A | B | C | D | E | F | H | I | J | K | L | M | N | O | P | Q | R | S | T | U | V | W | X | Y | Z | |
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6 | Section Heading | Control Heading | Original ID | Question Text | Answer | Notes/Comment | |||||||||||||||||||
7 | Application & Interface Security | Application Security | AIS-01.2 | Do you use an automated source code analysis tool to detect security defects in code prior to production? | Yes | We perform automated analysis and dependency checks through our continuous integration processes, which also test individual components of Cliniko. | |||||||||||||||||||
8 | AIS-01.5 | (SaaS only) Do you review your applications for security vulnerabilities and address any issues prior to deployment to production? | Yes | We perform peer reviews on Cliniko via our pull request process, prior being deployed to any environment. | |||||||||||||||||||||
9 | Customer Access Requirements | AIS-02.1 | Are all identified security, contractual, and regulatory requirements for customer access contractually addressed and remediated prior to granting customers access to data, assets, and information systems? | Yes | We provide this information to customers through Cliniko's terms of service, privacy policy and any other regulatory requirements (e.g. GDPR, HIPAA). | ||||||||||||||||||||
10 | Data Integrity | AIS-03.1 | Does your data management policies and procedures require audits to verify data input and output integrity routines? | Yes | We continuously monitor our data integrity though end to end tests, peer reviews, data sanitisation and penetration testing. Cliniko's database schema is managed, and changes are peer reviewed | ||||||||||||||||||||
11 | Audit Assurance & Compliance | Independent Audits | AAC-02.1 | Do you allow tenants to view your SOC2/ISO27001 or similar third-party audit or certification reports? | No | While we don't have SOC2 or ISO27001, we conduct an annual security audit, with a letter of assessment available to customers. Our cloud hosting provider, AWS, does hold SOC 2 and ISO 27001 certification. | |||||||||||||||||||
12 | AAC-02.2 | Do you conduct network penetration tests of your cloud service infrastructure at least annually? | Yes | We conduct an annual security assessment and audit of our network and application with an independent security company. We also invite independent researchers to participate in our bug bounty program. | |||||||||||||||||||||
13 | AAC-02.3 | Do you conduct application penetration tests of your cloud infrastructure regularly as prescribed by industry best practices and guidance? | Yes | We conduct an annual security assessment and audit of our network and application with an independent security company. We also invite independent researchers to participate in our bug bounty program. | |||||||||||||||||||||
14 | Information System Regulatory Mapping | AAC-03.1 | Do you have a program in place that includes the ability to monitor changes to the regulatory requirements in relevant jurisdictions, adjust your security program for changes to legal requirements, and ensure compliance with relevant regulatory requirements? | Yes | We review the regulatory requirements regularly and make changes to ensure we maintain compliance with our regulatory requirements and obligations. | ||||||||||||||||||||
15 | Business Continuity Management & Operational Resilience | Business Continuity Testing | BCR-02.1 | Are business continuity plans subject to testing at planned intervals or upon significant organizational or environmental changes to ensure continuing effectiveness? | Yes | We regularly test our business continuity plans within existing production systems, and also test when new Cliniko regions are created. We update them when system, organisational or regulatory changes are required and review them annually. | |||||||||||||||||||
16 | Policy | BCR-10.1 | Are policies and procedures established and made available for all personnel to adequately support services operations’ roles? | Yes | Our policies and procedures are available on company document repository. | ||||||||||||||||||||
17 | Retention Policy | BCR-11.1 | Do you have technical capabilities to enforce tenant data retention policies? | Not Applicable | Tenant data retention policies are managed by customers. | ||||||||||||||||||||
18 | BCR-11.3 | Have you implemented backup or recovery mechanisms to ensure compliance with regulatory, statutory, contractual or business requirements? | Yes | We backup over a rolling window to ensure compliance with regulatory requirements. For customers requiring additional data retention requirements, we offer data export facility from within Cliniko. | |||||||||||||||||||||
19 | BCR-11.7 | Do you test your backup or redundancy mechanisms at least annually? | Yes | We regularly test backup, recovery and redundancy mechanisms, at a minimum annually. | |||||||||||||||||||||
20 | Change Control & Configuration Management | Unauthorized Software Installations | CCC-04.1 | Do you have controls in place to restrict and monitor the installation of unauthorized software onto your systems? | Yes | Our systems are managed through automated systems and change management. Any changes are peer reviewed before being installed. | |||||||||||||||||||
21 | Data Security & Information Lifecycle Management | E-commerce Transactions | DSI-03.1 | Do you provide standardized (e.g. ISO/IEC) non-proprietary encryption algorithms (3DES, AES, etc.) to tenants in order for them to protect their data if it is required to move through public networks (e.g., the Internet)? | Yes | We encrypt data in transit and at rest. | |||||||||||||||||||
