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This a general information security policy meant to meet the EXACT requirements of the PCI-DSS. No more, no less, but still flexible for your organization.

Information Security Policy for PCI

The Information Security Policy helps to protect the confidentiality, integrity, and availability of information and information systems.

##Table of Contents##

##Roles and Responsibilities## Roles and responsibilities lists a top level breakdown of the duties and permissions assigned to each role in the organization.

###Security team###

  • Establish, document, and distribute security policies and procedures
  • Create and distribute security incident response and escalation procedures.
  • Monitor and analyze security alerts and information, and distribute to appropriate personnel
  • Provide appropriate security training
  • Act as the Primary Point of Contact for incidents

###Operations team###

  • Applying policies and procedures when and where appropriate.
  • Distribute secret shards
  • Follow Daily Operational Procedures

###Engineering team###

  • Follow security engineering principles
  • Responsible that all application security controls are added to the application design.
  • Coordinates security specialist and developers
  • Ensures that the products meet (security) specifications

###Human Resources team###

  • Ensure the Information Security Policy is distributed to all employees, contractors, vendors and partners.
  • Work with Security to formulate sanctions and other disciplinary actions involving violations of security policies.
  • Work with Security to distribute security information awareness and education materials to employees.
  • Coordinate employee hiring with Operations.

###Personnel###

  • Assist the organization in meetings its business goals by understanding that their actions have real consequences. Personnel must act accordingly, especially when it pertains to information security policy.
  • Avoid distributing restricted or sensitive information
  • Maintain an understanding of current information security policies.

Data management policy

The Data management policy ensures that the integrity of the data is maintained, risk associated with data retention is reduced, and loss of data is prevented.

Data Labeling And Marking

Personnel label information indicating the distribution limitations, handling caveats, and applicable security markings. Information labeling is accomplished in accordance with: (i) access control requirements; and (ii) special dissemination, handling, or distribution requirements. Personnel mark information using standard naming conventions to identify data sensitivity, special dissemination, and handling distribution instructions. Labeling and marking are not required for information determined to be Public, Private, or Restricted.

These naming conventions are :

  • Public: information (e.g. blog posts) that would not cause any effects to the organization;
  • Private: information (e.g. policies and procedures, meeting notes, and quarterly goals) that would cause undesirable effects, if publicly available;
  • Restricted: information (e.g. financial statements, employment records, and secret shards) that would cause damage or be prejudicial, if publicly available;
  • Sensitive: information (e.g. cardholders data) that would cause serious damage, if publicly available.

Data Access

Operations restricts access to sensitive information system data to authorized personnel. Operations authorizes, monitors, and controls all methods of data access to the information system. Operations employs automated mechanisms to (i) facilitate the monitoring and control of data access methods; (ii) restrict access to data storage areas; and (iii) audit access attempts and access granted.

Data Storage

Operations controls and securely stores sensitive information system data within controlled areas for no more then 3 months (unless required for business reasons). Sensitive information at rest is routinely encrypted. Operations develops, documents, and maintains a current inventory of sensitive information system data and updates the inventory every 1 year.

Data Sanitization And Disposal

Sanitization is the process used to remove information from information systems such that there is reasonable assurance, in proportion to the confidentiality of the information, that the information cannot be retrieved or reconstructed. Sanitization and disposal techniques (e.g. clearing, purging, and destroying data information) prevent the disclosure of organizational information to unauthorized individuals. Operations employs automated mechanisms to sanitize sensitive information system data older than 3 months. Operations tracks, documents, and verifies data sanitization and disposal actions. Data management procedure specifies methods for performing tasks on secure disposal of data.

Data Privacy

The information system obscures feedback of sensitive information system data (e.g. PANs) to protect the information from possible exploitation/use by unauthorized individuals. Tokenization Process describes how sensitive information system data is protected.

Access management policy

The Access management policy ensures that only authorized users are granted the right to use a service and that privileges are separated into functional roles.

