Initial Stage - Absence of Formal Security Policies:
In CW&L’s early years, the company operated with minimal formal security policies. This gap was primarily due to a lack of understanding of the importance of comprehensive security policies in establishing a security-conscious culture within the organization.
Recognizing the Need for Change:
The 2018 data breach was a wake-up call for CW&L. It highlighted the weaknesses in their security posture and the urgent need for robust security policies. This realization marked the beginning of their journey towards developing and implementing comprehensive security policies.
Formulation Stage - Developing the Security Policies:
CW&L began by creating a security policy development team composed of key stakeholders from various departments. Their first task was to identify the areas that needed to be addressed in the security policies, such as access control, data protection, incident response, and more.
They then went on to draft detailed policies for each area, considering best practices and compliance requirements like those of PCI DSS. These policies included password policies, encryption policies, remote access policies, and more.
Implementation Stage - Rolling out the Policies:
After the policies were created, they were reviewed by the legal team to ensure they met all regulatory requirements. They were then approved by the senior management team and rolled out to the entire organization.
To ensure everyone was aware of the new policies, CW&L held company-wide training sessions. These sessions explained the policies in detail, their importance, and the consequences of non-compliance.
Review and Update Stage - Ensuring Policies Stay Relevant:
CW&L established a review process to ensure the policies remained current and effective. This process involved a yearly review of all policies, or whenever significant changes occurred within the organization or in the regulatory landscape.
Current Status - Maintaining Robust and Up-to-date Security Policies:
Today, CW&L’s security policies are robust, current, and crucial to maintaining a strong security posture. The journey from an absence of formal security policies to a comprehensive set of up-to-date security policies has played a significant role in achieving and maintaining PCI DSS v4.0 compliance. These policies have also fostered a culture of security consciousness within the organization, ensuring that security is a consideration in all aspects of CW&L’s operations.