Merge branch 'master' of github.com:strongdm/comply

README.md

@@ -58,12 +58,13 @@ USAGE:
    comply [global options] command [command options] [arguments...]
 
 COMMANDS:
-     init       initialize a new compliance repository (interactive)
-     build, b   generate a static website summarizing the compliance program
-     scheduler  create tickets based on procedure schedule
-     serve      live updating version of the build command
-     sync       sync ticket status to local cache
-     todo       list declared vs satisfied compliance controls
-     help, h    Shows a list of commands or help for one command
+     init             initialize a new compliance repository (interactive)
+     build, b         generate a static website summarizing the compliance program
+     procedure, proc  create ticket by procedure ID
+     scheduler        create tickets based on procedure schedule
+     serve            live updating version of the build command
+     sync             sync ticket status to local cache
+     todo             list declared vs satisfied compliance controls
+     help, h          Shows a list of commands or help for one command
 ```
 

VERSION

@@ -1 +1 @@
-1.1.21
+1.1.22

themes/comply-soc2/policies/development.md

@@ -8,4 +8,188 @@ majorRevisions:
     comment: Initial document
 ---
 
-# Coming Soon
+# Purpose and Scope
+
+a. The purpose of this policy is to define requirements for establishing and maintaining baseline protection standards for company software, network devices, servers, and desktops.
+
+a. This policy applies to all users performing software development, system administration, and management of these activities within the organization. This typically includes employees and contractors, as well as any relevant external parties involved in these activities (hereinafter referred to as “users”). This policy must be made readily available to all users.
+
+a. This policy also applies to enterprise-wide systems and applications developed by the organization or on behalf of the organization for production implementation.
+
+# Background
+
+a. The intent of this policy is to ensure a well-defined, secure and consistent process for managing the entire lifecycle of software and information systems, from initial requirements analysis until system decommission. The policy defines the procedure, roles, and responsibilities, for each stage of the software development lifecycle.
+
+a. Within this policy, the software development lifecycle consists of requirements analysis, architecture and design, development, testing, deployment/implementation, operations/maintenance, and decommission. These processes may be followed in any form; in a waterfall model, it may be appropriate to follow the process linearly, while in an agile development model, the process can be repeated in an iterative fashion.
+
+# References
+
+a. Risk Assessment Policy
+
+# Policy
+
+a. The organization’s Software Development Life Cycle (SDLC) includes the following phases:
+
+    i. Requirements Analysis
+
+    i. Architecture and Design
+
+    i. Testing
+
+    i. Deployment/Implementation
+
+    i. Operations/Maintenance
+
+    i. Decommission
+
+a. During all phases of the SDLC where a system is not in production, the system must not have live data sets that contain information identifying actual people or corporate entities, actual financial data such as account numbers, security codes, routing information, or any other financially identifying data. Information that would be considered sensitive must never be used outside of production environments.
+
+a. The following activities must be completed and/or considered during the requirements analysis phase:
+
+    i. Analyze business requirements.
+
+    i. Perform a risk assessment. More information on risk assessments is discussed in the Risk Assessment Policy (reference (a)).
+
+    i. Discuss aspects of security (e.g., confidentiality, integrity, availability) and how they might apply to this requirement.
+
+    i. Review regulatory requirements and the organization’s policies, standards, procedures and guidelines.
+
+    i. Review future business goals.
+
+    i. Review current business and information technology operations.
+
+    i. Incorporate program management items, including:
+
+        1. Analysis of current system users/customers.
+
+        1. Understand customer-partner interface requirements (e.g., business-level, network).
+
+        1. Discuss project timeframe.
+
+    i. Develop and prioritize security solution requirements.
+
+    i. Assess cost and budget constraints for security solutions, including development and operations.
+
+    i. Approve security requirements and budget.
+
+    i. Make “buy vs. build” decisions for security services based on the information above.
+
+a. The following must be completed/considered during the architecture and design phase:
+
+    i. Educate development teams on how to create a secure system.
