- Confidentiality and training
- Personnel with access are bound by confidentiality; security training on joining and annually.
- Onboarding and offboarding
- Access granted by role on joining, revoked on leaving, reviewed on change.
- Vendor review cadence
- Subprocessors reviewed at least annually; the review date is published and staleness fails the site build.
- Incident response
- A written response plan with customer notification commitments in the DPA.
- Periodic risk assessment
- A documented organisation-wide risk assessment (product, data, vendors, AI) runs at least every six months and after material architecture or subprocessor changes; findings are recorded, gaps are tracked to a fix, and completed cycles are announced in the updates feed. The process is defined; the first cycle is tied to the SOC 2 observation window and the feed will carry its record.
- Independent control review
- Control operation is reviewed on a named cadence by someone other than the implementer: quarterly, the reviewer walks the controls inventory against its evidence (guards, tests, audit trail) and records the outcome; failures are tracked to a fix. The cadence is defined; reviews are announced in the updates feed, and no one signs off their own work.