2. ORGANISATIONAL SECURITY

Asset disposal procedures utilised
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.

Production inventory maintained
The company maintains a formal inventory of production system assets.

Portable media encrypted
The company encrypts portable and removable media devices when used.

Anti-malware technology utilised
The company deploys anti-malware technology to environments commonly susceptible to malicious attacks and configures this to be updated routinely, logged, and installed on all relevant systems.

Employee background checks performed
The company performs background checks on new employees.

Code of Conduct acknowledged by contractors
The company requires contractor agreements to include a code of conduct or reference to the company code of conduct.

Code of Conduct acknowledged by employees and enforced
The company requires employees to acknowledge a code of conduct at the time of hire. Employees who violate the code of conduct are subject to disciplinary actions in accordance with a disciplinary policy.

Confidentiality Agreement acknowledged by contractors
The company requires contractors to sign a confidentiality agreement at the time of engagement.

Confidentiality Agreement acknowledged by employees
The company requires employees to sign a confidentiality agreement during onboarding.

Performance evaluations conducted
The company managers are required to complete performance evaluations for direct reports at least annually.

Password policy enforced
The company requires passwords for in-scope system components to be configured according to the company's policy.

MDM system utilised
The company has a mobile device management (MDM) system in place to centrally manage mobile devices supporting the service.

Visitor procedures enforced
The company requires visitors to sign-in, wear a visitor badge, and be escorted by an authorised employee when accessing the data centre or secure areas.

Security awareness training implemented
The company requires employees to complete security awareness training within thirty days of hire and at least annually thereafter.

3. INTERNAL SECURITY PROCEDURES

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.

Cybersecurity insurance maintained
The company maintains cybersecurity insurance to mitigate the financial impact of business disruptions.

Configuration management system established
The company has a configuration management procedure in place to ensure that system configurations are deployed consistently throughout the environment.

Change management procedures enforced
The company requires changes to software and infrastructure components of the service to be authorised, formally documented, tested, reviewed, and approved prior to being implemented in the production environment.

Production deployment access restricted
The company restricts access to migrate changes to production to authorised personnel.

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.

Whistleblower policy established
The company has established a formalised whistleblower policy, and an anonymous communication channel is in place for users to report potential issues or fraud concerns.

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.

Board charter documented
The company's board of directors has a documented charter that outlines its oversight responsibilities for internal control.

Board expertise developed
The company's board members have sufficient expertise to oversee management's ability to design, implement and operate information security controls. The board engages third-party information security experts and consultants as needed.

Board meetings conducted
The company's board of directors meets at least annually and maintains formal meeting minutes. The board includes directors that are independent of the company.

System changes externally communicated
The company notifies customers of critical system changes that may affect their processing.

Management roles and responsibilities defined
The company management has established defined roles and responsibilities to oversee the design and implementation of information security controls.

Organisation structure documented
The company maintains an organisational chart that describes the organisational structure and reporting lines.

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.

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.

System changes communicated
The company communicates system changes to authorized internal users.

Access reviews conducted
The company conducts access reviews at least quarterly for the in-scope system components to help ensure that access is restricted appropriately. Required changes are tracked to completion.

Access requests required
The company ensures that user access to in-scope system components is based on job role and function or requires a documented access request form and manager approval prior to access being provisioned.

Incident response policies established
The company has security and privacy incident response policies and procedures that are documented and communicated to authorised users.

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.

Physical access processes established
The company has processes in place for granting, changing, and terminating physical access to company data centres based on an authorization from control owners.

Data centre access reviewed
The company reviews access to the data centres at least annually.

Company commitments externally communicated
The company's security commitments are communicated to customers in Master Service Agreements (MSA) or Terms of Service (TOS).

External support resources available
The company provides guidelines and technical support resources relating to system operations to customers.

Service description communicated
The company provides a description of its products and services to internal and external users.

Risk assessment objectives specified
The company specifies its objectives to enable the identification and assessment of risk related to the objectives.

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.

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.

Vendor management program established
The company has a vendor management program in place. Components of this program include:
critical third-party vendor inventory;
vendor's security and privacy requirements; and
review of critical third-party vendors at least annually.

Vulnerabilities scanned and remediated
Host-based vulnerability scans are performed at least quarterly on all external-facing systems. Critical and high vulnerabilities are tracked to remediation.

4. DATA & PRIVACY

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.

Customer data deleted upon leaving
The company purges or removes customer data containing confidential information from the application environment, in accordance with best practices, when customers leave the service.

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 authorised personnel.