create-filegrc 0.6.5 → 0.7.0
This diff represents the content of publicly available package versions that have been released to one of the supported registries. The information contained in this diff is provided for informational purposes only and reflects changes between package versions as they appear in their respective public registries.
- package/package.json +1 -1
- package/src/defaults.js +60 -121
- package/src/index.js +12 -11
- package/template/AGENTS.md +8 -3
- package/template/README.md +9 -5
- package/template/data/AGENTS.md +6 -3
- package/template/data/appointments/appointment-policy-owner.json +1 -1
- package/template/data/documents/document-data-retention-schedule.json +1 -1
- package/template/data/documents/document-data-retention-schedule.md +7 -9
- package/template/data/documents/{document-incident-response-plan.json → document-security-incident-recovery-plan.json} +5 -6
- package/template/data/documents/document-security-incident-recovery-plan.md +79 -0
- package/template/data/obligations/AGENTS.md +2 -1
- package/template/data/policies/AGENTS.md +18 -8
- package/template/data/policies/policy-information-security.json +1 -7
- package/template/data/policies/policy-information-security.md +50 -185
- package/template/data/training/training-security-awareness.json +1 -4
- package/template/data/training/training-security-awareness.md +16 -2
- package/template/package.json +1 -1
- package/template/data/documents/document-business-continuity-disaster-recovery.json +0 -29
- package/template/data/documents/document-business-continuity-disaster-recovery.md +0 -192
- package/template/data/documents/document-contractor-policy-acknowledgement.json +0 -20
- package/template/data/documents/document-contractor-policy-acknowledgement.md +0 -24
- package/template/data/documents/document-contractor-training-acknowledgement.json +0 -23
- package/template/data/documents/document-contractor-training-acknowledgement.md +0 -20
- package/template/data/documents/document-employee-handbook-acknowledgement.json +0 -20
- package/template/data/documents/document-employee-handbook-acknowledgement.md +0 -19
- package/template/data/documents/document-employee-policy-acknowledgement.json +0 -20
- package/template/data/documents/document-employee-policy-acknowledgement.md +0 -24
- package/template/data/documents/document-employee-training-acknowledgement.json +0 -23
- package/template/data/documents/document-employee-training-acknowledgement.md +0 -20
- package/template/data/documents/document-incident-response-plan.md +0 -138
- package/template/data/policies/policy-anti-bribery-corruption.json +0 -19
- package/template/data/policies/policy-anti-bribery-corruption.md +0 -87
- package/template/data/policies/policy-clear-desk-screen.json +0 -18
- package/template/data/policies/policy-clear-desk-screen.md +0 -49
- package/template/data/policies/policy-data-protection-handling.json +0 -22
- package/template/data/policies/policy-data-protection-handling.md +0 -130
- package/template/data/policies/policy-employee-handbook.json +0 -21
- package/template/data/policies/policy-employee-handbook.md +0 -161
- package/template/data/policies/policy-mobile-computing-communications.json +0 -18
- package/template/data/policies/policy-mobile-computing-communications.md +0 -74
- package/template/data/training/training-anti-bribery-high-risk-roles.json +0 -16
- package/template/data/training/training-anti-bribery-high-risk-roles.md +0 -19
- package/template/data/training/training-privileged-sensitive-roles.json +0 -20
- package/template/data/training/training-privileged-sensitive-roles.md +0 -20
- package/template/data/training/training-secure-development.json +0 -19
- package/template/data/training/training-secure-development.md +0 -22
|
@@ -1,233 +1,98 @@
|
|
|
1
1
|
# Information Security Policy
|
|
2
2
|
|
|
3
|
-
## Purpose
|
|
3
|
+
## Purpose and scope
|
|
4
4
|
|
|
5
|
-
This
|
|
5
|
+
This Policy defines the information security requirements for {{company_name}} and its in-scope services. It applies to employees, contractors, authorized users, Systems, Components, devices, code, data, facilities, and Vendors used to provide or protect those services. Vendor requirements apply through approved contracts and oversight.
|
|
6
6
|
|
|
7
|
-
|
|
7
|
+
A Policy says what the company commits to do by the date it takes effect. Approval means the company accepts those commitments. It does not prove the work is done. Controls and operating records describe how the company meets them and provide the proof. FileGRC does not infer technical implementation from this prose. Configuration facts belong in Controls, Components, Systems, governed schedules, and Evidence.
|
|
8
8
|
|
|
9
|
-
|
|
9
|
+
## Integrity, accountability, and reporting
|
|
10
10
|
|
|
11
|
-
|
|
12
|
-
- Company-managed and personally owned devices used for company work
|
|
13
|
-
- Applications, infrastructure, repositories, networks, data, and business processes managed by or for {{company_name}}
|
|
14
|
-
- Vendors that store, process, transmit, secure, or recover company or customer data
|
|
11
|
+
Everyone in scope must act honestly, protect company and customer information, follow approved security processes, disclose conflicts that could affect security decisions, and preserve accurate records. Fraud, deliberate control bypass, false evidence, credential sharing, unauthorized access, concealment of a security event, and retaliation for a good-faith report are prohibited.
|
|
15
12
|
|
|
16
|
-
|
|
13
|
+
Suspected security events, control failures, fraud, or policy violations must be reported promptly through the primary route at {{security_contact_email}} or the usable alternate route documented in the Security Incident and Recovery Plan. A person may use the alternate route when the primary route is unavailable, compromised, or involved in the concern. Management investigates credible reports, limits disclosure to people who need the information, preserves relevant records, and records corrective action.
|
|
17
14
|
|
|
18
|
-
|
|
15
|
+
Management evaluates conduct against these requirements and addresses violations consistently. Contractors and Vendor personnel follow equivalent requirements when their work or access can affect the in-scope service.
