Controls
Here are the controls implemented at Firsty.app to ensure compliance, as a part of our security program.
Product security (4)
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.
Vulnerability Remediation Process
Entity identifies vulnerabilities on the Company platform through the execution of regular vulnerability scans.
Centralized Management of Flaw Remediation Processes
Entity tracks all vulnerabilities and remediates them as per the policy and procedure defined to manage vulnerabilities.
Data security (11)
Identity 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.
Multi-factor Authentication
Entity requires that all staff members with access to any critical system be protected with a secure login mechanism such as Multifactor-authentication.
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.
Testing for Reliability and Integrity
Entity tests backup information periodically to verify media reliability and information integrity.
Transfer of PII
Entity ensures appropriate procedures are in place to ensure compliance with regulatory requirements related to transfer of personal data outside of the region from which it is collected
Inventory of Personal Data (PD)
Entity maintains an inventory of categories of personal information collected along with its usage, sources and specific purposes for collection as per regulatory requirements ("Record of Processing Activities") and reviews it on an annual basis
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
Network security (7)
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.
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.
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 (4)
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.
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.
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 (34)
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.
Automated Reporting
Entity has provided information to employees, via various Information Security Policies/procedures, on how to report failures, incidents, concerns, or other complaints related to the services or systems provided by the entity in the event there are problems.
Incident Reporting Assistance
Entity has provided information to customers on how to report failures, incidents, concerns, or other complaints related to the services or systems provided by the Entity in the event there are problems.
Risk Framing
Entity performs a formal risk assessment exercise annually, as per documented guidelines and procedures, to identify threats that could impair systems' security commitments and requirements.
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.
Fraud
Entity considers the potential for fraud when assessing risks. This is an entry in the risk matrix.
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.
Assigned Cybersecurity & Privacy Responsibilities
Entity's Senior Management assigns the role of Information Security Officer who is delegated to centrally manage, coordinate, develop, implement, and maintain an enterprise-wide cybersecurity and privacy program.
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.
Periodic Review & Update of Cybersecurity & Privacy Program
Entity's Senior Management reviews and approves the state of the Information Security program including policies, standards, and procedures, at planned intervals or if significant changes occur to ensure their continuing suitability, adequacy, and effectiveness.
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.
Subservice organization evaluation
Entity reviews and evaluates all subservice organizations periodically, to ensure commitments to Entity's customers can be met.
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
Testing
Entity has procedures to conduct regular tests and exercises that determine the effectiveness and the readiness to execute the contingency plan.
Chief Privacy Officer (CPO)
Entity appoints a Privacy Officer to assess and facilitate the entity's compliance with relevant regulatory requirements.
Privacy Act Statements
Entity includes Privacy Act statements on forms that collect information that will be maintained in a Privacy Act system of records, or provide Privacy Act statements on separate forms that can be retained by individuals.
Asset Ownership Assignment
Entity has set up mechanisms to assign and manage asset ownership responsibilities and establish a common understanding of asset protection requirements.
Data Governance
Entity maintains a list of legal, statutory, and regulatory requirements relevant to information security.
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.
Updates During Installations / Removals
Entity periodically updates and reviews the inventory of systems as a part of installations, removals, and system updates.
Inventory of Endpoint Assets
Entity develops, documents, and maintains an inventory of organizational endpoint systems, including all necessary information to achieve accountability.
