CircleBlack, Inc. engages the following sub-processors to process customer personal data on behalf of CircleBlack as defined by our Data Processing Policy.
A Configuration and Asset Management Policy governs configurations for new sensitive systems
Secure Development Policy
A Secure Development Policy defines the requirements for secure software and system development and maintenance.
Segregation of Environments
Development, staging, and production environments are segregated.
Change Management Policy
A Change Management Policy governs the documenting, tracking, testing, and approving of system, network, security, and infrastructure changes.
Baseline Configurations
Baseline configurations and codebases for production infrastructure, systems, and applications are securely managed.
Production Data Use is Restricted
Production data is not used in the development and testing environments, unless required for debugging customer issues.
Software Change Testing
Software changes are tested prior to being deployed into production.
Availability
Testing the Business Continuity and Disaster Recovery Plan
The Business Continuity and Disaster Recovery Plan is periodically tested via tabletop exercises or equivalents. When necessary, Management makes changes to the Business Continuity and Disaster Recovery Plan based on the test results.
Business Continuity and Disaster Recovery Policy
Business Continuity and Disaster Recovery Policy governs required processes for restoring the service or supporting infrastructure after suffering a disaster or disruption.
High Availability Configuration
The system is configured for high availability to support continuous availability, when applicable.
Backup Restoration Testing
Backed-up data is restored to a non-production environment at least annually to validate the integrity of backups.
Organizational Management
Information Security Policy
An Information Security Policy establishes the security requirements for maintaining the security, confidentiality, integrity, and availability of applications, systems, infrastructure, and data.
Advisor Meetings on Security
Senior management and/or board of directors meets at least annually to review business goals, company initiatives, resource needs, risk management activities, and other internal/external matters. The information security team meets at least annually to discuss security risks, roles & responsibilities, controls, changes, audit results and/or other matters as necessary.
Cybersecurity Insurance
Cybersecurity insurance has been procured to help minimize the financial impact of cybersecurity loss events.
Code of Conduct
A Code of Conduct outlines ethical expectations, behavior standards, and ramifications of noncompliance.
Performance Reviews
Internal personnel are evaluated via a formal performance review at least annually
Organizational Chart
Management maintains a formal organizational chart to clearly identify positions of authority and the lines of communication, and publishes the organizational chart to internal personnel.
Performance Review Policy
A Performance Review Policy provides personnel context and transparency into their performance and career development processes.
Disciplinary Action
Personnel who violate information security policies are subject to disciplinary action and such disciplinary action is clearly documented in one or more policies.
Acceptable Use Policy
An Acceptable Use Policy defines standards for appropriate and secure use of company hardware and electronic systems including storage media, communication tools and internet access.
Roles and Responsibilities
Information security roles and responsibilities are outlined for personnel responsible for the security, availability, and confidentiality of the system.
Information Security Program Review
Management is responsible for the design, implementation, and management of the organization’s security policies and procedures. The policies and procedures are reviewed by management at least annually.
Internal Control Policy
An Internal Control Policy identifies how a system of controls should be maintained to safeguard assets, promote operational efficiency, and encourage adherence to prescribed managerial policies.
Confidentiality
Disposal of Customer Data
Upon customer request, Company requires that data that is no longer needed from databases and other file stores is removed in accordance with agreed-upon customer requirements.
Data Retention and Disposal Policy
A Data Retention and Disposal Policy specifies how customer data is to be retained and disposed of based on compliance requirements and contractual obligations.
Data Classification Policy
A Data Classification Policy details the security and handling protocols for sensitive data.
Vulnerability Management
Vulnerability and Patch Management Policy
A Vulnerability Management and Patch Management Policy outlines the processes to efficiently respond to identified vulnerabilities.
Third-Party Penetration Test
A 3rd party is engaged to conduct a network and application penetration test of the production environment at least annually. Critical and high-risk findings are tracked through resolution.
Incident Response
Lessons Learned
After any identified security incident has been resolved, management provides a "Lessons Learned" document to the team in order to continually improve security and operations.
Incident Response Plan
An Incident Response Plan outlines the process of identifying, prioritizing, communicating, assigning and tracking confirmed incidents through to resolution.
Tracking a Security Incident
Identified incidents are documented, tracked, and analyzed according to the Incident Response Plan.
Incident Response Plan Testing
The Incident Response Plan is periodically tested via tabletop exercises or equivalents. When necessary, Management makes changes to the Incident Response Plan based on the test results.
Risk Assessment
Risk Assessment and Treatment Policy
A Risk Assessment and Treatment Policy governs the process for conducting risk assessments to account for threats, vulnerabilities, likelihood, and impact with respect to assets, team members, customers, vendors, suppliers, and partners. Risk tolerance and strategies are also defined in the policy.
Risk Assessment
Formal risk assessments are performed, which includes the identification of relevant internal and external threats related to security, availability, confidentiality, and fraud, and an analysis of risks associated with those threats.
Risk Register
A risk register is maintained, which records the risk mitigation strategies for identified risks, and the development or modification of controls consistent with the risk mitigation strategy.
Vendor Risk Management Policy
A Vendor Risk Management Policy defines a framework for the onboarding and management of the vendor relationship lifecycle.
Network Security
Network Security Policy
A Network Security Policy identifies the requirements for protecting information and systems within and across networks.
Automated Alerting for Security Events
Alerting software is used to notify impacted teams of potential security events.
Access Security
Administrative Access is Restricted
Administrative access to production infrastructure is restricted based on the principle of least privilege.
Least Privilege in Use
Users are provisioned access to systems based on principle of least privilege.
User Access Reviews
System owners conduct scheduled user access reviews of production servers, databases, and applications to validate internal user access is commensurate with job responsibilities.
Asset Inventory
A list of system assets, components, and respective owners are maintained and reviewed at least annually
Access Control and Termination Policy
An Access Control and Termination Policy governs authentication and access to applicable systems, data, and networks.
Unique Access IDs
Personnel are assigned unique IDs to access sensitive systems, networks, and information
Removal of Access
Upon termination or when internal personnel no longer require access, system access is removed, as applicable.
Physical Security
Visitor Control
Production facilities require all visitors to formally sign-in, unless preauthorization for the visitor exists.
Physical Security Policy
A Physical Security Policy that details physical security requirements for the company facilities is in place.
Physical Security Safeguards
Physical protections are in place to safeguard facilities, infrastructure, systems, and data from external and internal threats
Physical Access Reviews
Processes are in place to periodically review physical access to ensure consistency with job responsibilities.
Physical Access Restrictions
Processes are in place to create, modify or remove physical access to facilities such as data centers, office spaces, and work areas based on the needs of such individual.
Communications
Description of Services
Descriptions of the company's services and systems are available to both internal personnel and external users.
Confidential Reporting Channel
A confidential reporting channel is made available to internal personnel and external parties to report security and other identified concerns.
Privacy Policy
A Privacy Policy to both external users and internal personnel. This policy details the company's privacy commitments.
Terms of Service
Terms of Service or the equivalent are published or shared to external users.
Communication of Critical Information
Critical information is communicated to external parties, as applicable.
Communication of Security Commitments
Security commitments and expectations are communicated to both internal personnel and external users via the company's website.