+
+    i. Develop and/or refine infrastructure security architecture.
+
+    i. List technical and non-technical security controls.
+
+    i. Perform architecture walkthrough.
+
+    i. Create a system-level security design.
+
+    i. Create high-level non-technical and integrated technical security designs.
+
+    i. Perform a cost/benefit analysis for design components.
+
+    i. Document the detailed technical security design.
+
+    i. Perform a design review, which must include, at a minimum, technical reviews of application and infrastructure, as well as a review of high-level processes.
+
+    i. Describe detailed security processes and procedures, including: segregation of duties and segregation of development, testing and production environments. 
+
+    i. Design initial end-user training and awareness programs.
+
+    i. Design a general security test plan.
+
+    i. Update the organization’s policies, standards, and procedures, if appropriate.
+
+    i. Assess and document how to mitigate residual application and infrastructure vulnerabilities.
+
+    i. Design and establish separate development and test environments.
+
+a. The following must be completed and/or considered during the development phase:
+
+    i. Set up a secure development environment (e.g., servers, storage).
+
+    i. Train infrastructure teams on installation and configuration of applicable software, if required.
+
+    i. Develop code for application-level security components.
+
+    i. Install, configure and integrate the test infrastructure.
+
+    i. Set up security-related vulnerability tracking processes.
+
+    i. Develop a detailed security test plan for current and future versions (i.e., regression testing).
+
+    i. Conduct unit testing and integration testing.
+
+a. The following must be completed and/or considered during the testing phase:
+
+    i. Perform a code and configuration review through both static and dynamic analysis of code to identify vulnerabilities. 
+
+    i. Test configuration procedures.
+
+    i. Perform system tests.
+
+    i. Conduct performance and load tests with security controls enabled.
+
+    i. Perform usability testing of application security controls.
+
+
+    i. Conduct independent vulnerability assessments of the system, including the infrastructure and application.
+
+a. The following must be completed and/or considered during the deployment phase:
+
+    i. Conduct pilot deployment of the infrastructure, application and other relevant components.
+
+    i. Conduct transition between pilot and full-scale deployment.
+
+    i. Perform integrity checking on system files to ensure authenticity.
+
+    i. Deploy training and awareness programs to train administrative personnel and users in the system’s security functions.
+
+    i. Require participation of at least two developers in order to conduct full-scale deployment to the production environment.
+
+a. The following must be completed and/or considered during the operations/maintenance phase:
+
+    i. Several security tasks and activities must be routinely performed to operate and administer the system, including but not limited to:
+
+        1. Administering users and access.
+
+        1. Tuning performance.
+
+        1. Performing backups according to requirements defined in the System Availability Policy 
+
+        1. Performing system maintenance (i.e., testing and applying security updates and patches).
+
+        1. Conducting training and awareness.
+
+        1. Conducting periodic system vulnerability assessments.
+
+        1. Conducting annual risk assessments.
+
+    i. Operational systems must:
+
+        1. Be reviewed to ensure that the security controls, both automated and manual, are functioning correctly and effectively.
+
+        1. Have logs that are periodically reviewed to evaluate the security of the system and validate audit controls.
+
+        1. Implement ongoing monitoring of systems and users to ensure detection of security violations and unauthorized changes.
+
+        1. Validate the effectiveness of the implemented security controls through security training as required by the Procedure For Executing Incident Response.
+
+        1. Have a software application and/or hardware patching process that is performed regularly in order to eliminate software bug and security problems being introduced into the organization’s technology environment. Patches and updates must be applied within ninety (90) days of release to provide for adequate testing and propagation of software updates. Emergency, critical, break-fix, and zero-day vulnerability patch releases must be applied as quickly as possible.
+
+a. The following must be completed and/or considered during the decommission phase:
+
+    i. Conduct unit testing and integration testing on the system after component removal.
+
+    i. Conduct operational transition for component removal/replacement.
+
+    i. Determine data retention requirements for application software and systems data.