Account Management

Operations manages information system accounts, including establishing, activating, modifying, reviewing, disabling, and removing accounts. Operations reviews sensitive information system accounts every 1 year. Account management includes the identification of account types (e.g. individual, group, and system), establishment of conditions for group membership, and assignment of associated authorizations. Operations identifies authorized users of the information system and specifies access rights/privileges. Operations grants access to the information system based on: (i) a valid need-to-know that is determined by assigned official duties and satisfying all personnel security criteria; and (ii) intended system usage. Operations requires proper identification for requests to establish information system accounts and approves such requests. Operations prohibits and restricts the use of shared information system accounts (e.g., guest, anonymous accounts) and removes, disables, or otherwise secures unnecessary accounts on sensitive information systems every 3 months. Operations is notified when information system users are terminated or transferred and associated accounts are removed, disabled, or otherwise secured. Operations is notified when users information system usage or need-to-know changes. Operations employs automated mechanisms (e.g. configuration management tools) to support the management of information system accounts, including audit account creation, modification, disabling, termination actions, and notifying appropriate individuals.

Access Enforcement

Operations employs access control policies (e.g., identity-based policies, rule-based policies) and associated access enforcement mechanisms (e.g., password authentication, access control lists) to automatically control access between users (or processes acting on behalf of users) and objects (e.g., devices, files, records, processes, programs, domains) in the information system. In addition, access enforcement mechanisms are employed at the application level, when necessary, to provide increased information security. Consideration is given to the implementation of a controlled, audited, and manual override of automated mechanisms in the event of emergencies or other serious events. Access to privileged functions and security-relevant information is restricted to explicitly authorized personnel (e.g. Operations, Security).

Separation Of Duties

Operations establishes appropriate divisions of responsibility and separates duties as needed to eliminate conflicts of interests in the responsibilities and duties of personnel. Separation of duties is enforced through assigned access authorizations by the information system. There is access control software on the information system that prevents users from having all of the necessary authority or information access to perform fraudulent activity without collusion. Examples of separation of duties include: (i) mission functions and distinct information system support functions are divided among Operations, Engineering, and Security; and (ii) different teams perform information system support functions (e.g., systems programming and systems management).

Least Privilege

The most restrictive set of rights/privileges or accesses need by users (or processes acting on behalf of users) are enforced for the performance of specified tasks.

Unsuccessful Login Attempts

A limit of 6 consecutive invalid access attempts by a user is enforced by the sensitive information system. Unless released by an administrator, the information system automatically locks the account for 30 minutes and delays the next login prompt when the maximum number of unsuccessful attempts is exceeded.

Remote Access

Operations authorizes, monitors, and controls all methods of remote access to the information system. Remote access controls are applicable to information systems other than public web servers or systems specifically designed for public access. Operations restricts access achieved and protects against unauthorized connections (e.g. using virtual private network technology). Operations employs automated mechanisms to facilitate the monitoring and control of remote access methods. Cryptography is used to protect the confidentiality and integrity of remote access sessions. All remote accesses are controlled through a limited number of managed access control points. For vendor access, Operations (i) permits remote access for privileged functions only for compelling operational needs; (ii) documents the rational for such access; and (iii) immediately deactivates access after operational needs have been met.

Identification and Authentication management policy

The Identification and Authentication management policy ensures that privileged access to assets and services is controlled using industry standard security mechanisms.

User Identification And Authentication

Users (e.g. Personnel) or processes acting on behalf of users are uniquely identified and authenticated by the information system for all accesses explicitly documented by Human Resources and Security. Authentication of user identities is accomplished through the use of passwords, cryptographic keys, tokens, or some combination thereof for multifactor authentication. Sensitive information systems implement multifactor authentication for remote and local accesses at the application level or information system level (e.g. system logins).

Identifier Management

Operations manages user identifiers by: (i) uniquely identifying each user; (ii) verifying the identity of each user; (iii) receiving authorization to issue a user identifier from Human Resources or Security; (iv) issuing the user identifier to the intended party; (v) disabling or removing the user identifier after 3 months of inactivity; and (vi) archiving user identifiers.

