​15​ Vulnerability Scanning Policy

EA is proactive about information security and understands that vulnerabilities need to be monitored on an ongoing basis. EA utilizes various penetration testing tools to consistently scan, identify, and address vulnerabilities on our systems. We also utilize OSSEC on all systems, including logs, for file integrity checking and intrusion detection.

​15.1​ Vulnerability Scanning Policy

1. Vulnerability detection is performed by the EA Security Officer with assistance from the CTO.
2. Vulnerability scans are performed against all internal IP addresses (servers, VMs, etc) on EA networks.
3. Frequency of scanning is as follows:
   1. on a weekly basis;
   2. after every production deployment.
4. Reviewing vulnerability reports and findings, as well as any further investigation into discovered vulnerabilities, are the responsibility of the EA Security Officer. The process for reviewing Vulnerability reports is outlined below:
   1. The Security Officer initiates the review of a Vulnerability Report by creating an Issue in the Asana Compliance Review Activity (CRA) Project.
   2. The Security Officer, or an EA Security Engineer assigned by the Security Officer, is assigned to review the Vulnerability Report.
   3. If new vulnerabilities are found during review, the process below is used to test those vulnerabilities is outlined below. Once those steps are completed, the Issue is then reviewed again.
   4. Once the review is completed, the Security Officer approves or rejects the Issue. If the Issue is rejected, it goes back for further review.
   5. If the review is approved, the Security Officer then marks the Issue as Done, adding any pertinent notes required.
5. In the case of new vulnerabilities, the following steps are taken:
   1. All new vulnerabilities are verified manually to assure they are repeatable. Those not found to be repeatable are manually tested after the next vulnerability scan, regardless of if the specific vulnerability is discovered again.
   2. Vulnerabilities that are repeatable manually are documented and reviewed by the Security Officer, CTO, and Privacy Officer to see if they are part of the current risk assessment performed by EA.
      1. Those that are a part of the current risk assessment are checked for mitigations.
      2. Those that are not part of the current risk assessment trigger a new risk assessment, and this process is outlined in detail in the EA Risk Assessment Policy.
6. All vulnerability scanning reports are retained for 6 years by EA. Vulnerability report review is monitored on a quarterly basis using Asana reporting to assess compliance with above policy.
7. Penetration testing is performed regularly as part of the EA vulnerability management policy.
   1. Internal penetration testing is performed quarterly. Below is the process used to conduct internal penetration tests.
      1. The Security Officer initiates the penetration test by creating an Issue in the Asana Compliance Review Activity (CRA) Project.
      2. The Security Officer, or an EA Security Engineer assigned by the Security Officer, is assigned to conduct the penetration test.
      3. Gaps and vulnerabilities identified during penetration testing are reviewed, with plans for correction and/or mitigation, by the EA Security Officer before the Issue can move to be approved.
      4. Once the testing is completed, the Security Officer approves or rejects the Issue. If the Issue is rejected, it goes back for further testing and review.
      5. If the Issue is approved, the Security Officer then marks the Issue as Done, adding any pertinent notes required.
   2. Penetration tests results are retained for 6 years by EA.
   3. Internal penetration testing is monitored on an annual basis using Asana reporting to assess compliance with above policy.
8. This vulnerability policy is reviewed on a quarterly basis by the Security Officer and Privacy Officer.