22 | DSI-03.2 | Do you utilize open encryption methodologies any time your infrastructure components need to communicate with each other via public networks (e.g., Internet-based replication of data from one environment to another)? | Yes | We encrypt data in transit and at rest. | |||||||||||||||||||||
23 | Nonproduction Data | DSI-05.1 | Do you have procedures in place to ensure production data shall not be replicated or used in non-production environments? | Yes | We have procedures in place to ensure production data isn't used in non-production environments. | ||||||||||||||||||||
24 | Secure Disposal | DSI-07.1 | Do you support the secure deletion (e.g., degaussing/cryptographic wiping) of archived and backed-up data? | Not Applicable | This is managed by our cloud hosting provider, AWS. | ||||||||||||||||||||
25 | DSI-07.2 | Can you provide a published procedure for exiting the service arrangement, including assurance to sanitize all computing resources of tenant data once a customer has exited your environment or has vacated a resource? | Yes | Customers can cancel anytime, export their from within Cliniko and request data deletion. Customer data is removed once it has left our rolling backup window. | |||||||||||||||||||||
26 | Datacenter Security | Asset Management | DCS-01.2 | Do you maintain a complete inventory of all of your critical assets located at all sites/ or geographical locations and their assigned ownership? | Yes | We don't manage any sites or physical locations. We manage an inventory of hardware (company devices) and virtual/digital assets accordingly. | |||||||||||||||||||
27 | Controlled Access Points | DCS-02.1 | Are physical security perimeters (e.g., fences, walls, barriers, guards, gates, electronic surveillance, physical authentication mechanisms, reception desks, and security patrols) implemented for all areas housing sensitive data and information systems? | Not Applicable | We work remotely and we don't have any physical premises. Data centre security is managed by our cloud hosting providers. | ||||||||||||||||||||
28 | User Access | DCS-09.1 | Do you restrict physical access to information assets and functions by users and support personnel? | Not Applicable | We work remotely and we don't have any physical premises. Data centre security is managed by our cloud hosting providers. | ||||||||||||||||||||
29 | Encryption & Key Management | Key Generation | EKM-02.1 | Do you have a capability to allow creation of unique encryption keys per tenant? | No | Data is encrypted in transit and at rest, but not utilising unique encryption keys per customer. | |||||||||||||||||||
30 | Encryption | EKM-03.1 | Do you encrypt tenant data at rest (on disk/storage) within your environment? | Yes | This is managed by our cloud hosting provider, AWS. | ||||||||||||||||||||
31 | Governance and Risk Management | Baseline Requirements | GRM-01.1 | Do you have documented information security baselines for every component of your infrastructure (e.g., hypervisors, operating systems, routers, DNS servers, etc.)? | Yes | All of our infrastructure is automated (infrastructure as code) and is peer reviewed. | |||||||||||||||||||
32 | Policy | GRM-06.1 | Are your information security policies and procedures made available to all impacted personnel and business partners, authorized by accountable business role/function and supported by the information security management program as per industry best practices (e.g. ISO 27001, SOC 2)? | Yes | Our policies and procedures are available to our team via our company document repository. | ||||||||||||||||||||
33 | Policy Enforcement | GRM-07.1 | Is a formal disciplinary or sanction policy established for employees who have violated security policies and procedures? | Yes | These policies are supported by our employment contracts. | ||||||||||||||||||||
34 | Policy Reviews | GRM-09.1 | Do you notify your tenants when you make material changes to your information security and/or privacy policies? | Yes | Transparency is important to us. We notify customers of any changes to our terms of service, privacy policy or subprocessors. | ||||||||||||||||||||
35 | GRM-09.2 | Do you perform, at minimum, annual reviews to your privacy and security policies? | Yes | As part of our obligations under Australian law, and obligations in other jurisdictions, we review our privacy and security policies, at a minimum, annually. | |||||||||||||||||||||
36 | Human Resources | Asset Returns | HRS-01.1 | Upon termination of contract or business relationship, are employees and business partners adequately informed of their obligations for returning organizationally-owned assets? | Yes | ||||||||||||||||||||
37 | Background Screening | HRS-02.1 | Pursuant to local laws, regulations, ethics, and contractual constraints, are all employment candidates, contractors, and involved third parties subject to background verification? | Yes | |||||||||||||||||||||
38 | Employment Agreements | HRS-03.1 | Do your employment agreements incorporate provisions and/or terms in adherence to established information governance and security policies? | Yes | |||||||||||||||||||||
39 | Employment Termination | HRS-04.1 | Are documented policies, procedures, and guidelines in place to govern change in employment and/or termination? | Yes | |||||||||||||||||||||