|
|
19
16
|
|
|
20
|
-
|
|
17
|
+
## Governance and risk management
|
|
21
18
|
|
|
22
|
-
The
|
|
19
|
+
The current Policy Owner maintains this Policy, the risk program, Controls, governed plans, Exceptions, and improvement work. System and process owners approve access, maintain safeguards, keep inventories and recovery facts current, and resolve findings. An independent reviewer who is separate from the Policy owner approves the Policy and challenges management's assessment of Control operation.
|
|
23
20
|
|
|
24
|
-
|
|
25
|
-
- Reports material security matters to company leadership.
|
|
26
|
-
- Coordinates incidents, exercises, reviews, and audit work.
|
|
27
|
-
- Approves security exceptions or obtains the required approval.
|
|
21
|
+
Management reviews the security program on its approved governed schedule and after material change. Reviews cover objectives, service commitments, fraud and misconduct risk, threats, system and Vendor changes, incidents, findings, Exceptions, overdue work, and Control results. Risks receive an owner, response, target date, approval when accepted, and a review date. The Risk Assessment Control and Obligations record the actual method and cadence.
|
|
28
22
|
|
|
29
|
-
|
|
23
|
+
## Workforce security and acceptable use
|
|
30
24
|
|
|
31
|
-
|
|
25
|
+
Workers must accept applicable confidentiality, acceptable-use, and security responsibilities before receiving access. They receive security training on the approved onboarding and recurring schedules. Role-specific instruction is assigned when a person's access or duties require it.
|
|
32
26
|
|
|
33
|
-
|
|
27
|
+
Users must:
|
|
34
28
|
|
|
35
|
-
|
|
29
|
+
- Use approved identities, devices, applications, storage, messaging, meeting, and transfer services.
|
|
30
|
+
- Protect credentials, authentication devices, company equipment, customer information, and security records.
|
|
31
|
+
- Keep company data out of personal accounts and unapproved applications.
|
|
32
|
+
- Lock unattended devices and protect papers, screens, and conversations from unauthorized access.
|
|
33
|
+
- Report lost, stolen, compromised, or unexpectedly reconfigured devices promptly.
|
|
34
|
+
- Return company property and stop using company access when employment, services, or the business need ends.
|
|
36
35
|
|
|
37
|
-
|
|
36
|
+
Managers notify access administrators of starts, role changes, and departures. The Access Control and Offboarding Controls and their event windows record the approved timing, evidence, and escalation rules.
|
|
38
37
|
|
|
39
|
-
|
|
38
|
+
## Assets, data, and retention
|
|
40
39
|
|
|
41
|
-
|
|
40
|
+
{{company_name}} inventories important Systems, Components, devices, software, service accounts, Vendors, and data stores. Records identify an owner, purpose, lifecycle state, classification, dependencies, and recovery needs where relevant.
|
|
42
41
|
|
|
43
|
-
|
|
42
|
+
Data owners classify information as Public, Internal, Confidential, or Restricted and approve its collection, use, access, storage, sharing, retention, and disposal. When classification is uncertain, users protect the data as Confidential until an owner decides. Collect and retain only information needed for an approved purpose.
|
|
44
43
|
|
|
45
|
-
|
|
44
|
+
Confidential and Restricted data must use approved Systems, encryption in transit over untrusted networks, encryption at rest, least-privilege access, and protected transfer methods. Credentials, private keys, tokens, and recovery codes belong in approved secrets-management Systems and must not appear in source files, tickets, chat, logs, or FileGRC records.
|
|
46
45
|
|
|
47
|
-
|
|
46
|
+
Production data must not enter development or test Systems unless an owner approves the use and equivalent protection. Public links and exports of Confidential or Restricted data require explicit authorization. Legal holds and active investigations suspend normal disposal for affected records.
|
|
48
47
|
|
|
49
|
-
|
|
48
|
+
The Data Retention Schedule records the approved period and disposal method for important in-scope record classes. Systems, Controls, and Components record the actual implementation. Disposal must address active copies, local copies, media, backups, and Vendor-held copies where practical, with dated proof when the Control requires it.
|
|
50
49
|
|
|
51
|
-
##
|
|
50
|
+
## Identity and access
|
|
52
51
|
|
|
53
|
-
|
|
52
|
+
Access requires a documented business need, owner approval, a unique identity, and least privilege. Authorized administrators provision, change, and remove access. Shared accounts require a documented technical need, named owner, restricted use, and logging.
|
|
54
53
|
|
|
55
|
-
|
|
54
|
+
Multi-factor authentication is required for administrative, production, source-control, email, identity, and Confidential or Restricted data access. When a System cannot support MFA, management must approve a time-bound Exception with risk assessment, compensating Controls, an accountable owner, and a review or expiration date.
|
|
56
55
|
|
|
57
|
-
|
|
56
|
+
Authentication settings, privileged roles, service-account ownership, credential protection, access-review populations, review cadence, and removal deadlines belong in the applicable Controls, Components, Systems, and Obligations.
|
|
58
57
|
|
|
59
|
-
##
|
|
58
|
+
## Endpoint, remote work, and physical protection
|
|
60
59
|
|
|
61
|
-
|
|
60
|
+
Devices used for company work must run supported software, install security updates, require authentication, lock automatically, use encryption and host protections appropriate to the platform, and permit remote removal when company-managed and technically supported. Users must not disable management, security, logging, encryption, or remote-removal safeguards.
|
|
62
61
|
|
|
63
|
-
|
|
64
|
-
- Multi-factor authentication is required for administrative access, source control, production systems, email, identity systems, and systems containing Confidential or Restricted data when the system supports it.
