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SafetyCircuit

FullCircle

We encourage you to explore FullCircle's SafetyCircuit in detail and get in touch with us should you have any questions. Your safety and peace of mind is our top priority.

AI is a topic for which security regulations are constantly evolving, and at FullCircle, we don’t just keep up- we set the standard. FullCircle disseminates leading thought pieces on AI safety through our Board and selected Partners in industry. We not only maintain compliance, we go above and beyond to make sure your safety is prioritized over profit: our engineering systems bear all extra costs to proactively adapt to new threats, and keep well above emerging AI regulations both in the US, and globally. In addition, our engine provides a proactive, in-built, triple-tier-check system to ensure reliability at all times.

Welcome to FullCircle's SafetyCircuit. FullCircle's mission is to make your life easier. This SafetyCircuit provides in-depth insights into our security practices, detailing the robust controls and policies our teams have implemented to keep your business fully protected.

connect@fullcircle.fyi

Overview

Controls

Subprocessors

Following

SOC 2

HIPAA

GDPR

CCPA

Infrastructure security

Control

Unique production database authentication enforced

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

Encryption key access restricted

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

Unique account authentication enforced

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

Production application access restricted

System access restricted to authorized access only

Access control procedures established

The company'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.

Production database access restricted

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

Firewall access restricted

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

Production network access restricted

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

Access revoked upon termination

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

Unique network system authentication enforced

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

Remote access MFA enforced

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

Remote access encrypted enforced

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

Log management utilized

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

Infrastructure performance monitored

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

Network segmentation implemented

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

Network firewalls reviewed

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

Network firewalls utilized

The company uses firewalls and configures them to prevent unauthorized access.

Network and system hardening standards maintained

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

Service infrastructure maintained

The company 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.

Organizational security

Control

Asset disposal procedures utilized

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

Production inventory maintained

The company maintains a formal inventory of production system assets.

Anti-malware technology utilized

The company 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.

Employee background checks performed

The company performs background checks on new employees.

Code of Conduct acknowledged by contractors

The company requires contractor agreements to include a code of conduct or reference to the company code of conduct.

Code of Conduct acknowledged by employees and enforced

The company 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.

Confidentiality Agreement acknowledged by contractors

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

Confidentiality Agreement acknowledged by employees

The company requires employees to sign a confidentiality agreement during onboarding.

Performance evaluations conducted

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

Password policy enforced

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

Security awareness training implemented

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

Product security

Control

Data encryption utilized

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

Control self-assessments conducted

The company 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 the company has committed to an SLA for a finding,

the corrective action is completed within that SLA.

Data transmission encrypted

The company uses secure data transmission protocols to encrypt confidential and sensitive data when transmitted over

public networks.

Vulnerability and system monitoring procedures established

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

  • vulnerability management;

  • system monitoring.

Internal security procedures

Control

Continuity and Disaster Recovery plans established

The company 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.

Continuity and disaster recovery plans tested

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

Configuration management system established

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

Change management procedures enforced

The company 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.

Production deployment access restricted

The company restricts access to migrate changes to production to authorized personnel.

Development lifecycle established

The company 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.

SOC 2 - System Description

Complete a description of your system for Section III of the audit report

Whistleblower policy established

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

Board oversight briefings conducted

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

Board charter documented

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

Board expertise developed

The company'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.

Board meetings conducted

The company's board of directors meets at least annually and maintains formal meeting minutes. The board includes directors that are independent of the company.

Backup processes established

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

System changes externally communicated

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

Management roles and responsibilities defined

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

Organization structure documented

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

Roles and responsibilities specified

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.

Security policies established and reviewed

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

Support system available

The company 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.

System changes communicated

The company communicates system changes to authorized internal users.

Access reviews conducted

The company 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.

Access requests required

The company 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.

Incident response plan tested

The company tests their incident response plan at least annually.

Incident response policies established

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

Incident management procedures followed

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

Data center access reviewed

The company reviews access to the data centers at least annually.

Company commitments externally communicated

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

External support resources available

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

Service description communicated

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

Risk management program established

The company 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.

Risk assessment objectives specified

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

Risks assessments performed

The company'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.

Third-party agreements established

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

Vendor management program established

The company 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.

Vulnerabilities scanned and remediated

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

Data and privacy

Control

Data retention procedures established

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

Customer data deleted upon leaving

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

Data classification policy established

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

Overview

Controls

Subprocessors

Following

SOC 2

HIPAA

GDPR

CCPA

Infrastructure security

Control

Unique production database authentication enforced

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

Encryption key access restricted

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

Unique account authentication enforced

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

Production application access restricted

System access restricted to authorized access only

Access control procedures established

The company'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.

Production database access restricted

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

Firewall access restricted

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

Production network access restricted

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

Access revoked upon termination

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

Unique network system authentication enforced

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

Remote access MFA enforced

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

Remote access encrypted enforced

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

Log management utilized

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

Infrastructure performance monitored

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

Network segmentation implemented

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

Network firewalls reviewed

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

Network firewalls utilized

The company uses firewalls and configures them to prevent unauthorized access.