40 | Training / Awareness | HRS-09.5 | Are personnel trained and provided with awareness programs at least once a year? | Yes | Awareness programs are conducted annually and the team is updated regularly as regulations and obligations change. | ||||||||||||||||||||
41 | Identity & Access Management | Audit Tools Access | IAM-01.1 | Do you restrict, log, and monitor access to your information security management systems (e.g., hypervisors, firewalls, vulnerability scanners, network sniffers, APIs, etc.)? | Yes | ||||||||||||||||||||
42 | IAM-01.2 | Do you monitor and log privileged access (e.g., administrator level) to information security management systems? | Yes | We utilise our cloud hosting providers auditing trail to log access to systems. | |||||||||||||||||||||
43 | User Access Policy | IAM-02.1 | Do you have controls in place ensuring timely removal of systems access that is no longer required for business purposes? | Yes | Once access is no longer required for a system, it is removed. | ||||||||||||||||||||
44 | Policies and Procedures | IAM-04.1 | Do you manage and store the identity of all personnel who have access to the IT infrastructure, including their level of access? | Yes | We review the team's level of access regularly, at least annually. | ||||||||||||||||||||
45 | Source Code Access Restriction | IAM-06.1 | Are controls in place to prevent unauthorized access to your application, program, or object source code, and assure it is restricted to authorized personnel only? | Yes | We utilise source control management, which requires appropriate authentication, including MFA. | ||||||||||||||||||||
46 | IAM-06.2 | Are controls in place to prevent unauthorized access to tenant application, program, or object source code, and assure it is restricted to authorized personnel only? | Yes | We have both technical and procedural controls in place to prevent unauthorised access. | |||||||||||||||||||||
47 | User Access Restriction / Authorization | IAM-08.1 | Do you document how you grant, approve and enforce access restrictions to tenant/customer credentials following the rules of least privilege? | Yes | We don't have access to customer credentials, but for support purposes, customers can authorise support access to their account for troubleshooting. | ||||||||||||||||||||
48 | User Access Reviews | IAM-10.1 | Do you require a periodical authorization and validation (e.g. at least annually) of the entitlements for all system users and administrators (exclusive of users maintained by your tenants), based on the rule of least privilege, by business leadership or other accountable business role or function? | Yes | We review the team's level of access regularly, at least annually. | ||||||||||||||||||||
49 | User Access Revocation | IAM-11.1 | Is timely deprovisioning, revocation, or modification of user access to the organizations systems, information assets, and data implemented upon any change in status of employees, contractors, customers, business partners, or involved third parties? | Yes | |||||||||||||||||||||
50 | Infrastructure & Virtualization Security | Audit Logging / Intrusion Detection | IVS-01.1 | Are file integrity (host) and network intrusion detection (IDS) tools implemented to help facilitate timely detection, investigation by root cause analysis, and response to incidents? | Not Applicable | This is managed by our cloud hosting provider, AWS. | |||||||||||||||||||
51 | IVS-01.2 | Is physical and logical user access to audit logs restricted to authorized personnel? | Yes | Physical access is managed by our cloud hosting provider, with logical access being restricted to the appropriate teams. | |||||||||||||||||||||
52 | IVS-01.5 | Are audit logs reviewed on a regular basis for security events (e.g., with automated tools)? | Yes | Audit logs are reviewed with automated and manual processes. | |||||||||||||||||||||
53 | Clock Synchronization | IVS-03.1 | Do you use a synchronized time-service protocol (e.g., NTP) to ensure all systems have a common time reference? | Yes | |||||||||||||||||||||
54 | OS Hardening and Base Controls | IVS-07.1 | Are operating systems hardened to provide only the necessary ports, protocols, and services to meet business needs using technical controls (e.g., antivirus, file integrity monitoring, and logging) as part of their baseline build standard or template? | Yes | |||||||||||||||||||||
55 | Production / Non-Production Environments | IVS-08.1 | For your SaaS or PaaS offering, do you provide tenants with separate environments for production and test processes? | No | Customers are able to create seperate accounts to replicate separate environments, however they will be contained within the production environment. | ||||||||||||||||||||
56 | IVS-08.3 | Do you logically and physically segregate production and non-production environments? | Yes | ||||||||||||||||||||||
57 | Segmentation | IVS-09.1 | Are system and network environments protected by a firewall or virtual firewall to ensure business and customer security requirements? | Yes | |||||||||||||||||||||
58 | VMM Security - Hypervisor Hardening | IVS-11.1 | Do you restrict personnel access to all hypervisor management functions or administrative consoles for systems hosting virtualized systems based on the principle of least privilege and supported through technical controls (e.g., two-factor authentication, audit trails, IP address filtering, firewalls and TLS-encapsulated communications to the administrative consoles)? | Yes | We restrict access to the team with the appropriate authentication and MFA. | ||||||||||||||||||||
