Security and privacy at Sparkwise

Sparkwise has infrastructure supporting the service patched as a part of routine maintenance and as a result of identified vulnerabilities to help ensure that servers supporting the service are hardened against security threats.

Sparkwise's network and system hardening standards are documented, based on industry best practices, and reviewed at least annually.

Sparkwise uses firewalls and configures them to prevent unauthorized access.

Sparkwise reviews its firewall rulesets at least annually. Required changes are tracked to completion.

An infrastructure monitoring tool is utilized to monitor systems, infrastructure, and performance and generates alerts when specific predefined thresholds are met.

Sparkwise's network is segmented to prevent unauthorized access to customer data.

Sparkwise utilizes a log management tool to identify events that may have a potential impact on Sparkwise's ability to achieve its security objectives.

Sparkwise uses an intrusion detection system to provide continuous monitoring of Sparkwise's network and early detection of potential security breaches.

Sparkwise restricts privileged access to the production network to authorized users with a business need.

Sparkwise's production systems can only be remotely accessed by authorized employees via an approved encrypted connection.

Sparkwise's production systems can only be remotely accessed by authorized employees possessing a valid multi-factor authentication (MFA) method.

Sparkwise requires authentication to the "production network" to use unique usernames and passwords or authorized Secure Socket Shell (SSH) keys.

Sparkwise restricts privileged access to the operating system to authorized users with a business need.

Sparkwise completes termination checklists to ensure that access is revoked for terminated employees within SLAs.

Sparkwise restricts privileged access to the firewall to authorized users with a business need.

Sparkwise requires authentication to systems and applications to use unique username and password or authorized Secure Socket Shell (SSH) keys.

System access restricted to authorized access only

Sparkwise restricts privileged access to databases to authorized users with a business need.

Sparkwise's access control policy documents the requirements for the following access control functions:

• adding new users;
• modifying users; and/or
• removing an existing user's access.

Sparkwise restricts privileged access to encryption keys to authorized users with a business need.

Sparkwise requires authentication to production datastores to use authorized secure authentication mechanisms, such as unique SSH key.

Sparkwise requires passwords for in-scope system components to be configured according to Sparkwise's policy.

Sparkwise requires employees to complete security awareness training within thirty days of hire and at least annually thereafter.

Sparkwise requires contractors to sign a confidentiality agreement at the time of engagement.

Sparkwise managers are required to complete performance evaluations for direct reports at least annually.

Sparkwise has a mobile device management (MDM) system in place to centrally manage mobile devices supporting the service.

Sparkwise requires employees to sign a confidentiality agreement during onboarding.

Sparkwise requires employees to acknowledge a code of conduct at the time of hire. Employees who violate the code of conduct are subject to disciplinary actions in accordance with a disciplinary policy.

Sparkwise requires contractor agreements to include a code of conduct or reference to Sparkwise code of conduct.

Sparkwise performs background checks on new employees.

Sparkwise deploys anti-malware technology to environments commonly susceptible to malicious attacks and configures this to be updated routinely, logged, and installed on all relevant systems.

Sparkwise has electronic media containing confidential information purged or destroyed in accordance with best practices, and certificates of destruction are issued for each device destroyed.

Sparkwise maintains a formal inventory of production system assets.

Sparkwise's formal policies outline the requirements for the following functions related to IT / Engineering:

• vulnerability management;
• system monitoring.

Sparkwise uses secure data transmission protocols to encrypt confidential and sensitive data when transmitted over public networks.

Sparkwise's penetration testing is performed at least annually. A remediation plan is developed and changes are implemented to remediate vulnerabilities in accordance with SLAs.

Sparkwise performs control self-assessments at least annually to gain assurance that controls are in place and operating effectively. Corrective actions are taken based on relevant findings. If Sparkwise has committed to an SLA for a finding, the corrective action is completed within that SLA.

Sparkwise's datastores housing sensitive customer data are encrypted at rest.

Sparkwise has a vendor management program in place. Components of this program include:

• critical third-party vendor inventory;
• vendor's security and privacy requirements; and
• review of critical third-party vendors at least annually

Host-based vulnerability scans are performed at least quarterly on all external-facing systems. Critical and high vulnerabilities are tracked to remediation.