Authenticator Management

Operations manages information system authenticators (e.g. passwords, cryptographic keys, tokens) by: (i) defining unique initial authenticator content; (ii) implementing administrative procedures for initial authenticator distribution, for lost/compromised, or damaged authenticators, and for revoking authenticators; (iii) changing authenticators upon information system installation; and (iv) changing/refreshing authenticators periodically. For password-based authentication, the information system: (i) protects passwords from unauthorized disclosure and modification when stored and transmitted; (ii) prohibits passwords from being displayed when entered; (iii) enforces password uniqueness containing both numeric and alphabetic characters; (iv) enforces password minimum length of 7 characters; (v) enforces password maximum lifetime restrictions of 3 months; and (vi) prohibits password reuse for 4 generations. For public-key authentication, the information system: (i) establishes user control of the corresponding private key; and (ii) maps the authenticated identity to the user account.

Cryptographic Key Establishment And Management

Operations establishes and manages sensitive cryptographic keys using automated mechanisms with supporting procedures. Operations implements strong cryptography and effective cryptographic key management in support of encryption and provides protections to maintain the availability of the sensitive information in the event of the loss of cryptographic keys. Operations changes sensitive cryptographic keys (i) every 1 year; (ii) when cryptographic keys are lost, compromised; and (iii) when individuals are transferred/terminated. Public key certificates are obtained from an approved service provider or issued by the organization. Key management procedure specifies methods for performing tasks on managing cryptographic keys. PCI-DSS provides guidance on strong cryptography.

Audit management policy

The Audit Management Policy ensures that activities within the business are traced and accounted.

Auditable Events

Audit records are generated by the information system for at least the following events: invalid/valid access attempts, actions taken with root/administrative privileges, changes to time settings. Security specifies which information system components carry out auditing activities, which events require auditing on a continuous basis, and which events require auditing in response to specific situations. Additionally, the security audit function is coordinated with the network health and status monitoring function to enhance the mutual support between the two functions by the selection of information to be recorded by each function. Audit records are compiled from multiple components throughout the system into a system-wide (logical or physical), time-correlated audit trail. PCI-DSS 10.2 provides guidance on auditable events.

Content Of Audit Records

The information system produces audit records that contain sufficient information to establish what events occurred, the sources of the events, and the outcomes of the events. The information system provides the capability to include additional, more detailed information in the audit records for audit events identified by type, location, or subject. The information system provides the capability to centrally manage the content of audit records generated by individual components throughout the system. PCI-DSS 10.3 provides guidance on content of audit records.

Audit Monitoring, Analysis, And Reporting

Security (i) reviews and analyzes information system audit records every 1 day (e.g. intrusion detection logs, system activity logs) for indications of inappropriate/unusual activity; (ii) investigates suspicious activity or suspected violations; (iii) takes necessary actions (e.g. reports findings to Operations). Operations also (i) reviews the activities of users (e.g. user activity logs) with respect to the enforcement and usage of information system access controls; (ii) investigates any unusual information system related activities; and (iii) periodically reviews changes to access authorizations. It is not intended that every single audit record be reviewed, but rather with automated mechanisms (e.g. log harvesting, parsing, alerting tools) and when specific circumstances warrant review of other audit records. Operations employs automated mechanisms to integrate audit monitoring, analysis, and reporting into an overall process for investigation and response to suspicious activities. Automated mechanisms are employed to alert Operations and Security of inappropriate/unusual activities with security implications and facilitate the review of user activities. Daily operational procedure specifies methods for performing tasks on audit monitoring and analysis.

Audit Reduction, Report Generation, And Protection

Audit reduction and report generation tools are provided by the information system to support after-the-fact investigations of security incidents without altering original audit records. Audit information (e.g. audit records, audit settings, and audit reports) and audit tools are protected from unauthorized access, modification, and deletion by the information system. Access to audit information is restricted to Operations, Engineering, and Security. Audit records are automatically processed for events of interest based upon selectable event criteria.

Audit Record Retention And Storage

Operations retains audit records for 1 year and makes 3 months of audit records immediately available to provide support for after-the-fact investigations of security incidents and to meet regulatory and organizational information retention requirements (e.g. PCI-DSS). Audit management procedure provides methods on retaining and restoring audit records.