|
|
65
|
-
- Passwords must be unique, stored in an approved password manager, and never shared in plaintext.
|
|
66
|
-
- Systems must enforce approved password, authentication, and lockout settings appropriate to their risk and technical capability.
|
|
67
|
-
- Only authorized administrators may change password or lockout settings.
|
|
68
|
-
- Default credentials must be changed or disabled before use.
|
|
69
|
-
- Privileged access must use separate administrative roles or accounts where practical.
|
|
70
|
-
- Access requests and material changes require approval from the manager or system owner.
|
|
71
|
-
- Owners review privileged and production access at least quarterly and other important access at least annually.
|
|
72
|
-
- Dormant, expired, or unneeded access must be removed.
|
|
62
|
+
Platforms such as macOS may provide continuous native malware and application protection without a user-triggered full scan. The Endpoint Protection Control describes the continuous protections in use and the periodic process that verifies configuration, update, and compliance state. A scheduled scan applies only when the selected technology and risk decision require one.
|
|
73
63
|
|
|
74
|
-
|
|
64
|
+
Personal-device access requires prior approval, registration, verified safeguards, defined company-data boundaries, and exit steps. Remote workers must protect devices, paper, screens, calls, home networks, and travel locations. Public or untrusted networks require approved encrypted access. Physical access to nonpublic work areas and protected assets is limited to authorized people.
|
|
75
65
|
|
|
76
|
-
##
|
|
66
|
+
## Infrastructure and secure change
|
|
77
67
|
|
|
78
|
-
|
|
68
|
+
Owners restrict network paths and management interfaces to approved business needs, use encrypted administrative protocols, disable unnecessary defaults and services, protect remote production access, and maintain secure configuration baselines. Deviations require review and, when material, an approved Exception.
|
|
79
69
|
|
|
80
|
-
|
|
81
|
-
- Encrypt Confidential and Restricted data in transit over untrusted networks.
|
|
82
|
-
- Encrypt Confidential and Restricted data at rest in approved systems and on devices.
|
|
83
|
-
- Keep production data out of development and test systems unless approved and equally protected.
|
|
84
|
-
- Restrict data exports and public links.
|
|
85
|
-
- Store credentials and cryptographic keys in approved protected systems.
|
|
70
|
+
Software and infrastructure changes must be recorded, tested, approved, deployed through an authorized process, and recoverable in proportion to risk. Use independent pre-deployment review when practical. When team size or urgency makes that separation impossible, record a risk-appropriate compensating or post-deployment review. Use a time-bound Exception when the remaining departure is material.
|
|
86
71
|
|
|
87
|
-
|
|
72
|
+
Development and deployment Controls address protected branches, controlled credentials, dependency and secret detection, input and authorization checks, production-data restrictions, security testing, emergency change review, and rollback.
|
|
88
73
|
|
|
89
|
-
|
|
74
|
+
## Vulnerability, logging, and monitoring
|
|
90
75
|
|
|
91
|
-
-
|
|
92
|
-
- Use full-disk encryption when supported.
|
|
93
|
-
- Lock automatically after no more than 15 minutes of inactivity.
|
|
94
|
-
- Require authentication after locking or restarting.
|
|
95
|
-
- Install security updates within the vulnerability-remediation targets in this policy unless an approved exception applies.
|
|
96
|
-
- Use malware protection and host firewall controls appropriate to the platform.
|
|
97
|
-
- Permit remote lock or wipe when company-managed and supported.
|
|
76
|
+
{{company_name}} monitors trusted sources for vulnerabilities affecting in-scope Systems. Management selects scanning coverage, penetration-testing applicability, remediation targets, and review cadence from exposure, change, customer commitments, and risk. The applicable Controls and Obligations record those choices. A missed target requires documented exposure, compensating Controls, a revised date, and risk approval or Exception.
|
|
98
77
|
|
|
99
|
-
|
|
78
|
+
Important Systems record and protect the security and operational events needed to investigate misuse and operate the service. Logs use synchronized time, restrict alteration and access, and avoid unnecessary secrets or personal data. Each System's retention period belongs in the approved Data Retention Schedule.
|
|
100
79
|
|
|
101
|
-
|
|
80
|
+
Owners define risk-based alerts, review paths, thresholds, and response ownership in Controls, Components, Systems, and governed schedules. Representative alert paths are tested from generation through acknowledgement, escalation, and fallback on the approved schedule and after a material path change.
|
|
102
81
|
|
|
103
|
-
##
|
|
82
|
+
## Incident response, recovery, and continuity
|
|
104
83
|
|
|
105
|
-
|
|
84
|
+
The Security Incident and Recovery Plan defines reporting, alternate access, severity, declaration, roles, containment, evidence handling, notification assessment, communication, recovery, closure, and exercises. Suspected unauthorized access, malware, data loss, credential exposure, or security-Control failure must be reported promptly.
|
|
106
85
|
|
|
107
|
-
-
|
|
108
|
-
- Separate production from development, test, and general user environments where practical.
|
|
109
|
-
- Use encrypted administrative protocols and restrict management interfaces.
|
|
110
|
-
- Review firewall rules and other material network access at least annually.
|
|
111
|
-
- Disable unused services, ports, accounts, and default configurations.
|
|
112
|
-
- Protect cloud and infrastructure management interfaces with multi-factor authentication.
|
|
113
|
-
- Record infrastructure configuration in reviewed code or another controlled system where practical.
|
|
114
|
-
|
|
115
|
-
Important systems use documented secure configuration baselines. Owners review deviations, remove unnecessary defaults, and track approved exceptions. A material change to system behavior, security, availability, or customer commitments must include an appropriate communication plan.
