Posted September 23, 2019
Vendor and Risk Management
Information Security Program
We have an Information Security Program in place that is communicated throughout the organization. Our Information Security Program follows the criteria set forth by the SOC 2 Framework. SOC 2 is a widely known information security auditing procedure created by the American Institute of Certified Public Accountants.
Our organization undergoes independent third-party assessments to test our security and compliance controls.
Third-Party Penetration Testing
We perform an independent third-party penetration at least annually to ensure that the security posture of our services is uncompromised.
Roles and Responsibilities
Roles and responsibilities related to our Information Security Program and the protection of our customer’s data are well defined and documented. Our team members are required to review and accept all of the security policies.
Security Awareness Training
Our team members are required to go through employee security awareness training covering industry standard practices and information security topics such as phishing and password management.
All team members are required to sign and adhere to an industry standard confidentiality agreement prior to their first day of work.
We perform background checks on all new team members in accordance with local laws.
Cloud Infrastructure Security
All of our services are hosted with Render. They employ a robust security program.
Data Hosting Security
All of our data is hosted on Render and AWS databases. These databases are located in the United States.
Encryption at Rest
All databases are encrypted at rest.
Encryption in Transit
Our applications encrypt in transit with TLS/SSL only.
We perform vulnerability scanning and actively monitor for threats.
Logging and Monitoring
We actively monitor and log various cloud services.
Business Continuity and Disaster Recovery
We use our data hosting provider’s backup services to reduce any risk of data loss in the event of a hardware failure. We utilize monitoring services to alert the team in the event of any failures affecting users.
We have a process for handling information security events which includes escalation procedures, rapid mitigation and communication.
Permissions and Authentication
Access to cloud infrastructure and other sensitive tools are limited to authorized employees who require it for their role. Where available we have Single Sign-on (SSO), 2-factor authentication (2FA) and strong password policies to ensure access to cloud services are protected.
Least Privilege Access Control
We follow the principle of least privilege with respect to identity and access management.
Quarterly Access Reviews
We perform quarterly access reviews of all team members with access to sensitive systems.
All team members are required to adhere to a minimum set of password requirements and complexity for access.
All company issued laptops utilize a password manager for team members to manage passwords and maintain password complexity.
Vendor and Risk Management
Annual Risk Assessments
We undergo at least annual risk assessments to identify any potential threats, including considerations for fraud.
Vendor Risk Management
Vendor risk is determined and the appropriate vendor reviews are performed prior to authorizing a new vendor.
If you have any questions, comments or concerns or if you wish to report a potential security issue, please contact [email protected].
Is Sparrow HIPAA compliant?
HIPAA applies specifically to health plans, health care clearinghouses, and health care providers. Sparrow is authorized to collect information for leave management in accordance with employment law, the Department of Labor (DOL), and the Equal Employment Opportunity Commission (EEOC). While HIPAA does not apply to Sparrow’s activities, we take security very seriously and strive to align with the security elements of HIPAA, also known as the Federal Privacy Act, that require reasonable administrative, technical, and physical safeguards in order to protect your employees’ data.
Is Sparrow CCPA compliant?
The California Consumer Privacy Act (CCPA) is a data privacy law that regulates businesses that collect or sell California consumer data and satisfies one of the following thresholds: (1) generates $25 million or more in annual revenue; or (2) possesses personal data for more than 50,000 “consumers, households, or devices;” or (3) earns more than half of its annual revenue selling consumers’ personal data. While Sparrow does not meet these entity requirements, we consider your employees’ privacy rights to be fundamental to our relationship. In that respect, we do not sell information to third parties, we explain what information is collected, we give the employee access to their information, and we do not discriminate against them when they choose to exercise their privacy rights.
Is Sparrow GDPR compliant?
Sparrow is based in the State of California in the United States. All of Sparrow’s operations, including data control and processing is located within the United States. Sparrow does not target or profile data subjects within the European Union. Therefore, Sparrow’s activities fall outside the scope of Union law and Sparrow is not required to comply with GDPR. That said, we strive to meet the accountability principles of GDPR:
- To process data lawfully, fairly, and in a transparent manner;
- To collect data for a specific, legitimate purpose and to not further process it in a manner incompatible with that purpose;
- To only collect what is necessary for the purpose of the processing;
- To maintain accuracy of the data;
- To minimize the retention of data with personally identifiable information; and
- To process in a manner to ensure appropriate security.