+
+    i. Document the detailed technical security design.
+
+    i. Update the organization’s policies, standards and procedures, if appropriate.
+
+    i. Assess and document how to mitigate residual application and infrastructure vulnerabilities.
+

themes/comply-soc2/policies/media.md

@@ -8,4 +8,133 @@ majorRevisions:
     comment: Initial document
 ---
 
-# Coming Soon
+# Purpose and Scope
+
+a. This removable media, cloud storage and Bring Your Own Device (BYOD) policy defines the objectives, requirements and implementing instructions for storing data on removable media, in cloud environments, and on personally-owned devices, regardless of data classification level.
+
+a. This policy applies to all information and data within the organization’s information security program, as well as all removable media, cloud systems and personally-owned devices either owned or controlled by the organization.
+
+a. This policy applies to all users of information systems within the organization. This typically includes employees and contractors, as well as any external parties that come into contact with systems and information controlled by the organization (hereinafter referred to as “users”). This policy must be made readily available to all users.
+
+# Background
+
+a. This policy defines the procedures for safely using  removable media, cloud storage and personally-owned devices to limit data loss or exposure.  Such forms of storage must be strictly controlled because of the sensitive data that can be stored on them. Because each of these storage types are inherently ephemeral or portable in nature, it is possible for the organization to lose the ability to oversee or control the information stored on them if strict security standards are not followed.
+
+a. This document consists of three sections pertaining to removable media, cloud storage, and personally-owned devices. Each section contains requirements and implementing instructions for the registration, management, maintenance, and disposition of each type of storage.
+
+a. Within this policy, the term sensitive information refers to information that is classified as RESTRICTED or CONFIDENTIAL in accordance with the Data Classification Policy (reference (a)).
+
+# References
+
+a. Data Classification Policy
+
+a. Asset Inventory
+
+a. Security Incident Response Policy
+
+a. Encryption Policy
+
+# Policy
+
+a. *Removable Media*
+
+    i. All removable media in active use and containing data pertinent to the organization must be registered in the organization’s Asset Inventory (reference (b)).
+
+    i. All removable media listed in reference (b) must be re-inventoried on a quarterly basis to ensure that it is still within the control of the organization.
+
+        1. To re-inventory an item, the owner of the removable media must check in the item with the organization’s Information Security Manager (ISM).
+
+        1. The ISM must treat any removable media that cannot be located as lost, and a security incident report must be logged in accordance with the Security Incident Response Policy (reference (c)).
+
+    i. The owner of the removable media must conduct all appropriate maintenance on the item at intervals appropriate to the type of media, such as cleaning, formatting, labeling, etc.
+
+    i. The owner of the removable media, where practical, must ensure that an alternate or backup copy of the information located on the device exists.
+
+    i. Removable media must be stored in a safe place that has a reduced risk of fire or flooding damage. 
+
+    i. If the storage item contains sensitive information, removable media must:
+
+        1. Be stored in a locked cabinet or drawer.
+
+        1. Store only encrypted data that is securely enciphered in accordance with the Encryption Policy (reference (d)).
+
+    i. All data on removable media devices must be erased, or the device must be destroyed, before it is reused or disposed of.
+
+    i. When removable media devices are disposed, the device owner must inform the ISM so that it can be removed from reference (b).
+
+a. *Cloud Storage*
+
+    i. All cloud storage systems in active use and containing data pertinent to the organization must be registered in reference (b). Registration may be accomplished by manual or automated means.
+
+
+    i. All cloud storage systems listed in reference (b) must be re-inventoried on a quarterly basis to ensure that it is still within the control of the organization. To re-inventory an item, the owner of the removable media must check in the item with the organization’s Information Security Manager (ISM). Re-inventory may be accomplished by manual or automated means.
+
+    i. The owner of the cloud storage system must conduct all appropriate maintenance on the system at regular intervals to include system configuration, access control, performance monitoring, etc.