Network and system hardening standards maintained

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

Service infrastructure maintained

The company 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.

Organizational security

Control

Asset disposal procedures utilized

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

Production inventory maintained

The company maintains a formal inventory of production system assets.

Anti-malware technology utilized

The company 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.

Employee background checks performed

The company performs background checks on new employees.

Code of Conduct acknowledged by contractors

The company requires contractor agreements to include a code of conduct or reference to the company code of conduct.

Code of Conduct acknowledged by employees and enforced

The company 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.

Confidentiality Agreement acknowledged by contractors

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

Confidentiality Agreement acknowledged by employees

The company requires employees to sign a confidentiality agreement during onboarding.

Performance evaluations conducted

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

Password policy enforced

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

Security awareness training implemented

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

Product security

Control

Data encryption utilized

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

Control self-assessments conducted

The company 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 the company has committed to an SLA for a finding,

the corrective action is completed within that SLA.

Data transmission encrypted

The company uses secure data transmission protocols to encrypt confidential and sensitive data when transmitted over

public networks.

Vulnerability and system monitoring procedures established

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

  • vulnerability management;

  • system monitoring.

Internal security procedures

Control

Continuity and Disaster Recovery plans established

The company 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.

Continuity and disaster recovery plans tested

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

Configuration management system established

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

Change management procedures enforced

The company 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.

Production deployment access restricted

The company restricts access to migrate changes to production to authorized personnel.

Development lifecycle established

The company 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.

SOC 2 - System Description

Complete a description of your system for Section III of the audit report

Whistleblower policy established

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

Board oversight briefings conducted

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

Board charter documented

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

Board expertise developed

The company'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.

Board meetings conducted

The company's board of directors meets at least annually and maintains formal meeting minutes. The board includes directors that are independent of the company.

Backup processes established

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

System changes externally communicated

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

Management roles and responsibilities defined

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

Organization structure documented

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

Roles and responsibilities specified

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.

Security policies established and reviewed

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

Support system available

The company 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.

System changes communicated

The company communicates system changes to authorized internal users.

Access reviews conducted

The company 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.

Access requests required

The company 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.

Incident response plan tested

The company tests their incident response plan at least annually.

Incident response policies established

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

Incident management procedures followed

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

Data center access reviewed

The company reviews access to the data centers at least annually.

Company commitments externally communicated

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

External support resources available

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

Service description communicated

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

Risk management program established

The company 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.

Risk assessment objectives specified

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

Risks assessments performed

The company'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.

Third-party agreements established

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

Vendor management program established

The company 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.

Vulnerabilities scanned and remediated

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

Data and privacy

Control

Data retention procedures established

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

Customer data deleted upon leaving

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

Data classification policy established

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

Overview

Controls

Subprocessors

Following

SOC 2

HIPAA

GDPR

CCPA

Infrastructure security

Control

Unique production database authentication enforced

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

Encryption key access restricted

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

Unique account authentication enforced

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

Production application access restricted

System access restricted to authorized access only

Access control procedures established

The company'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.

Production database access restricted

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

Firewall access restricted

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

Production network access restricted

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

Access revoked upon termination

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

Unique network system authentication enforced

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

Remote access MFA enforced

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

Remote access encrypted enforced

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

Log management utilized

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

Infrastructure performance monitored

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

Network segmentation implemented

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

Network firewalls reviewed

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

Network firewalls utilized

The company uses firewalls and configures them to prevent unauthorized access.

Network and system hardening standards maintained

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

Service infrastructure maintained

The company 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.

Organizational security

Control

Asset disposal procedures utilized

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

Production inventory maintained

The company maintains a formal inventory of production system assets.

Anti-malware technology utilized

The company 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.

Employee background checks performed

The company performs background checks on new employees.

Code of Conduct acknowledged by contractors

The company requires contractor agreements to include a code of conduct or reference to the company code of conduct.

Code of Conduct acknowledged by employees and enforced

The company 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.

Confidentiality Agreement acknowledged by contractors

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

Confidentiality Agreement acknowledged by employees

The company requires employees to sign a confidentiality agreement during onboarding.

Performance evaluations conducted

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

Password policy enforced

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

Security awareness training implemented

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

Product security

Control

Data encryption utilized

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

Control self-assessments conducted

The company 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 the company has committed to an SLA for a finding,

the corrective action is completed within that SLA.

Data transmission encrypted

The company uses secure data transmission protocols to encrypt confidential and sensitive data when transmitted over

public networks.

Vulnerability and system monitoring procedures established

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

  • vulnerability management;

  • system monitoring.

Internal security procedures

Control

Continuity and Disaster Recovery plans established

The company 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.

Continuity and disaster recovery plans tested

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

Configuration management system established

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

Change management procedures enforced

The company 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.

Production deployment access restricted

The company restricts access to migrate changes to production to authorized personnel.

Development lifecycle established

The company 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.

SOC 2 - System Description

Complete a description of your system for Section III of the audit report

Whistleblower policy established

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

Board oversight briefings conducted

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

Board charter documented

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

Board expertise developed

The company'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.