|
|
116
|
-
|
|
117
|
-
Wireless networks used for company work must use current encryption and authentication. Public or untrusted networks require an approved protected connection.
|
|
118
|
-
|
|
119
|
-
Remote production access is limited to approved users, requires multi-factor authentication, and must originate from a trusted network or use an approved encrypted connection. Users on public or otherwise untrusted networks must use the additional safeguards approved for remote access.
|
|
120
|
-
|
|
121
|
-
## Secure development and change management
|
|
122
|
-
|
|
123
|
-
Software and infrastructure changes must be recorded, reviewed, tested, approved, and recoverable in proportion to risk. The record should identify the reason, author, reviewer, test result, deployment, and rollback method.
|
|
124
|
-
|
|
125
|
-
Production changes should be made through an approved deployment process. Emergency changes may use an expedited review, but they must be documented and reviewed after service is stable.
|
|
126
|
-
|
|
127
|
-
Development practices include:
|
|
128
|
-
|
|
129
|
-
- Peer review for material code and infrastructure changes
|
|
130
|
-
- Automated or manual security tests suited to the change
|
|
131
|
-
- Separation of production duties where practical
|
|
132
|
-
- Protected branches and controlled deployment credentials
|
|
133
|
-
- Dependency and secret scanning where supported
|
|
134
|
-
- No production secrets in source code, test fixtures, or logs
|
|
135
|
-
- Validation of input and authorization at trust boundaries
|
|
136
|
-
|
|
137
|
-
## Vulnerability and patch management
|
|
138
|
-
|
|
139
|
-
{{company_name}} monitors trusted sources for vulnerabilities affecting in-scope systems. It scans internet-facing and production systems at least quarterly and after a material change when practical. An independent penetration test is performed at least annually for the external attack surface of the in-scope service.
|
|
140
|
-
|
|
141
|
-
The security owner assigns the final severity using a recognized technical scoring method together with exploit availability, reachability, affected privileges, data classification, exposure, and business impact. The remediation clock starts when {{company_name}} confirms the finding and assigns an owner. A later severity change must record the reason and date.
|
|
142
|
-
|
|
143
|
-
Confirmed vulnerabilities are assigned a target based on their final severity:
|
|
144
|
-
|
|
145
|
-
| Severity | Target remediation time |
|
|
146
|
-
| --- | --- |
|
|
147
|
-
| Critical | 7 days |
|
|
148
|
-
| High | 14 days |
|
|
149
|
-
| Medium | 30 days |
|
|
150
|
-
| Low | 90 days |
|
|
151
|
-
|
|
152
|
-
If remediation cannot meet the target, the owner must document the reason, exposure, compensating controls, revised date, and risk approval.
|
|
153
|
-
|
|
154
|
-
## Logging and monitoring
|
|
155
|
-
|
|
156
|
-
Important systems must record security-relevant activity needed to investigate misuse and support operations. Depending on the system, this includes:
|
|
157
|
-
|
|
158
|
-
- Authentication success and failure
|
|
159
|
-
- Privileged and administrative actions
|
|
160
|
-
- Access-control and identity changes
|
|
161
|
-
- Production deployments and configuration changes
|
|
162
|
-
- Access to Restricted data
|
|
163
|
-
- Security control failures and alerts
|
|
164
|
-
|
|
165
|
-
Logs must use synchronized time, restrict alteration and access, and avoid unnecessary secrets or personal data. Security logs for important systems are retained for at least 12 months unless a longer contractual or legal period applies.
|
|
166
|
-
|
|
167
|
-
Owners review or alert on events based on risk. Alerts must have an assigned response path. The annual incident response exercise tests at least one representative alert from generation through acknowledgement, escalation, and fallback. A material change to an alert or response path receives an appropriate test within 30 days, or the owner records why no test applies.
|
|
168
|
-
|
|
169
|
-
Owners review important log output and access to logs at least quarterly. They also monitor process health, network use, processor load, memory use, disk capacity, and other indicators needed to detect service degradation. Important systems have documented alert thresholds and response ownership.
|
|
170
|
-
|
|
171
|
-
## Incident response
|
|
172
|
-
|
|
173
|
-
Anyone who suspects unauthorized access, malware, data loss, credential exposure, security-control failure, or other security harm must report it immediately to {{security_contact_email}}.
|
|
174
|
-
|
|
175
|
-
The Incident Response Plan defines severity, materiality, declaration, roles, escalation, evidence handling, notification assessment, recovery, and closure. The incident lead will:
|
|
176
|
-
|
|
177
|
-
1. Record and assess the report.
|
|
178
|
-
2. Contain the event and preserve evidence.
|
|
179
|
-
3. Remove the cause and recover affected service.
|
|
180
|
-
4. Coordinate legal, contractual, privacy, insurance, customer, and regulatory review.
|
|
181
|
-
5. Communicate through authorized channels.
|
|
182
|
-
6. Document the outcome, lessons, and follow-up work.
|
|
183
|
-
|
|
184
|
-
The incident lead assigns a severity based on actual or likely harm. High-severity incidents receive immediate leadership and technical escalation, frequent status updates, and review of external notification duties. Lower-severity events still receive an owner, documented resolution, and escalation if impact grows.
|
|
185
|
-
|
|
186
|
-
{{company_name}} tests its incident process and a representative alert path at least annually. Material incidents receive a retrospective within one week and tracked corrective actions.
|
|
187
|
-
|
|
188
|
-
## Business continuity, backup, and recovery
|
|
189
|
-
|
|
190
|
-
Important systems have recovery objectives based on business impact. Unless a system has an approved objective that requires stronger safeguards, important production data is backed up at least daily and retained for at least 30 days. Backups must restrict access, report failures, and be restored in a test at least annually.
