shall demonstrate leadership and commitment with respect to the AI management system by ensuring that the AI policy and AI objectives are established, ensuring the integration of the AI management system requirements into the organization's business processes, and ensuring that the resources needed are available. |
|
| AI policy
Top management shall establish an AI policy that is appropriate to the purpose of the organization, provides a framework for setting AI objectives, includes a commitment to meet applicable requirements, and includes a commitment to continual improvement of the AI management system. |
|
| Roles, responsibilities and
authorities
Top management shall ensure that the responsibilities and authorities for relevant roles are assigned and communicated within the organization. |
|
| Awareness
Persons doing work under the organization's control shall be aware of the AI policy, their contribution to the effectiveness of the AI management system, and the implications of not conforming with the AI management system requirements. |
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| Communication
The organization shall determine the internal and external communications relevant to the AI management system including what it will communicate, when to communicate, with whom to communicate, and how to communicate. |
|
| General - AI management
The organization's AI management system shall include documented information required by this document and documented information determined by the organization as being necessary for the effectiveness of the AI management system. |
|
| Creating and updating
When creating and updating documented information, the organization shall ensure appropriate identification and description, format and media, and review and approval for suitability and adequacy. |
|
| AI risk treatment
The organization shall implement the AI risk treatment plan according to 6.1.3 and verify its effectiveness. The organization shall retain documented information of the results of all AI risk treatments. |
|
| Internal audit programme
The organization shall plan, establish, implement and maintain an audit programme, including the frequency, methods, responsibilities, planning requirements and reporting. |
|
| General Management
Review
Top management shall review the organization's AI management system, at planned intervals, to ensure its continuing suitability, adequacy and effectiveness. |
|
| Management review inputs
The management review shall include the status of actions from previous management reviews, changes in external and internal issues, information on the AI management system performance, and opportunities for continual improvement. |
|
| Management review
results
The results of the management review shall include decisions related to continual improvement opportunities and any need for changes to the AI management system. |
|
| Alignment with other
organizational policies
The organization should determine where other policies can be affected by or apply to the organization's objectives with respect to AI systems. |
|
| Review of the AI policy
The AI policy should be reviewed at planned intervals or additionally as needed to ensure its continuing suitability, adequacy and effectiveness. |
|
| Reporting of concerns
The organization should define and put in place a process to report concerns about the organization's role with respect to an AI system throughout its life cycle. |
|
| Control of documented
information
Documented information required by the AI management system shall be controlled to ensure it is available and suitable for use where and when needed, and it is adequately protected. |
|
| General
When planning for the AI management system, the organization shall consider the issues referred to in 4.1 and the requirements referred to in 4.2 and determine the risks and opportunities that need to be addressed. |
|
| AI risk assessment
The organization shall define and establish an AI risk assessment process. The organization shall perform AI risk assessments at planned intervals or when significant changes are proposed or occur. |
|
| AI system deployment
The organization should document a deployment plan and ensure that appropriate requirements are met prior to deployment. |
|
| AI system recording of event
logs
The organization should determine at which phases of the AI system life cycle record keeping of event logs should be enabled, but at the minimum when the AI system is in use. |
|
| Quality of data for AI
systems
The organization should define and document requirements for data quality and ensure that data used to develop and operate the AI system meet those requirements. |
|
| System documentation and
information
The organization should determine and provide the necessary information to users of the system. |
Product Security
| Control | Status |
|---|---|
| Vulnerability and system
monitoring procedures established
Host-based vulnerability scans are performed at least quarterly on all external-facing systems. Critical and high vulnerabilities are tracked to remediation. The company's formal policies outline requirements for system monitoring. |
Data and Privacy
| Control | Status |
|---|---|
| Privacy policy
established
The company has a privacy policy in place that documents and clearly communicates to individuals the extent of personal information collected, the company's obligations, the individual's rights to access, update, or erase their personal information, and an up-to-date point of contact where individuals can direct their questions, requests or concerns. |
|
| Data retention procedures
established
The company has formal retention and disposal procedures in place to guide the secure retention and disposal of company and customer data. |
|
| Privacy compliant procedures
established
The company has documented processes and procedures in place to ensure that any privacy-related complaints are addressed, and the resolution is documented in the company's designated tracking system and communicated to the individual. |
|
| Privacy policy available
The company has a privacy policy available to customers, employees, and/or relevant third parties who need them before and/or at the time information is collected from the individual. |
|
| Privacy policy reviewed
The company reviews the privacy policy as needed or when changes occur and updates it accordingly to ensure it is consistent with the applicable laws, regulations, and appropriate standards. |
|
| Privacy policy
maintained
The company has established a privacy policy that uses plain and simple language, is clearly dated, and provides information related to the company's practices and purposes for collecting, processing, handling, and disclosing personal information including:
|
|
| Data classification policy
established
The company has a data classification policy in place to help ensure that confidential data is properly secured and restricted to authorized personnel. |
|
| Data deletion requests
handled
The company validates deletion requests and once confirmed are flagged and the requested information is deleted, in accordance with applicable laws and regulations. |
|
| Continuity and Disaster Recovery
plans established
The company has Business Continuity and Disaster Recovery Plans in place that outline communication plans in order to maintain information security continuity in the event of the unavailability of key personnel. |
|
| Continuity and Disaster Recovery
plans tested annually
The company has a documented business continuity/disaster recovery (BC/DR) plan and tests it annually. |
|
| Limit collection
The company limits collection of PII to the minimum that is necessary for its purposes. |
|
| Appoint EU
representative
The company shall appoint an EU based representative. |
|
| Customer data deleted upon
leave
The company purges or removes customer data containing confidential information from the application environment, in accordance with best practices, when customers leave the service. |
|
| PII transmission controls for
processor
The company encrypts PII in transit. |
|
| PII transmission controls for
controller
The company implements technical controls to ensure data transmitted to third parties reaches its destination. |