+
+    i. Data on cloud storage systems must be replicated to at least one other physical location. Depending on the cloud storage provider, this replication may be automatically configured.
+
+    i. The organization must only use cloud storage providers that can demonstrate, either through security accreditation, demonstration, tour, or other means that their facilities are secured, both physically and electronically, using best practices.
+
+    i. If the cloud storage system contains sensitive information, that information must be encrypted in accordance with reference (d).
+
+    i. Data must be erased from from cloud storage systems using a technology and process that is approved by the ISM. 
+
+    i. When use of a cloud storage system is discontinued, the system owner must inform the ISM so that it can be removed from reference (b).
+
+a. *Personally-owned Devices*
+
+    i. Organizational data that is stored, transferred or processed on personally-owned devices remains under the organization’s ownership, and the organization retains the right to control such data even though it is not the owner of the device.
+
+    i. The ISM is responsible for conducting overall management of personally-owned devices, to include:
+
+        1. Installation and maintenance of Mobile Device Management (MDM) software that can effectively manage, control and wipe data under the organization’s control from personally-owned devices.
+
+        1. Maintain a list of job titles and/or persons authorized to use personally-owned devices for the organization’s business, as well as the applications and databases that may be accessed from such devices.
+
+        1. Maintain a list of applications prohibited from use on personally-owned devices, and ensuring that device users are aware of these restrictions.
+
+    i. Personally-identifiable information (PII) may not be stored, processed or accessed at any time on a personally-owned device.
+
+    i. The following acceptable use requirements must be observed by users of personally-owned devices:
+
+        1. All organizational data must be backed up at regular intervals.
+
+        1. MDM and endpoint protection software must be installed on the device at all times.
+
+        1. Sensitive information stored on the device must be encrypted in accordance with reference (d).
+
+        1. The device must be secured using a password, pin, unlock pattern, fingerprint or equivalent security mechanism.
+
+        1. The device must only connect to secure and encrypted wireless networks.
+
+        1. When using the device outside of the organization’s premises, it must not be left unattended, and if possible, physically secured.
+
+        1. When using the device in public areas, the owner must take measures to ensure that the data cannot be read or accessed by unauthorized persons.
+
+        1. Patches and updates must be installed regularly.
+
+        1. Classified information must be protected in accordance with reference (a).
+
+        1. The device owner must install the ISM before the device is disposed of, sold, or provided to a third party for servicing.
+
+        1. It is prohibited to:
+
+            a. Allow device access for anyone except its owner.
+        
+            a. Store illegal materials on the device.
+
+            a. Install unlicensed software.
+
+            a. Locally-store passwords.
+
+            a. Transfer organizational data to other devices which have not been approved by the organization.
+
+    i. The organization must reserve the right to view, edit, and/or delete any organizational information that is stored, processed or transferred on the device.
+
+    i. The organization must reserve the right to perform full deletion of all of its data on the device if it considers that necessary for the protection of company-related data, without the consent of the device owner.
+
+    i. The organization will not pay the employees (the owners of BYOD) any fee for using the device for work purposes.
+
+    i. The organization will pay for any new software that needs to be installed for company use.
+
+    i. All security breaches related to personally-owned devices must be reported immediately to the ISM. 

themes/comply-soc2/policies/remote.md

@@ -10,4 +10,50 @@ majorRevisions:
     comment: Initial document
 ---
 
-# Coming Soon
+# Purpose and Scope
+
+a. The purpose of this policy is to define requirements for connecting to the organization’s systems and networks from remote hosts, including personally-owned devices, in order to minimize data loss/exposure.
+
+a. This policy applies to all users of information systems within the organization. This typically includes employees and contractors, as well as any external parties that come into contact with systems and information controlled by the organization (hereinafter referred to as “users”). This policy must be made readily accessible to all users.
+
+# Background
+
+a. The intent of this policy is to minimize the organization’s exposure to damages which may result from the unauthorized remote use of resources, including but not limited to: the loss of sensitive, company confidential data and intellectual property; damage to the organization’s public image; damage to the organization’s internal systems; and fines and/or other financial liabilities incurred as a result of such losses.