|
|
191
|
-
|
|
192
|
-
The Business Continuity and Disaster Recovery Plan defines activation, response, communication, and recovery duties. Continuity and recovery exercises are recorded with results and follow-up work.
|
|
86
|
+
Each important System records approved continuity objectives, dependencies, a backup or alternate recovery approach, monitoring, and restore-validation needs. The applicable Controls, Components, Systems, and Obligations record the actual frequency, retention, procedures, access owners, and test schedule. Management records incident and recovery exercises, results, findings, and follow-up work.
|
|
193
87
|
|
|
194
88
|
## Vendor security
|
|
195
89
|
|
|
196
|
-
Vendors receive
|
|
197
|
-
|
|
198
|
-
Contracts with vendors that handle Confidential or Restricted data should address:
|
|
199
|
-
|
|
200
|
-
- Permitted data use and confidentiality
|
|
201
|
-
- Security safeguards
|
|
202
|
-
- Incident notification
|
|
203
|
-
- Subprocessor controls
|
|
204
|
-
- Service continuity
|
|
205
|
-
- Data return and deletion
|
|
206
|
-
- Audit or assurance rights when warranted
|
|
207
|
-
|
|
208
|
-
Critical and high-risk vendors are reviewed at least annually. A material service change, data-use change, or vendor incident triggers a reassessment within 30 days. The owner updates the vendor, risk, contract, data-use, and follow-up records affected by the reassessment.
|
|
209
|
-
|
|
210
|
-
## Physical security
|
|
211
|
-
|
|
212
|
-
Company facilities and equipment must be protected according to their risk. Access to nonpublic work areas is limited to authorized people. Visitors must be controlled and accompanied where sensitive work or information is present.
|
|
213
|
-
|
|
214
|
-
Remote workers must follow the Clear Desk and Clear Screen Policy and protect devices and conversations from unauthorized viewing or access.
|
|
215
|
-
|
|
216
|
-
## Compliance, exceptions, and enforcement
|
|
217
|
-
|
|
218
|
-
{{company_name}} identifies security, privacy, contractual, and regulatory obligations that apply to its work and maps them to responsible controls. Evidence should be retained according to the applicable audit and record-retention period.
|
|
219
|
-
|
|
220
|
-
An exception to this policy requires:
|
|
90
|
+
New Vendors receive a risk-based security review and suitable contractual safeguards before access to Confidential or Restricted data. Reviews consider service scope, data, access, assurance, recovery, incident history, dependencies, and contract terms.
|
|
221
91
|
|
|
222
|
-
-
|
|
223
|
-
- A risk assessment
|
|
224
|
-
- Compensating controls
|
|
225
|
-
- An accountable owner
|
|
226
|
-
- An expiration or review date
|
|
227
|
-
- Approval from the current Policy Owner or a person with greater authority
|
|
92
|
+
For a Vendor already in use when this Policy becomes effective, the owner records a transition review and deadline or an approved risk acceptance. Policy adoption does not imply that a historical pre-access review occurred. Vendor monitoring cadence and change-driven reassessment windows belong in the Vendor Controls and Obligations.
|
|
228
93
|
|
|
229
|
-
|
|
94
|
+
## Exceptions, enforcement, and review
|
|
230
95
|
|
|
231
|
-
|
|
96
|
+
An Exception requires a specific scope and reason, risk assessment, compensating Controls, accountable owner, approval, and expiration or review date. Violations may result in access removal, corrective action, contract remedies, or other action allowed by law and agreement.
|
|
232
97
|
|
|
233
|
-
The
|
|
98
|
+
The Policy Owner reviews this Policy on the approved governed schedule and after a material change to services, Systems, risks, commitments, or obligations. The independent reviewer approves each revised version. Git history and FileGRC records preserve the reviewed content, approval, activation, and later changes.
|
|
@@ -13,10 +13,7 @@
|
|
|
13
13
|
"assignmentTrigger": "onboarding",
|
|
14
14
|
"completionWindowDays": 30,
|
|
15
15
|
"policyIds": [
|
|
16
|
-
"policy-
|
|
17
|
-
"policy-data-protection-handling",
|
|
18
|
-
"policy-information-security",
|
|
19
|
-
"policy-mobile-computing-communications"
|
|
16
|
+
"policy-information-security"
|
|
20
17
|
],
|
|
21
18
|
"controlIds": [
|
|
22
19
|
"control-security-communication",
|
|
@@ -92,7 +92,7 @@ Use a company-managed device for company work unless another arrangement is appr
|
|
|
92
92
|
- Keep the operating system, browser, applications, and security tools supported and updated.
|
|
93
93
|
- Enable automatic security updates when approved.
|
|
94
94
|
- Keep disk encryption, screen locking, malware protection, firewall, logging, and device-management controls enabled.
|
|
95
|
-
- Lock the screen whenever the device is unattended. Company devices lock
|
|
95
|
+
- Lock the screen whenever the device is unattended. Company-managed devices use the automatic-lock setting recorded in the applicable Endpoint Control, Component, or System.
|
|
96
96
|
- Use a standard user account for routine work. Use administrative access only when authorized and needed.
|
|
97
97
|
- Install applications and browser extensions only through an approved process.
|
|
98
98
|
- Do not connect unapproved removable media.
|
|
@@ -126,7 +126,7 @@ A secure connection protects data in transit. It does not prove that a site, sen
|
|
|
126
126
|
|
|
127
127
|
## Data handling
|
|
128
128
|
|
|
129
|
-
Follow the
|
|
129
|
+
Follow the Information Security Policy and use the highest applicable classification.