Time Stamps

Time stamps for use in audit record generation are provided by the information system. Time stamps (including date and time) of audit records are generated using internal system clocks. Operations employs automated mechanisms (e.g. ntp) to synchronize sensitive information system time with internal time servers. Internal time servers receive time updates only from industry-accepted time sources.

Information System Monitoring Tools And Techniques

Operations employs tools and techniques (e.g. intrusion detection systems, integrity verification applications, audit record monitoring software) to monitor events on the information system, detect attacks, and provide identification of unauthorized use of the system. Monitoring tools are strategically deployed within the information system (e.g. at selected perimeter locations, ad hoc locations) to collect essential information and track specific transactions. Additionally, these tools are used to track the impact of security changes to the information system. Intrusion detection tools (i) are connected and configured into a system-wide intrusion detection system for near real-time analysis of events; (ii) are integrated into access control/flow control mechanisms for rapid response to attacks and by enabling reconfiguration of these mechanisms in support of attack isolation and elimination; (iii) monitor inbound and outbound communications for unusual or unauthorized activities or conditions. File integrity monitoring tools: (i) detect and protect against unauthorized changes to software and information, and (ii) automatically monitor the integrity of the information system and the applications it hosts. Operations reassesses the integrity of software and information by performing integrity scans of the system every 1 week and looks for evidence of information tampering, errors, and omissions. Operations employs automated tools that provide notification to appropriate individuals upon discovering discrepancies during integrity verification.

Risk management policy

The Risk Management Policy ensures that activities and environments are assessed for business impact and possible disruption.

Risk Assessment

Security conducts assessments of the risk and magnitude of harm that could result from the unauthorized access, use, disclosure, disruption, modification, or destruction of sensitive information and sensitive information systems that support the operations and assets of the organization (including information and information systems managed/operated by external parties). Security updates the risk assessment every 1 year and after significant changes to the information system. Risk assessments take into account vulnerabilities, threat sources, and security controls planned or in place to determine the resulting level of residual risk posed to organizational operations, organizational assets, or individuals based on the operation of the information system. Risk assessments also take into account risk posed to organizational operations, organizational assets, or individuals from external parties (e.g., service providers, contractors operating information systems on behalf of the organization, individuals accessing organizational information systems, outsourcing entities). PCI DSS Risk Assessment Guidelines provides guidance on conducting risk assessments.

Security Alerts And Advisories

Security receives information system security alerts/advisories (e.g. vendor security notifications, CVE) on a regular basis, issues alerts/advisories to appropriate personnel, and takes appropriate actions in response. Security documents the types of actions to be taken in response to security alerts/advisories and assigns a risk ranking according to CVSS. Security also maintains contact with special interest groups (e.g., information security forums) that: (i) facilitate sharing of security-related information (e.g., threats, vulnerabilities, and latest security technologies); (ii) provide access to advice from security professionals; and (iii) improve knowledge of security best practices. Automated mechanisms are employed to make security alert and advisory information available throughout the organization as needed.

Vulnerability Scanning

Security scans for vulnerabilities in the sensitive information system every 3 months and after any significant change in the network occurs. Vulnerability scanning is internally conducted using appropriate scanning tools and techniques and externally conducted via an Approved Scanning Vendor (ASV). Security performs rescans until passing results are obtained and all high risk vulnerabilities (e.g. according to CVSS) are resolved. Selected personnel are trained in the use and maintenance of internal vulnerability scanning tools and techniques. Vulnerability scanning procedures demonstrating the breadth and depth of scan coverage, including vulnerabilities checked and information system components scanned is employed. Vulnerability analysis for custom software and applications require more specialized approaches (e.g. source code reviews and static analysis of source code). Incident management policy and Change management policy are initiated for remediation efforts.

