Controls

Control	Status
Information backup Backup copies of information, software and systems are maintained and regularly tested in accordance with the agreed topic-specific policy on backup.
Access control procedures established The company’s access control policy documents the requirements for the following access control functions: adding new users. modifying users; and/or removing an existing user’s access.
Intrusion detection system utilized The company uses an intrusion detection system to provide continuous monitoring of the company’s network and early detection of potential security breaches.
Network firewalls utilized The company uses firewalls and configures them to prevent unauthorized access.
Password policy enforced The company requires passwords for in-scope system components to be configured according to the company’s policy.
Network segmentation implemented The company’s network is segmented to prevent unauthorized access to customer data.
Network firewalls reviewed The company reviews its firewall rulesets at least annually. Required changes are tracked to completion.

Control	Status
Security awareness training implemented The company requires employees to complete security awareness training within thirty days of hire and at least annually thereafter.
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.
Access control procedures established The company’s access control policy documents the requirements for the following access control functions: adding new users; modifying users; and/or removing an existing user’s access.
Physical access processes established The company has processes in place for restricted acess
Risk management program established The company has a documented risk management program in place that includes guidance on the identification of potential threats, rating the significance of the risks associated with the identified threats, and mitigation strategies for those risks.
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.
Board oversight briefings conducted The company’s board of directors or a relevant subcommittee is briefed by senior management at least annually on the state of the company’s cybersecurity and privacy risk. The board provides feedback and direction to management as needed.
Risks assessments performed The company’s risk assessments are performed at least annually. As part of this process, threats and changes (environmental, regulatory, and technological) to service commitments are identified and the risks are formally assessed. The risk assessment includes a consideration of the potential for fraud and how fraud may impact the achievement of objectives.

Control	Status
Data encryption utilized The company’s datastores housing sensitive customer data are encrypted at rest.
Data transmission encrypted The company uses secure data transmission protocols to encrypt confidential and sensitive data when transmitted over public networks.
Vulnerability and system monitoring procedures established The company’s formal policies outline the requirements for the following functions related to IT / Engineering: vulnerability management. system monitoring.
Penetration testing performed The company’s penetration testing is performed at least annually. A remediation plan is developed, and changes are implemented to remediate vulnerabilities.
Application security requirements Information security requirements shall be identified, specified and approved when developing or acquiring applications.
Secure system architecture and engineering principles Principles for engineering secure systems shall be established, documented, maintained and applied to any information system development activities.
Secure coding Secure coding principles shall be applied to software development.
Security testing in development and acceptance Security testing processes shall be defined and implemented in the development life cycle.

Control	Status
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.
Appoint Data Protection Officer
Handling DSAR requests Define and document procedures for handling Data Subject Access Requests (DSAR).
Privacy impact assessment The company performs a privacy impact assessment for processing or changes to processing, which represent a high risk to the rights and freedoms of data subjects.