|
|
130
130
|
|
|
131
131
|
- Collect, access, and retain only the data needed for approved work.
|
|
132
132
|
- Store company data only in approved systems.
|
|
@@ -136,6 +136,20 @@ Follow the Data Protection and Handling Policy and use the highest applicable cl
|
|
|
136
136
|
- Dispose of paper, devices, and media through an approved process.
|
|
137
137
|
- Report unintended disclosure, excessive access, improper disposal, or an unexpected public link.
|
|
138
138
|
|
|
139
|
+
## Building and changing systems
|
|
140
|
+
|
|
141
|
+
People who design, build, review, deploy, or administer company Systems must:
|
|
142
|
+
|
|
143
|
+
- Keep code, infrastructure changes, and production access in approved repositories and workflows.
|
|
144
|
+
- Protect branches and deployments with the reviews, tests, and approvals required by the Change Management Control.
|
|
145
|
+
- Keep secrets out of source code, build output, tickets, chat, and logs.
|
|
146
|
+
- Validate input, authorization, error handling, and sensitive-data use at trust boundaries.
|
|
147
|
+
- Review new and changed dependencies, resolve security findings within the approved risk targets, and record Exceptions when a target cannot be met.
|
|
148
|
+
- Separate development and production duties when practical. Record a compensating or post-deployment review when team size or urgency prevents independent pre-deployment review.
|
|
149
|
+
- Record emergency changes, limit their scope, validate the result, and complete the required follow-up review.
|
|
150
|
+
|
|
151
|
+
The applicable Controls, Components, Systems, and governed schedules record the actual tools, settings, approval paths, and evidence.
|
|
152
|
+
|
|
139
153
|
## Physical security and clear workspaces
|
|
140
154
|
|
|
141
155
|
- Use your own badge, key, and authentication factor. Do not allow another person to follow you into a restricted area without authorization.
|
package/template/package.json
CHANGED
|
@@ -1,29 +0,0 @@
|
|
|
1
|
-
{
|
|
2
|
-
"id": "document-business-continuity-disaster-recovery",
|
|
3
|
-
"type": "document",
|
|
4
|
-
"title": "Business Continuity and Disaster Recovery Plan",
|
|
5
|
-
"status": "draft",
|
|
6
|
-
"documentKind": "plan",
|
|
7
|
-
"ownerIds": [
|
|
8
|
-
"appointment-policy-owner"
|
|
9
|
-
],
|
|
10
|
-
"version": "1.0",
|
|
11
|
-
"audience": [
|
|
12
|
-
"employees",
|
|
13
|
-
"contractors"
|
|
14
|
-
],
|
|
15
|
-
"acknowledgementRequired": true,
|
|
16
|
-
"controlIds": [
|
|
17
|
-
"control-policy-management",
|
|
18
|
-
"control-incident-exercise",
|
|
19
|
-
"control-backup-restoration",
|
|
20
|
-
"control-continuity-exercise"
|
|
21
|
-
],
|
|
22
|
-
"relatedDocumentIds": [
|
|
23
|
-
"document-incident-response-plan"
|
|
24
|
-
],
|
|
25
|
-
"evidenceIds": [],
|
|
26
|
-
"classificationId": "internal",
|
|
27
|
-
"proposedEffectiveOn": "{{effective_date}}",
|
|
28
|
-
"programRole": "required"
|
|
29
|
-
}
|
|
@@ -1,192 +0,0 @@
|
|
|
1
|
-
# Business Continuity and Disaster Recovery Plan
|
|
2
|
-
|
|
3
|
-
## Purpose
|
|
4
|
-
|
|
5
|
-
This plan describes how {{company_name}} will respond to a disruption, continue its most important work, recover systems and data, and return to normal operations.
|
|
6
|
-
|
|
7
|
-
## Scope
|
|
8
|
-
|
|
9
|
-
This plan applies to the people, systems, facilities, vendors, and business processes needed to deliver {{company_name}} products and services. It covers events that materially affect availability, including:
|
|
10
|
-
|
|
11
|
-
- Cloud or hosting failures
|
|
12
|
-
- Software defects and failed deployments
|
|
13
|
-
- Cybersecurity incidents
|
|
14
|
-
- Loss of data or access to data
|
|
15
|
-
- Utility, network, or workplace outages
|
|
16
|
-
- Unavailability of a key vendor or workforce member
|
|
17
|
-
- Natural disasters and other regional events
|
|
18
|
-
|
|
19
|
-
Security incidents follow the incident response requirements in the Information Security Policy. A single event may activate both processes.
|
|
20
|
-
|
|
21
|
-
## Objectives
|
|
22
|
-
|
|
23
|
-
During a disruption, {{company_name}} will:
|
|
24
|
-
|
|
25
|
-
1. Protect people.
|
|
26
|
-
2. Limit harm to customers, systems, and data.
|
|
27
|
-
3. Maintain or restore critical work within approved recovery targets.
|
|
28
|
-
4. Communicate accurate information to affected parties.
|
|
29
|
-
5. Preserve evidence needed for investigation and review.
|
|
30
|
-
6. Record lessons and assign follow-up work.
|
|
31
|
-
|
|
32
|
-
## Roles
|
|
33
|
-
|
|
34
|
-
These names describe recovery functions, not required job titles or separate Appointments. The current Policy Owner performs them by default and management delegates a function only when that matches how the organization actually recovers its services.
|
|
35
|
-
|
|
36
|
-
### Policy owner
|
|
37
|
-
|
|
38
|
-
The current Policy Owner owns this plan and keeps it current. The Policy Owner may delegate response duties but remains accountable for the plan.
