xcPEP Risk Assessment Policy
1. Purpose and Scope
This Risk Assessment Policy outlines Advanced Structures India Private Limited's systematic approach to identifying, assessing, and managing information security risks related to the xcPEP SaaS platform, its underlying infrastructure, and associated processes. The policy aims to protect our information assets, ensure business continuity, and comply with relevant regulatory requirements and industry best practices.
2. Principles of Risk Management
Our risk management framework is guided by the following principles:
- Proactive: Regularly identify potential risks before they lead to incidents.
- Comprehensive: Assess risks across all relevant aspects of the xcPEP service, including technology, processes, and people.
- Contextual: Consider the specific context of our operations and the criticality of our information assets.
- Continuous Improvement: Regularly review and update risk assessments and mitigation strategies.
- Accountable: Clearly define roles and responsibilities for risk ownership and treatment.
3. Risk Identification
We identify risks through various methods, including:
- Threat intelligence gathering (e.g., industry reports, security advisories).
- Vulnerability scanning and penetration testing results.
- Internal audit findings and compliance reviews.
- Incident reports and post-mortems.
- Regular reviews of business processes and technological changes.
- Feedback from employees and customers.
4. Risk Assessment Methodology
Identified risks are assessed based on a combination of:
- Likelihood: The probability of a threat exploiting a vulnerability.
- Impact: The potential harm or damage resulting from a successful exploit (e.g., financial loss, reputational damage, operational disruption, regulatory fines, data loss).
Risks are quantified or qualitatively ranked (e.g., High, Medium, Low) to prioritize treatment efforts.
5. Risk Treatment
Once assessed, risks are managed through one or a combination of the following strategies:
- Risk Mitigation: Implementing controls to reduce the likelihood or impact of the risk (e.g., security controls, process changes, training).
- Risk Acceptance: Accepting the risk without further action, typically when the cost of mitigation outweighs the potential impact, and the risk is within acceptable tolerance levels.
- Risk Transfer: Shifting the risk to a third party (e.g., through insurance, contractual agreements with vendors).
- Risk Avoidance: Eliminating the activity or condition that gives rise to the risk.
6. Risk Review and Monitoring
- Frequency: Risk assessments are formally reviewed at least annually, or more frequently in response to significant changes in our environment (e.g., new services, major system changes, significant incidents, changes in regulatory landscape).
- Responsible Stakeholders: The Information Security Officer (ISO), in conjunction with the BCDR Committee and relevant departmental leads, is responsible for overseeing risk reviews.
- Monitoring: Implemented risk treatment controls are continuously monitored for effectiveness.
- Documentation: All identified risks, their assessments, treatment plans, and residual risks are meticulously documented in a central risk register. This register is updated regularly.
7. Roles and Responsibilities
- Management: Provides overall direction, approves risk tolerance levels, and allocates resources for risk treatment.
- Information Security Officer (ISO): Manages the risk assessment process, maintains the risk register, and reports on risk posture to management.
- Departmental Leads: Identify risks within their respective areas, participate in risk assessments, and implement agreed-upon risk treatment plans.
- Employees and Contractors: Responsible for reporting potential risks and adhering to risk mitigation controls.
8. Policy Review and Updates
This xcPEP Risk Assessment Policy is reviewed annually and updated as necessary to reflect changes in our operational environment, risk profile, and regulatory requirements.