The company restricts privileged access to encryption keys to authorized users with a business need.

System access restricted to authorized access only.

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.

The company's production systems can only be remotely accessed by authorized employees possessing a valid multi-factor authentication (MFA) method.

The company's production systems can only be remotely accessed by authorized employees via an approved encrypted connection.

The company uses an intrusion detection system to provide continuous monitoring of the company's network and early detection of potential security breaches.

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.

The company requires contractor agreements to include a code of conduct or reference to the company code of conduct.

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.

The company requires contractors to sign a confidentiality agreement at the time of engagement.

The company requires visitors to sign-in, wear a visitor badge, and be escorted by an authorized employee when accessing the data center or secure areas.

The company performs control self-assessments at least annually to gain assurance that controls are in place and operating effectively. Corrective actions are taken based on relevant findings. If the company has committed to an SLA for a finding, the corrective action is completed within that SLA.

The company's penetration testing is performed at least annually. A remediation plan is developed and changes are implemented to remediate vulnerabilities in accordance with SLAs.

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.

The company has a documented Business Continuity/Disaster Recovery (BC/DR) plan and tests it at least annually.

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

The company restricts access to migrate changes to production to authorized personnel.

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.

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.

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

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.

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.

The company's data backup policy documents requirements for backup and recovery of customer data.

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

The company maintains an organizational chart that describes the organizational structure and reporting lines.

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.

The company's information security policies and procedures are documented and reviewed at least annually.

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.

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.

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

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

The company reviews access to the data centers at least annually.

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

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

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.

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.

The company has formal retention and disposal procedures in place to guide the secure retention and disposal of company and customer data.

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