+
+a. Within this policy, the following definitions apply:
+
+    i. *Mobile computing equipment:* includes portable computers, mobile phones, smart phones, memory cards and other mobile equipment used for storage, processing and transfer of data.
+
+    i. *Remote host:* is defined as an information system, node or network that is not under direct control of the organization.
+
+    i. *Telework:* the act of using mobile computing equipment and remote hosts to perform work outside the organization’s physical premises. Teleworking does not include the use of mobile phones.
+
+# Policy
+
+a. *Security Requirements for Remote Hosts and Mobile Computing Equipment*
+
+    i. Caution must be exercised when mobile computing equipment is placed or used in uncontrolled spaces such as vehicles, public spaces, hotel rooms, meeting places, conference centers, and other unprotected areas outside the organization’s premises.
+
+    i. When using remote hosts and mobile computing equipment, users must take care that information on the device (e.g. displayed on the screen) cannot be read by unauthorized persons if the device is being used to connect to the organization’s systems or work with the organization’s data.
+
+    i. Remote hosts must be updated and patched for the latest security updates on at least a monthly basis.
+
+    i. Remote hosts must have endpoint protection software (e.g. malware scanner) installed and updated at all times.
+
+    i. Persons using mobile computing equipment off-premises are responsible for regular backups of organizational data that resides on the the device.
+
+    i. Access to the organization’s systems must be done through an encrypted and authenticated VPN connection with multi-factor authentication enabled. All users requiring remote access must be provisioned with VPN credentials from the organization’s information technology team. VPN keys must be rotated at least twice per year. Revocation of VPN keys must be included in the Offboarding Policy. 
+
+    i. Information stored on mobile computing equipment must be encrypted using hard drive full disk encryption.
+
+a. *Security Requirements for Telework*
+
+    i. Employees must be specifically authorized for telework in writing from their hiring manager .
+
+    i. Only device’s assigned owner is permitted to use remote nodes and mobile computing equipment. Unauthorized users (such as others living or working at the location where telework is performed) are not permitted to use such devices.
+
+    i. Devices must be authorized using certificates
+
+    i. Users performing telework are responsible for the appropriate configuration of the local network used for connecting to the Internet at their telework location.
+
+    i. Users performing telework must protect the organization’s intellectual property rights, either for software or other materials that are present on remote nodes and mobile computing equipment.

themes/comply-soc2/policies/vendor.md

@@ -8,4 +8,40 @@ majorRevisions:
     comment: Initial document
 ---
 
-# Coming Soon
+# Purpose and Scope
+
+a. This policy defines the rules for relationships with the organization’s Information Technology (IT) vendors and partners. 
+
+a. This policy applies to all IT vendors and partners who have the ability to impact the confidentiality, integrity, and availability of the organization’s technology and sensitive information, or who are within the scope of the organization’s information security program.
+
+a. This policy applies to all employees and contractors that are responsible for the management and oversight of IT vendors and partners of the organization. 
+
+# Background
+
+a. The overall security of the organization is highly dependent on the security of its contractual relationships with its IT suppliers and partners. This policy defines  requirements for effective management and oversight of such suppliers and partners from an information security perspective. The policy prescribes minimum standards a vendor must meet from an information security standpoint, including security clauses, risk assessments, service level agreements, and incident management.
+
+# References
+
+a. Information Security Policy
+
+a. Security Incident Response Policy
+
+# Policy
+
+a. IT vendors are prohibited from accessing the organization’s information security assets until  a contract containing security controls is agreed to and signed by the appropriate parties.
+
+a. All IT vendors must comply with the security policies defined and derived from the Information Security Policy (reference (a)). 
+
+a. All security incidents by IT vendors or partners must be documented in accordance with the organization’s Security Incident Response Policy (reference (b)) and immediately forwarded to the Information Security Manager (ISM). 