Board meetings conducted

The company's board of directors meets at least annually and maintains formal meeting minutes. The board includes directors that are independent of the company.

Backup processes established

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

System changes externally communicated

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

Management roles and responsibilities defined

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

Organization structure documented

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

Roles and responsibilities specified

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.

Security policies established and reviewed

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

Support system available

The company 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.

System changes communicated

The company communicates system changes to authorized internal users.

Access reviews conducted

The company 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.

Access requests required

The company 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.

Incident response plan tested

The company tests their incident response plan at least annually.

Incident response policies established

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

Incident management procedures followed

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

Data center access reviewed

The company reviews access to the data centers at least annually.

Company commitments externally communicated

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

External support resources available

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

Service description communicated

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

Risk management program established

The company 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.

Risk assessment objectives specified

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

Risks assessments performed

The company'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.

Third-party agreements established

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

Vendor management program established

The company 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.

Vulnerabilities scanned and remediated

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

Data and privacy

Control

Data retention procedures established

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

Customer data deleted upon leaving

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

Data classification policy established

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

Overview

Controls

Subprocessors

Following

SOC 2

HIPAA

GDPR

CCPA

Infrastructure security

Control

Unique production database authentication enforced

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

Encryption key access restricted

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

Unique account authentication enforced

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

Production application access restricted

System access restricted to authorized access only

Access control procedures established

The company'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.

Production database access restricted

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

Firewall access restricted

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

Production network access restricted

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

Access revoked upon termination

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

Unique network system authentication enforced

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

Remote access MFA enforced

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

Remote access encrypted enforced

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

Log management utilized

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

Infrastructure performance monitored

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

Network segmentation implemented

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

Network firewalls reviewed

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

Network firewalls utilized

The company uses firewalls and configures them to prevent unauthorized access.

Network and system hardening standards maintained

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

Service infrastructure maintained

The company 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.

Organizational security

Control

Asset disposal procedures utilized

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

Production inventory maintained

The company maintains a formal inventory of production system assets.

Anti-malware technology utilized

The company 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.

Employee background checks performed

The company performs background checks on new employees.

Code of Conduct acknowledged by contractors

The company requires contractor agreements to include a code of conduct or reference to the company code of conduct.

Code of Conduct acknowledged by employees and enforced

The company 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.

Confidentiality Agreement acknowledged by contractors

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

Confidentiality Agreement acknowledged by employees

The company requires employees to sign a confidentiality agreement during onboarding.

Performance evaluations conducted

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

Password policy enforced

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

Security awareness training implemented

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

Product security

Control

Data encryption utilized

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

Control self-assessments conducted

The company 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 the company has committed to an SLA for a finding,

the corrective action is completed within that SLA.

Data transmission encrypted

The company uses secure data transmission protocols to encrypt confidential and sensitive data when transmitted over

public networks.

Vulnerability and system monitoring procedures established

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

  • vulnerability management;

  • system monitoring.

Internal security procedures

Control

Continuity and Disaster Recovery plans established

The company 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.

Continuity and disaster recovery plans tested

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

Configuration management system established

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

Change management procedures enforced

The company 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.

Production deployment access restricted

The company restricts access to migrate changes to production to authorized personnel.

Development lifecycle established

The company 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.

SOC 2 - System Description

Complete a description of your system for Section III of the audit report

Whistleblower policy established

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

Board oversight briefings conducted

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

Board charter documented

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

Board expertise developed

The company'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.

Board meetings conducted

The company's board of directors meets at least annually and maintains formal meeting minutes. The board includes directors that are independent of the company.

Backup processes established

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

System changes externally communicated

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

Management roles and responsibilities defined

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

Organization structure documented

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

Roles and responsibilities specified

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.

Security policies established and reviewed

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

Support system available

The company 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.

System changes communicated

The company communicates system changes to authorized internal users.

Access reviews conducted

The company 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.

Access requests required

The company 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.

Incident response plan tested

The company tests their incident response plan at least annually.

Incident response policies established

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

Incident management procedures followed

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

Data center access reviewed

The company reviews access to the data centers at least annually.

Company commitments externally communicated

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

External support resources available

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

Service description communicated

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

Risk management program established

The company 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.

Risk assessment objectives specified

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

Risks assessments performed

The company'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.

Third-party agreements established

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

Vendor management program established

The company 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.

Vulnerabilities scanned and remediated

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

Data and privacy

Control

Data retention procedures established

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

Customer data deleted upon leaving

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

Data classification policy established

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

COPYRIGHT © 2025 FULLCIRCLE TECHNOLOGIES INC. ALL RIGHTS RESERVED.

COPYRIGHT © 2025 FULLCIRCLE TECHNOLOGIES INC. ALL RIGHTS RESERVED.

COPYRIGHT © 2025 FULLCIRCLE TECHNOLOGIES INC. ALL RIGHTS RESERVED.

COPYRIGHT © 2025 FULLCIRCLE TECHNOLOGIES INC. ALL RIGHTS RESERVED.