|
|
39
|
-
|
|
40
|
-
### Security and risk oversight
|
|
41
|
-
|
|
42
|
-
The security and risk oversight group reviews the plan, material disruptions, annual exercise results, and unresolved continuity risks. Its review is recorded in formal meeting minutes.
|
|
43
|
-
|
|
44
|
-
### Incident lead
|
|
45
|
-
|
|
46
|
-
The incident lead coordinates the response, assigns work, maintains the incident record, approves status changes, and decides when normal operations have resumed. The policy owner acts as incident lead until another qualified person is assigned.
|
|
47
|
-
|
|
48
|
-
### Executive sponsor
|
|
49
|
-
|
|
50
|
-
The executive sponsor makes business-priority decisions that exceed the incident lead's authority and approves material external communications.
|
|
51
|
-
|
|
52
|
-
### Technical recovery lead
|
|
53
|
-
|
|
54
|
-
The technical recovery lead coordinates system restoration, data recovery, technical validation, and vendor escalation.
|
|
55
|
-
|
|
56
|
-
### System and process owners
|
|
57
|
-
|
|
58
|
-
Owners assess impact, recover their systems or processes, validate restored service, and keep recovery instructions current.
|
|
59
|
-
|
|
60
|
-
### Continuity team
|
|
61
|
-
|
|
62
|
-
The continuity team carries out assigned business, technical, customer, vendor, and communications tasks. Membership may change with the event.
|
|
63
|
-
|
|
64
|
-
### Workforce members
|
|
65
|
-
|
|
66
|
-
Employees and contractors must report suspected disruptions promptly, follow response instructions, and avoid uncoordinated changes that could make recovery harder.
|
|
67
|
-
|
|
68
|
-
## Activation
|
|
69
|
-
|
|
70
|
-
Anyone may report a disruption to {{security_contact_email}}. The policy owner or incident lead activates this plan when normal operating procedures cannot restore an important service within its expected time or when coordinated business action is needed.
|
|
71
|
-
|
|
72
|
-
The incident lead records:
|
|
73
|
-
|
|
74
|
-
- What happened and when it was detected
|
|
75
|
-
- Affected services, data, customers, locations, and vendors
|
|
76
|
-
- Current business and security impact
|
|
77
|
-
- Response owner and participants
|
|
78
|
-
- Decisions, actions, communications, and timestamps
|
|
79
|
-
- Recovery status and remaining risks
|
|
80
|
-
|
|
81
|
-
## Recovery priorities and objectives
|
|
82
|
-
|
|
83
|
-
System and process owners define recovery objectives from business impact rather than assigning a universal target to a severity label. Each important system or process records:
|
|
84
|
-
|
|
85
|
-
- Its business priority and maximum tolerable downtime
|
|
86
|
-
- Its recovery time objective
|
|
87
|
-
- Its recovery point objective
|
|
88
|
-
- The people, systems, vendors, facilities, and data it depends on
|
|
89
|
-
- Minimum staffing, access, and communications needed for recovery
|
|
90
|
-
- Available manual workarounds or alternate services
|
|
91
|
-
- The owner responsible for validating recovery
|
|
92
|
-
|
|
93
|
-
The incident lead normally restores Critical work before High, Medium, and Low work. The incident lead may change that order to protect people, contain security harm, preserve data integrity, meet a legal or contractual deadline, or unblock another recovery.
|
|
94
|
-
|
|
95
|
-
The approved objective recorded for each affected system or process is the recovery target. If no approved objective exists, the incident lead sets and records an interim target based on business impact and dependencies. The owner must formalize the missing objective as follow-up work.
|
|
96
|
-
|
|
97
|
-
Recovery timing starts when the disruption began when that time is known. If it is not known, the incident record uses the earliest confirmed time and states that limitation.
|
|
98
|
-
|
|
99
|
-
## Response and recovery
|
|
100
|
-
|
|
101
|
-
The incident lead coordinates these steps in the order appropriate to the event:
|
|
102
|
-
|
|
103
|
-
1. Confirm the event and protect people.
|
|
104
|
-
2. Identify affected systems, data, processes, and dependencies.
|
|
105
|
-
3. Contain the cause and prevent additional harm.
|
|
106
|
-
4. Activate manual procedures, alternate services, or remote work when available.
|
|
107
|
-
5. Recover systems and data in priority order.
|
|
108
|
-
6. Validate security, integrity, and expected operation before resuming normal use.
|
|
109
|
-
7. Communicate status to affected parties.
|
|
110
|
-
8. Monitor the recovered service for recurrence.
|
|
111
|
-
9. Close the event after owners accept the restored state and remaining risk.
|
|
112
|
-
|
|
113
|
-
Responders must record material decisions and actions as they occur. Emergency changes must be reviewed through the normal change process after service is stable.
|
|
114
|
-
|
|
115
|
-
## Communication
|
|
116
|
-
|
|
117
|
-
The incident lead chooses the audience, channel, and frequency based on impact.
|
|
118
|
-
|
|
119
|
-
Internal updates should state what is known, what remains uncertain, who is responsible, and when the next update is expected. Only authorized people may communicate externally on behalf of {{company_name}}.
|
|
120
|
-
|
|
121
|
-
When customers are affected, the incident lead identifies the applicable contractual commitments, legal duties, and approved communications plan, then records the audience, owner, and deadline for the initial update. When no fixed deadline applies, {{company_name}} communicates promptly after confirming enough facts to provide an accurate and useful update.
|
|
122
|
-
|
|
123
|
-
Customer, regulator, insurer, or law-enforcement notifications must be reviewed by the people responsible for legal, contractual, privacy, and communications obligations. Notifications must meet applicable deadlines and avoid unsupported claims.