Penetration Testing

Security performs penetration (e.g. network-layer, application-layer) testing every 1 year or when significant new changes potentially affecting the system are identified. Tests include components for network functions, operating systems, and high risk vulnerabilities identified in PCI-DSS 6.5. Penetration testing is internally and externally conducted using appropriate testing tools and techniques and by trained selected personnel. Security performs retests until all noted exploitable vulnerabilities are corrected. Penetration testing procedure specifies methods for performing tasks on penetration testing.

Incident management policy

The Incident Management Policy ensures that adverse impact on business operations are minimized, and normal service operations are restored as quickly as possible.

Incident Response Training And Testing

Security trains personnel in their incident response roles and responsibilities with respect to the sensitive information system and provides refresher training every 1 year. Security tests and exercises the incident response capability for the sensitive information system every 1 year using simulated events to determine the incident response effectiveness and documents the results.

Incident Handling

Security implements an incident handling capability for security incidents that includes preparation, detection and analysis, containment, eradication, and recovery. Incident-related information is obtained from a variety of sources (e.g. audit monitoring, network monitoring, user/administrator reports). Security incorporates the lessons learned from ongoing incident handling activities into the incident response procedures and implements the procedures accordingly. Operations employs automated mechanisms to support the incident handling process.

Incident Monitoring And Reporting

Security tracks and documents sensitive information system security incidents on an ongoing basis. Operations employs automated mechanisms (e.g. monitoring tools) to assist in the tracking of security incidents and in the collection and analysis of incident information. Security promptly reports incident information to appropriate authorities. In addition to incident information, weaknesses and vulnerabilities in the sensitive information system are reported to appropriate organizational officials in a timely manner to prevent security incidents. Organizational officials report security compromises to appropriate payment brands and legal bodies within an appropriate timeframe. Operations employs automated mechanisms to assist in the tracking of security incidents, reporting of security incidents, and in the collection and analysis of incident information. Incident management procedure specifies methods for performing tasks on incident monitoring and reporting.

Incident Response Assistance

Security provides an incident response support resource available on-call 24/7 that offers advice and assistance to personnel of the sensitive information system for the handling and reporting of security incidents.

Application management policy

The Application management policy ensures that software is resilient, features are delivered securely with minimized risk, and required functionality is available with minimal risk.

Life Cycle Support

Engineering designs and implements the sensitive information system using an agile software development life cycle methodology that includes information security considerations. In the following phase, Engineering employs information security considerations in the following phases: (i) Requirements: Misuse cases are identified and assessed against security risks (e.g. Owasp Top 10); (ii) Implementation: Test cases are developed and code is reviewed by a peer knowledgeable in Security Engineering Principles; (iii) Testing: Outcomes are verified for success using continuous integration mechanisms; (iv) Release: Appropriate personnel are notified and Change management policy is followed; (v) Maintenance: Problems are identified and Incident management policy is followed.

Security Engineering Principles

Engineering designs and implements the information system using security engineering principles and applies them to system upgrades and modifications. Engineering adheres to best practice secure coding guidelines (e.g. Owasp Top 10, Cert Secure Coding, CWE/Sans Top 25). Sensitive information system data (e.g. live PANs) is not used for development/testing, and test data (e.g. custom application accounts, identifiers, authenticators) is removed before code release into the information system. Application management procedure specifies methods for ensuring applications are not vulnerable to common coding vulnerabilities.

Developer Security Testing

Engineering creates a security test and evaluation plan, implements the plan, and documents the results for the sensitive information system. Developmental security test results are used to the greatest extent feasible after verification of the results and recognizing that these results are impacted whenever there have been security relevant modifications to the sensitive information system subsequent to developer testing.

Developer Change Control

Engineering controls changes to the system during development, tracks security flaws, requires authorization of changes, and provides documentation of the implementation for the sensitive information system.

Change management policy

The Change management policy ensures that changes into controlled environments are maintained throughout transition activities and handled reliably on the basis of formal approvals.