+
+a. The organization must adhere to the terms of all Service Level Agreements (SLAs) entered into with IT vendors. As terms are updated, and as new ones are entered into, the organization must implement any changes or controls needed to ensure it remains in compliance. 
+
+a. Before entering into a contract and gaining access to the parent organization’s information systems, IT vendors must undergo a risk assessment. 
+
+    i. Security risks related to IT vendors and partners must be identified during the risk assessment process. 
+    
+    i. The risk assessment must identify risks related to information and communication technology, as well as risks related to IT vendor supply chains, to include sub-suppliers. 
+
+a. IT vendors and partners must ensure that organizational records are protected, safeguarded, and disposed of securely. The organization strictly adheres to all applicable legal, regulatory and contractual requirements regarding the collection, processing, and transmission of sensitive data such as Personally-Identifiable Information (PII). 
+
+a. The organization may choose to audit IT vendors and partners to ensure compliance with applicable security policies, as well as legal, regulatory and contractual obligations.

themes/comply-soc2/procedures/offboarding.md

@@ -2,4 +2,10 @@ id: "offboard"
 name: "Offboard User"
 ---
 
-# Coming Soon
+Resolve this ticket by executing the following steps:
+
+- [ ] Immediately suspend user in SSO
+- [ ] Append HR termination request e-mail to this ticket
+- [ ] Look up manually-provisioned applications for this role or user
+- [ ] Validate access revocation in each
+- [ ] Append confirmation or revocation to this ticket

themes/comply-soc2/procedures/onboarding.md

@@ -2,4 +2,11 @@ id: "onboard"
 name: "Onboard New User"
 ---
 
-# Coming Soon
+Resolve this ticket by executing the following steps:
+
+- [ ] Append HR add request e-mail to this ticket
+- [ ] Proactively validate role assignment with manager (see HR request e-mail)
+- [ ] Add user to default group for the specified role
+- [ ] Provision any manually-provisioned applications by role
+    - [ ] Append manual provisioning confirmation to this ticket
+- [ ] Proactively confirm with new user that they can access all provisioned systems

themes/comply-soc2/procedures/patch.md

@@ -1,6 +1,15 @@
 id: "patch"
 name: "Apply OS patches"
-cron: "0 0 1 * * *"
+cron: "0 0 0 15 * *"
 ---
 
-# Coming Soon
+# OS Patch Procedure
+
+Resolve this ticket by executing the following steps:
+
+- [ ] Pull the latest scripts from the Ops repository
+- [ ] Execute `ENV=staging patch-all.sh`
+- [ ] Inspect output
+    - [ ] Errors? Investigate and resolve
+- [ ] Execute `ENV=production patch-all.sh`
+- [ ] Attach log output to this ticket

themes/comply-soc2/procedures/workstation.md

@@ -1,6 +1,40 @@
 id: "workstation"
 name: "Collect Workstation Details"
-cron: "0 0 * * * *"
+cron: "0 0 0 15 4 *"
 ---
 
-# Coming Soon
+Resolve this ticket by executing the following steps:
+
+- [ ] Send the communications below
+- [ ] For any email replies, attach content to this ticket
+- [ ] Validate responses are received from each
+
+
+```
+To: Desktop support
+Subject: Annual workstation inventory
+
+Please attach the current workstation inventory to the following ticket: [REPLACE WITH URL TO THIS TICKET]
+
+The workstation inventory shall include the following fields:
+    * Serial number
+    * Custodian
+    * Full disk encryption status
+    * Malware protection status
+```
+
+
+```
+To: Outsourced Call Center IT
+Subject: Annual workstation inventory
+
+As part of our ongoing compliance efforts and per our services agreement, we require a current inventory of workstations in use in the service of our account.
+
+Please respond to this message with the current inventory.
+
+The workstation inventory shall include the following fields:
+    * Serial number
+    * Custodian
+    * Full disk encryption status
+    * Malware protection status
+```