|
|
124
|
-
|
|
125
|
-
Employees receive the disruption status, work instructions, available recovery estimate, and next expected update through one or more approved channels. The continuity team keeps an alternate contact method for use when ordinary company communications are unavailable.
|
|
126
|
-
|
|
127
|
-
Owners of affected vendor relationships contact the vendor through the fastest available approved channel, coordinate restoration steps, and record material commitments and updates.
|
|
128
|
-
|
|
129
|
-
## Data backup and restoration
|
|
130
|
-
|
|
131
|
-
Owners of systems that store important data must:
|
|
132
|
-
|
|
133
|
-
- Define backup scope and frequency that meet the system recovery point objective.
|
|
134
|
-
- Protect backups from unauthorized access and changes.
|
|
135
|
-
- Keep recovery access separate from ordinary user access where practical.
|
|
136
|
-
- Monitor backup jobs and address failures.
|
|
137
|
-
- Test restoration at least annually.
|
|
138
|
-
- Record the test date, scope, result, evidence, and follow-up work.
|
|
139
|
-
|
|
140
|
-
A successful backup job is not proof of recoverability. Restore tests must confirm that data can be retrieved and used.
|
|
141
|
-
|
|
142
|
-
During recovery, people take priority over data or equipment. When it is safe to proceed, authorized responders assess the integrity and usability of available electronic and paper records. They may restore approved backups, use intact replicas, rebuild from reviewed configuration or source, use an approved alternate service, or recover other safeguarded copies. The restored environment must receive the same backup and security protections required for normal operation.
|
|
143
|
-
|
|
144
|
-
## Specific disruption procedures
|
|
145
|
-
|
|
146
|
-
### Hosted service or vendor outage
|
|
147
|
-
|
|
148
|
-
The owner confirms vendor status, opens a support case when appropriate, assesses alternate service options, and tracks contractual notification and recovery commitments.
|
|
149
|
-
|
|
150
|
-
### Failed deployment or software defect
|
|
151
|
-
|
|
152
|
-
The owner stops further deployment, rolls back or applies an approved corrective change, validates data integrity, and monitors the restored version.
|
|
153
|
-
|
|
154
|
-
### Loss of workplace access
|
|
155
|
-
|
|
156
|
-
Workers use approved remote-work procedures or an approved alternate location. The incident lead confirms access to required systems, contact methods, and records.
|
|
157
|
-
|
|
158
|
-
### Loss of a key workforce member
|
|
159
|
-
|
|
160
|
-
The responsible manager reassigns urgent duties, obtains access through approved recovery procedures, and records any missing documentation or concentration risk as follow-up work.
|
|
161
|
-
|
|
162
|
-
### Cybersecurity event
|
|
163
|
-
|
|
164
|
-
Responders protect evidence and coordinate containment with recovery. Systems must not return to service until the incident lead and system owner accept the security risk.
|
|
165
|
-
|
|
166
|
-
## Plan access
|
|
167
|
-
|
|
168
|
-
The current plan is stored in this repository. The policy owner must ensure that people who may lead recovery can access an approved copy when the primary systems or identity provider are unavailable. Emergency contacts and access instructions must be stored in an approved protected location and must not be committed to this repository if they contain secrets.
|
|
169
|
-
|
|
170
|
-
The policy owner reviews the emergency contact list at least annually and after a material personnel or vendor change.
|
|
171
|
-
|
|
172
|
-
Employees receive this plan after approval and after a material update. Suppliers, customers, and other parties receive the parts needed to coordinate recovery when appropriate.
|
|
173
|
-
|
|
174
|
-
## Exercises and maintenance
|
|
175
|
-
|
|
176
|
-
{{company_name}} tests this plan at least annually and after a material change when the existing test no longer represents the environment. An exercise may be a tabletop scenario, technical recovery test, communication test, or combined exercise.
|
|
177
|
-
|
|
178
|
-
Each exercise records:
|
|
179
|
-
|
|
180
|
-
- Scenario and scope
|
|
181
|
-
- Participants and roles
|
|
182
|
-
- Systems and processes tested
|
|
183
|
-
- Recovery objectives evaluated
|
|
184
|
-
- Expected and actual results
|
|
185
|
-
- Evidence
|
|
186
|
-
- Findings, owners, and due dates
|
|
187
|
-
|
|
188
|
-
The security and risk oversight group reviews the annual exercise and records its conclusions in meeting minutes.
|
|
189
|
-
|
|
190
|
-
After this plan is activated for a real disruption, the incident lead completes a root-cause and lessons review within one week. The review identifies follow-up work, owners, and due dates.
|
|
191
|
-
|
|
192
|
-
The policy owner reviews this plan at least annually and after a major disruption. Git history records approvals and changes.
|
|
@@ -1,20 +0,0 @@
|
|
|
1
|
-
{
|
|
2
|
-
"id": "document-contractor-policy-acknowledgement",
|
|
3
|
-
"type": "document",
|
|
4
|
-
"title": "Contractor Policy Acknowledgement",
|
|
5
|
-
"status": "draft",
|
|
6
|
-
"documentKind": "attestation-template",
|
|
7
|
-
"ownerIds": [
|
|
8
|
-
"appointment-policy-owner"
|
|
9
|
-
],
|
|
10
|
-
"version": "1.0",
|
|
11
|
-
"audience": [
|
|
12
|
-
"contractors"
|
|
13
|
-
],
|
|
14
|
-
"controlIds": [
|
|
15
|
-
"control-workforce-expectations"
|
|
16
|
-
],
|
|
17
|
-
"classificationId": "internal",
|
|
18
|
-
"proposedEffectiveOn": "{{effective_date}}",
|
|
19
|
-
"programRole": "conditional"
|
|
20
|
-
}
|