Configuration Change Control

Operations authorizes, documents, and controls changes to the sensitive information system. Configuration change control involves the systematic proposal, justification, implementation, test/evaluation, review, and disposition of changes to the sensitive information system, including upgrades and modifications. Configuration change control includes changes to the configuration settings for sensitive information technology products (e.g., operating systems and firewalls). Operations includes emergency changes in the configuration change control process, including changes resulting from the remediation of flaws. Operations employs automated mechanisms to: (i) document proposed and completed changes to the information system; (ii) notify appropriate approval authorities; (iii) inhibit change until necessary approvals are received; and (iv) track security flaws and impact of change. Operations includes documentation of (i) impact of changes; (ii) change approval by authorized personnel; (iii) functionality testing of changes; and (iv) back out procedures. The approvals to implement a change to the information system include (i) successful results from the security analysis of the change; and (ii) change reviews by authorized personnel (e.g. Operations, Engineering). Change management procedure specifies methods for performing tasks on configuration change control.

Monitoring Configuration Changes

Operations and Engineering monitor changes to the sensitive information system conducting security impact analyses to determine the effects of the changes. Prior to change implementation, and as part of the change approval process, Operations analyzes changes to the information system for potential security impacts. After the sensitive information system is changed (including upgrades and modifications), Operations checks the security features to verify that the features are still functioning properly. Operations audits activities associated with the configuration changes to the sensitive information system. Monitoring configuration changes and conducting security impact analyses are important elements with regard to the ongoing assessment of security controls in the information system.

Access Restrictions For Change

Operations: (i) approves individual access privileges and enforces physical and logical access restrictions associated with changes to the information system; and (ii) generates, retains, and reviews records reflecting all such changes. Only Operations obtain access to sensitive information system components for the purposes of initiating changes, including upgrades, and modifications. Operations employs automated mechanisms to enforce access restrictions and support auditing of the enforcement actions.

Flaw Remediation

Operations identifies, reports, and corrects information system flaws. Operations identifies information systems containing software affected by recently announced software flaws (and potential vulnerabilities resulting from those flaws). Operations (or the vendor in the case of software developed and maintained by a vendor/contractor) (i) installs, within 1 month, newly released security relevant patches, service packs, and hot fixes; and (ii) tests patches, service packs, and hot fixes for effectiveness and potential side effects on the organization’s sensitive information systems before installation. Flaws discovered during security assessments, continuous monitoring, incident response activities, or information system error handling are also addressed expeditiously. Operations centrally manages the flaw remediation process and installs updates automatically. Operations employs automated mechanisms to periodically and upon demand determine the state of information system components with regard to flaw remediation.

Configuration management policy

The Configuration Management Policy ensures that assets and services are baselined, maintained, and consistent.

Baseline Configuration

Operations develops, documents, and maintains a current baseline configuration of the sensitive information system. Baseline configurations provide information about a component’s makeup (e.g. the standard software stack for a database including updated patch information) and the component’s logical placement within the information system architecture. Baseline configurations also provide a well-defined and documented specification to which the information system is built and deviations, if required, are documented in support of mission needs/objectives. Operations updates baseline configurations as an integral part of information system component installations, especially when new vulnerabilities are identified. Operations employs automated mechanisms (e.g. Configuration Management Tools) to maintain an up-to-date, complete, accurate, and readily available baseline configuration of the information system. System configuration standard provides guidance on baseline configurations and system hardening standards.

Configuration Settings

Configuration settings are the configurable parameters of the information technology products that compose the information system. Operations: (i) establishes mandatory configuration settings for information technology products employed within the information system; (ii) configures the security settings of information technology products to the most restrictive mode consistent with operational requirements (e.g. according to Least Functionality); (iii) documents the configuration settings; (iv) enforces the configuration settings in all components of the information system; and (v) monitors and controls changes in accordance with Change Management Policy. Operations employs automated mechanisms (e.g. configuration management tools) to centrally manage, apply, and verify configuration settings. System configuration standard provides guidance on configuration settings and system hardening standards.

Least Functionality

Operations configures the sensitive information system to provide only essential capabilities and specifically prohibits/restricts the use of all ports, protocols, and/or services without documented business justifications. Operations limits component functionality to a single function per server (e.g. application server or database server, not both), where feasible. Operations reviews the sensitive information system every 6 months to document business justifications for enabled capabilities and to eliminate unnecessary functions (e.g. scripts, drivers, ports, protocols, services, firewall rules).

