Controls
Here are the controls implemented at Facctum to ensure compliance, as a part of our security program.
Product security (3)
Production System User Review
Entity's Infosec officer reviews and approves the list of people with access to production console annually
Situational Awareness For Incidents
Entity maintains a record of information security incidents, its investigation, and the response plan that was executed in accordance with the policy and procedure defined to report and manage incidents.
Log Priviledged Operations
The Entity ensures that critical Cloud Service Providers can log privileged operations executed by the Entity. The Entity also defines if the logging capabilities provided by the CSPs are adequate or if additional logging solutions should be implemented.
Data security (11)
Identify Validation
Entity ensures that logical access provisioning to critical systems requires approval from authorized personnel on an individual need or for a predefined role.
Termination of Employment
Entity ensures logical access that is no longer required in the event of termination is made inaccessible in a timely manner.
Production Databases Access Restriction
Entity ensures that access to the production databases is restricted to only those individuals who require such access to perform their job functions.
User Privileges Reviews
Entity's Senior Management or the Information Security Officer periodically reviews and ensures that access to the critical systems is restricted to only those individuals who require such access to perform their job functions.
User Access Reviews
Entity's Senior Management or the Information Security Officer periodically reviews and ensures that administrative access to the critical systems is restricted to only those individuals who require such access to perform their job functions.
Encrypting Data At Rest
Entity has set up cryptographic mechanisms to encrypt all production database[s] that store customer data at rest.
Inventory of Infrastructure Assets
Entity develops, documents, and maintains an inventory of organizational infrastructure systems, including all necessary information to achieve accountability.
Data Backups
Entity backs up relevant user and system data regularly to meet recovery time and recovery point objectives and verifies the integrity of these backups.
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
Physical Security
Facctum is hosted in AWS which maintains robust and industry leading physical security of their data centres. All physical security requirements are taken care of by AWS. Facctum ensures AWS's SOC 2 report is reviewed periodically to ensure AWS implements and complies with physical security controls.
Network security (9)
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.
External System Connections
Every Production host is protected by a firewall with a deny-by-default rule. Deny by default rule set is a default on the Entity's cloud provider.
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
Capacity & Performance Management
Entity has set up methods to continuously monitor critical assets to generate capacity alerts to ensure optimal performance, meet future capacity requirements, and protect against denial-of-service attacks.
Data used in Testing
Entity ensures that customer data used in non-Production environments requires the same level of protection as the production environment.
Cloud Provider Requirements
Entity ensures that critical Cloud Service Providers can meet the defined requirements related to network segregation and tenant separation.
Centralized Collection of Security Event Logs
Entity's infrastructure is configured to generate audit events for actions of interest related to security for all critical systems.
App security (6)
Conspicuous Link To Privacy Notice
Entity displays the most current information about its services on its website, which is accessible to its customers.
Secure system modification
Entity has procedures to govern changes to its operating environment.
Approval of Changes
Entity has established procedures for approval when implementing changes to the operating environment.
Testing of changes
Entity has procedures to test and validate changes before they are implemented in the operating environment.
Unauthorized Activities
Entity uses Sprinto, a continuous monitoring system, to alert the security team to update the access levels of team members whose roles have changed.
Regression Testing
Company does application regression testing to validate key processing for the application during the change management process.
Endpoint security (5)
Malicious Code Protection (Anti-Malware)
Where applicable, Entity ensures that endpoints with access to critical servers or data must be protected by malware-protection software.
Full Device or Container-based Encryption
Where applicable, Entity ensures that endpoints with access to critical servers or data must be encrypted to protect from unauthorized access.
Endpoint Security Validation
Entity has set up measures to perform security and privacy compliance checks on the software versions and patches of remote devices prior to the establishment of the internal connection.
Session Lock
Entity ensures that endpoints with access to critical servers or data are configured to auto-screen-lock after 15 minutes of inactivity.
Endpoints Encryption
Entity requires that all critical endpoints are encrypted to protect them from unauthorized access.
Corporate security (31)
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.
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.
Third-Party Criticality Assessments
Entity performs a formal vendor risk assessment exercise annually to identify vendors that are critical to the systems' security commitments and requirements.
Internal Audit using Sprinto
Entity uses Sprinto, a continuous monitoring system, to track and report the health of the information security program to the Information Security Officer and other stakeholders.
Management Review of Org Chart
Entity's Senior Management reviews and approves the Organizational Chart for all employees annually.
Management Review of Risks
Entity's Senior Management reviews and approves the "Risk Assessment Report" annually.
Management Review of Third-Party Risks
Entity's Senior Management reviews and approves the "Vendor Risk Assessment Report" annually.
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.
Subprocessor Requirements
Entity ensures that appropriate remediation measures are in place when personal data is shared with vendors as a part of its processing activities
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
EU Representative
Entity appoints a EU Representative to serve as a point of contact between EU authorities, data subjects and the organization
Testing
Entity has procedures to conduct regular tests and exercises that determine the effectiveness and the readiness to execute the contingency plan.
Customer Obligations
Entity maintains a list of all contractual obligations based on customer contracts.
Retention of Policies
Entity ensures that all policy documents are retained for at least (6) years from creation.
UK Representative
Entity appoints a UK Representative to serve as a point of contact between UK authorities, data subjects and the organization.
Asset Ownership Assignment
Entity has set up mechanisms to assign and manage asset ownership responsibilities and establish a common understanding of asset protection requirements.
Incident Management by Service Providers
The Entity ensures that its incident response procedures are updated to reflect the usage of cloud service providers. Entity has identified how to report incidents to Cloud Service Providers, as well as how to respond to an incident reported by the Cloud Service Providers.
Validate Security Controls
The Entity assesses and validates the controls implemented by critical Cloud Service Providers for the protection of data collected and stored by the Cloud Service Provider.
Review of Third-Party Services
The Entity requests an external security certification of an independent audit report of the implemented and claimed information security controls for all critical Cloud Service Providers.
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.
