Written policy versus what is actually configured
10 statements from the Board-approved Information Security Policy v4.2, each compared with the live access and configuration it governs. 8 have drifted.
Policy §6.1 says
Privileged accounts are vaulted, with credentials rotated at least every 90 days.
Privilege Cloud shows · 2 h ago
23 domain-privileged service accounts outside the vault; oldest credential 604 days.
PR-01 · ev-pr01-1Policy §6.4 says
Administrators sign in only with a phishing-resistant factor.
Entra ID shows · 1 h ago
400 of 412 privileged administrators on FIDO2 or Windows Hello; 12 still use push approval.
PR-02 · ev-pr02-1Policy §5.2 says
MFA applies to every user; any exception expires within 30 days.
Entra ID shows · 1 h ago
84 users excluded from CA-014; the exception expired 63 days ago.
PR-02 · ev-pr02-2Policy §7.1 says
Access recertification removes unreviewed access by default.
Entra ID shows · 30 h ago
Q3 review closed at 89% reviewed; default for unreviewed: keep access.
PR-04 · ev-pr04-1Policy §7.3 says
Firewall exceptions carry an approval and expire within 30 days.
Panorama shows · 2 h ago
TEMP-MIGRATION-CDE-DB allows CORP-ANY to the CDE database tier with no expiry and no review.
PR-06 · ev-pr06-1Policy §8.2 says
Security logs are kept for 365 days.
Policy §8.5 says
Transaction logs are tamper-evident and kept for 5 years.
Fraud management system shows · 5 h ago
Write-once, hash-chained store; retention 1,826 days; integrity check passed.
PR-03 · ev-pr03-3Policy §9.1 says
Internet-facing critical vulnerabilities are fixed within 15 days.
Vulnerability Management shows · 9 h ago
Median 21 days over 90 days; 6 open beyond 15 days.
ID-02 · ev-id02-1Policy §9.4 says
Every managed endpoint has full-disk encryption.
Defender and Intune shows · 1 h ago
11,632 of 11,702 encrypted (99.4%); 70 in the grace period with remediation queued.
PR-05 · ev-pr05-1Policy §11.2 says
Each tier-one system has a restore test every 12 months.
Security Cloud shows · 7 h ago
Payments gateway last tested 16 months ago; card management 14 months ago.
RC-02 · ev-rc02-1