Information System Recovery And Reconstitution

Operations employs mechanisms with supporting procedures to allow the information system to be recovered and reconstituted to a known state after a disruption or failure. Information system recovery and reconstitution to a known secure state means that all system parameters are set to secure values, security-critical patches are reinstalled, security-related configuration settings are reestablished, system documentation and operating procedures are available, application and system software is reinstalled and configured with secure settings, information from the most recent, known secure backups is loaded, and the system is fully tested.

Network management policy

The Network Management Policy ensures that assets and services are segmented into functional roles within monitored and controlled environments.

Boundary Protection

Information system communications are monitored and controlled at external boundaries and at key internal boundaries within the information system. Any connections to the Internet, or other external networks or information systems, occur through appropriate boundary protection devices (e.g., proxies, gateways, firewalls, encrypted tunnels) arranged in an effective architecture (e.g. DMZs where sensitive application gateways reside on a protected subnetwork). Operations (i) allocates publicly accessible information system components to separate subnetworks; (ii) prevents public access into the organization’s sensitive internal networks except as appropriately mediated; (iii) limits the number of access points to and from the sensitive information system. Operations partitions information systems into separate environments (e.g. development, test, production) and restricts/prohibits network access to authorized personnel. Boundary protections at any designated alternate processing sites provide the same levels of protection as that of the primary site. Information systems deny network traffic by default and allow network traffic by exception (i.e. deny all, permit by exception).

Information Flow Enforcement

The information system enforces assigned authorizations for controlling the flow of information within the system and between interconnected systems. Information flow control regulates where information is allowed to travel within an information system and between information systems (e.g. blocking outside traffic that claims to be from within the organization, and not passing direct connections between the Internet and internal networks). As opposed to who is allowed to access the information, information flow control regulates information travel without explicit regard to subsequent accesses to that information. As a basis for flow control decisions (e.g. to control the release of certain types of information), information flow control is enforced using (i) explicit labels on source and destination objects; (ii) protected processing domains (e.g. domain type-enforcement); and/or (iii) dynamic security policy mechanisms.

Wireless Access Restrictions

Operations (i) authorizes, monitors, and controls sensitive wireless access to the information system; and (ii) uses strong authentication and strong encryption to protect sensitive wireless access to the information system. PCI-DSS provides guidance on strong encryption.

Information System Documentation

Operations obtains, protects as required, and makes available to authorized personnel, adequate documentation for the information system. Documentation (e.g. network diagrams) describing the functional properties, design, and implementation details of the security controls employed within the sensitive information system are updated every 1 month with sufficient detail to permit analysis and testing of the controls.

External Information System Services

Operations: (i) requires that providers (e.g. backup, payment processors, hosting) of external information system services provide written acknowledgement that adequate security controls are employed in accordance with policies, standards, guidance, and established service-level agreements, (ii) monitors and reviews security control compliance of providers every 1 year; and (iii) maintains an up-to-date list of all service providers. External Information Systems Services procedure specifies methods for performing tasks on engaging service providers.

Transmission Integrity And Confidentiality

The information system protects the integrity and confidentiality of transmitted information. Operations employs strong cryptographic mechanisms (e.g. SSL, SSH, IPSEC) to prevent unauthorized disclosure/recognize changes to information during transmission. PCI-DSS provides guidance on strong cryptography.

Session Termination

All sessions (e.g. remote, local) are automatically terminated after 15 minutes of inactivity by the information system.

Personnel management policy

The Personnel Management Policy ensures that due diligence has been conducted on all personnel with access to assets.

Security Awareness

Security provides basic security awareness training to personnel before authorizing access to the system, when required by system changes, upon hire, and every 1 year thereafter. Security determines the appropriate content of security awareness training based on the specific requirements of the organization and the information systems to which personnel have authorized access.

Security Training

Security identifies personnel (e.g. Operations, Engineering) that have significant information system security roles and responsibilities during the system development life cycle and provides appropriate information system security training (e.g. secure coding techniques according to industry best practices) every 1 year. NIST SP 800-50 provides guidance on security training.