Sparkwise has written agreements in place with vendors and related third-parties. These agreements include confidentiality and privacy commitments applicable to that entity.

Sparkwise has a documented risk management program in place that includes guidance on the identification of potential threats, rating the significance of the risks associated with the identified threats, and mitigation strategies for those risks.

Sparkwise's risk assessments are performed at least annually. As part of this process, threats and changes (environmental, regulatory, and technological) to service commitments are identified and the risks are formally assessed. The risk assessment includes a consideration of the potential for fraud and how fraud may impact the achievement of objectives.

Sparkwise specifies its objectives to enable the identification and assessment of risk related to the objectives.

Sparkwise provides a description of its products and services to internal and external users.

Sparkwise's security commitments are communicated to customers in Master Service Agreements (MSA) or Terms of Service (TOS).

Sparkwise provides guidelines and technical support resources relating to system operations to customers.

Sparkwise's security and privacy incidents are logged, tracked, resolved, and communicated to affected or relevant parties by management according to Sparkwise's security incident response policy and procedures.

Sparkwise tests their incident response plan at least annually.

Sparkwise has security and privacy incident response policies and procedures that are documented and communicated to authorized users.

Sparkwise ensures that user access to in-scope system components is based on job role and function or requires a documented access request form and manager approval prior to access being provisioned.

Sparkwise communicates system changes to authorized internal users.

Sparkwise conducts access reviews at least quarterly for the in-scope system components to help ensure that access is restricted appropriately. Required changes are tracked to completion.

Sparkwise maintains an organizational chart that describes the organizational structure and reporting lines.

Sparkwise has an external-facing support system in place that allows users to report system information on failures, incidents, concerns, and other complaints to appropriate personnel.

Sparkwise's information security policies and procedures are documented and reviewed at least annually.

Roles and responsibilities for the design, development, implementation, operation, maintenance, and monitoring of information security controls are formally assigned in job descriptions and/or the Roles and Responsibilities policy.

Sparkwise's data backup policy documents requirements for backup and recovery of customer data.

Sparkwise management has established defined roles and responsibilities to oversee the design and implementation of information security controls.

Sparkwise notifies customers of critical system changes that may affect their processing.

Sparkwise's board of directors has a documented charter that outlines its oversight responsibilities for internal control.

Sparkwise's board members have sufficient expertise to oversee management's ability to design, implement and operate information security controls. The board engages third-party information security experts and consultants as needed.

Sparkwise's board of directors or a relevant subcommittee is briefed by senior management at least annually on the state of Sparkwise's cybersecurity and privacy risk. The board provides feedback and direction to management as needed.

Sparkwise has established a formalized whistleblower policy, and an anonymous communication channel is in place for users to report potential issues or fraud concerns.

Sparkwise has completed a description of Sparkwise system for Section III of the audit report

Sparkwise has a formal systems development life cycle (SDLC) methodology in place that governs the development, acquisition, implementation, changes (including emergency changes), and maintenance of information systems and related technology requirements.

Sparkwise restricts access to migrate changes to production to authorized personnel.

Sparkwise requires changes to software and infrastructure components of the service to be authorized, formally documented, tested, reviewed, and approved prior to being implemented in the production environment.

Sparkwise has a configuration management procedure in place to ensure that system configurations are deployed consistently throughout the environment.

Sparkwise maintains cybersecurity insurance to mitigate the financial impact of business disruptions.

Sparkwise has Business Continuity and Disaster Recovery Plans in place that outline communication plans in order to maintain information security continuity in the event of the unavailability of key personnel.

Sparkwise has a documented business continuity/disaster recovery (BC/DR) plan and tests it at least annually.

Sparkwise has a data classification policy in place to help ensure that confidential data is properly secured and restricted to authorized personnel.

Sparkwise purges or removes customer data containing confidential information from the application environment, in accordance with best practices, when customers leave the service.

Sparkwise has formal retention and disposal procedures in place to guide the secure retention and disposal of company and customer data.