59 | Wireless Security | IVS-12.1 | Are policies and procedures established and mechanisms configured and implemented to protect the wireless network environment perimeter and to restrict unauthorized wireless traffic? | Yes | Although we work remotely and don't manage wireless networks, as part of our awareness program, we include a section on wireless network security and access. | ||||||||||||||||||||
60 | IVS-12.2 | Are policies and procedures established and mechanisms implemented to ensure wireless security settings are enabled with strong encryption for authentication and transmission, replacing vendor default settings (e.g., encryption keys, passwords, SNMP community strings)? | Yes | ||||||||||||||||||||||
61 | IVS-12.3 | Are policies and procedures established and mechanisms implemented to protect wireless network environments and detect the presence of unauthorized (rogue) network devices for a timely disconnect from the network? | Yes | ||||||||||||||||||||||
62 | Interoperability & Portability | APIs | IPY-01.1 | Do you publish a list of all APIs available in the service and indicate which are standard and which are customized? | Yes | API documentation is available at https://docs.api.cliniko.com/developer-portal/ | |||||||||||||||||||
63 | Mobile Security | Approved Applications | MOS-03.1 | Do you have a policy enforcement capability (e.g., XACML) to ensure that only approved applications and those from approved application stores can be loaded onto a mobile device? | Not Applicable | Although we don't provide mobile devices to the team, as part of our awareness program, we include a section on securing devices. | |||||||||||||||||||
64 | Security Incident Management, E-Discovery, & Cloud Forensics | Incident Management | SEF-02.1 | Do you have a documented security incident response plan? | Yes | ||||||||||||||||||||
65 | SEF-02.4 | Have you tested your security incident response plans in the last year? | Yes | We test our security response plans at least annually. | |||||||||||||||||||||
66 | Incident Reporting | SEF-03.1 | Are workforce personnel and external business relationships adequately informed of their responsibility, and, if required, consent and/or contractually required to report all information security events in a timely manner? | Yes | |||||||||||||||||||||
67 | SEF-03.2 | Do you have predefined communication channels for workforce personnel and external business partners to report incidents in a timely manner adhering to applicable legal, statutory, or regulatory compliance obligations? | Yes | ||||||||||||||||||||||
68 | Incident Response Legal Preparation | SEF-04.4 | Do you enforce and attest to tenant data separation when producing data in response to legal subpoenas? | Yes | |||||||||||||||||||||
69 | Supply Chain Management, Transparency, and Accountability | Incident Reporting | STA-02.1 | Do you make security incident information available to all affected customers and providers periodically through electronic methods (e.g., portals)? | Yes | We post incident information at https://status.cliniko.com/and other methods, such as social media, where appropriate. For some incidents, we may contact the affected customers directly. | |||||||||||||||||||
70 | Network / Infrastructure Services | STA-03.1 | Do you collect capacity and use data for all relevant components of your cloud service offering? | Yes | |||||||||||||||||||||
71 | Third Party Agreements | STA-05.4 | Do third-party agreements include provision for the security and protection of information and assets? | Yes | We ensure all our subprocessors adhere with relevant policies and procedures to comply with our regulatory requirements and obligations. | ||||||||||||||||||||
72 | STA-05.5 | Do you have the capability to recover data for a specific customer in the case of a failure or data loss? | Yes | ||||||||||||||||||||||
73 | Supply Chain Metrics | STA-07.4 | Do you provide tenants with ongoing visibility and reporting of your operational Service Level Agreement (SLA) performance? | Yes | Although we don't provide a SLA, we are transparent with our availability and performance at https://status.cliniko.com/ | ||||||||||||||||||||
74 | Third Party Audits | STA-09.1 | Do you mandate annual information security reviews and audits of your third party providers to ensure that all agreed upon security requirements are met? | Yes | We regularly review our subprocessors, at least annually. | ||||||||||||||||||||
75 | Threat and Vulnerability Management | Antivirus / Malicious Software | TVM-01.1 | Do you have anti-malware programs that support or connect to your cloud service offerings installed on all of your IT infrastructure network and systems components? | Yes | The team are required to keep their devices up-to-date with the latest operating system and security updates. | |||||||||||||||||||
76 | Vulnerability / Patch Management | TVM-02.5 | Do you have a capability to patch vulnerabilities across all of your computing devices, applications, and systems? | Yes | |||||||||||||||||||||
77 | Mobile Code | TVM-03.1 | Is mobile code authorized before its installation and use, and the code configuration checked, to ensure that the authorized mobile code operates according to a clearly defined security policy? | Not Applicable | We don't provide the team with mobile devices. | ||||||||||||||||||||
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