Personnel Screening

Human Resources screens individuals requiring access to organizational information and information systems before authorizing access. Screenings (e.g. background checks) are consistent with the criteria established for the risk designation of the assigned position.

Personnel Termination

Operations, upon termination of individual employment, immediately terminates information system access, retrieves all organizational information system-related property (e.g. identifiers, authenticators, and laptops) and provides appropriate personnel with access to official records created by the terminated employee that are stored on organizational information systems.

Personnel Transfer

Operations reviews information systems access authorizations when personnel are reassigned or transferred to other positions within the organization and initiates appropriate actions. Appropriate actions that may be required include: (i) deactivating old and issuing new keys, (ii) closing old accounts and establishing new accounts; (iii) changing system access authorizations; and (iv) providing for access to official records created or controlled by the employee at the old work location and in the old accounts.

Personnel Sanctions

Human Resources employs a formal sanctions process for personnel failing to comply with established information security policies and procedures.

Access Agreements

Human Resources completes appropriate signed access agreements (e.g. acceptable use agreements, rules of behavior, information security policy) for personnel requiring access to organizational information and information systems. Human Resources receives signed acknowledgement from users every 1 year indicating that they have read, understood, and agree to abide by the agreements before authorizing access to the information system and its resident information. Security reviews and updates the access agreements every 1 year. Electronic signatures are acceptable for use in acknowledging access agreements. Security establishes a set of rules (e.g. Rules Of Behavior) for all Personnel.

Acceptable Use Policy

The acceptable use policy (AUP) is a set of rules to restrict the ways in which the information system may be used.

Rules Of Behavior

  • Personnel MUST NOT copy, move, or store sensitive information data onto non-sensitive information system media (e.g. local hard drives, flash drives).

  • Personnel with access to sensitive information systems MUST (i) enable personal firewall software; (ii) enable personal antivirus software with automatic updates; and (iii) install operating system updates and security patches to existing software whenever new releases are available.

  • Personnel MUST take reasonable measures to safeguard secrets (e.g. identifiers, authenticators, secret shards) including maintaining possession of their individual secrets, not loaning or sharing secrets with others, and reporting lost or compromised secrets shards immediately.

  • Personnel SHOULD only distribute public information after receiving approval from Communications.

  • Personnel MUST NOT distribute private information outside of the organization.

  • Personnel MUST only distribute restricted information on a valid need-to-know basis.

  • Personnel should not distribute sensitive information.

  • Personnel MUST NOT send sensitive information by end-user messaging technologies (e.g. email, instant messaging, chat).

  • Personnel MUST complete Security Awareness Training upon hire and every 1 year, thereafter.

  • Personnel MUST read, understand, and sign the Information Security Policy upon hire and every 1 year, thereafter.

##Definitions##

Access: level and extent of a service’s functionality or data that a user is entitled to use

Identity: information about a user that distinguishes them as an individual and verifies their status within the organization

Controlled Area: any area or space for which the organization has confidence that the physical and procedural protections provided are sufficient to meet the requirements established for protecting the information and/or information system.

Data: a recorded information produced or received in the initiation, conduct or completion of an institutional or individual activity and that comprises content, context and structure sufficient to provide evidence of the activity.

PAN: Primary Account Number

MUST: This word, or the terms "REQUIRED" or "SHALL", mean that the definition is an absolute requirement of the specification.

MUST NOT: This phrase, or the phrase "SHALL NOT", mean that the definition is an absolute prohibition of the specification.

SHOULD: This word, or the adjective "RECOMMENDED", mean that there may exist valid reasons in particular circumstances to ignore a particular item, but the full implications must be understood and carefully weighed before choosing a different course.

SHOULD NOT: This phrase, or the phrase "NOT RECOMMENDED" mean that there may exist valid reasons in particular circumstances when the particular behaviour is acceptable or even useful, but the full implications should be understood and the case carefully weighed before implementing any behaviour described with this label.

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An information security policy flexible for your organization

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