Vulnerability Management Policy (SEC-POL-008)

Vulnerability Management Policy (SEC-POL-008)

1. Objective

This policy establishes a systematic and continuous process for identifying, prioritizing, remediating, and verifying security vulnerabilities across all of [Company Name]’s information assets. The policy ensures that risks to the confidentiality and integrity of data are managed in a timely and effective manner.

2. Scope

This policy applies to all information systems and assets owned or managed by [Company Name], including servers, workstations, network devices, applications (both internally developed and third-party), and cloud infrastructure.

3. Policy

[Company Name] implements and maintains a comprehensive vulnerability management program that covers the full lifecycle of vulnerability identification, assessment, remediation, and verification.

3.1 Vulnerability Management Lifecycle

The program follows a continuous four-phase lifecycle:

1. Discovery: Vulnerabilities are identified through multiple methods:

  • Automated Scanning: Regular vulnerability scans of the environment
  • Threat Intelligence: Monitoring security feeds, vendor notifications, and public disclosures
  • Penetration Testing: Annual internal and external penetration tests
  • Manual Reporting: Reports from workforce members or external security researchers

2. Prioritization: All discovered vulnerabilities are assigned a severity rating using the Common Vulnerability Scoring System (CVSS) version 3.x, enhanced with contextual factors:

  • Asset Criticality: Based on business importance and data sensitivity
  • Exploitability: Likelihood of successful exploitation
  • Network Exposure: Internal vs. external accessibility
  • Threat Intelligence: Active exploitation in the wild

3. Remediation: Vulnerabilities are remediated by the responsible asset owner within defined timeframes based on severity rating. Remediation may include applying vendor patches, implementing configuration changes, or deploying compensating controls. All remediation activities follow the Change Control Policy (ENG-POL-002).

4. Verification: After remediation, the IT Manager/Security Officer performs verification scans to confirm successful resolution. All verification results are documented in the vulnerability tracking system.

3.2 Vulnerability Scanning

To ensure comprehensive vulnerability discovery, the following scanning schedule is maintained:

  • External Scans: Unauthenticated scans of all internet-facing systems performed at least weekly
  • Internal Scans: Authenticated scans of all internal production systems and workstations performed at least monthly
  • Application Scans: Dynamic and/or static analysis of in-house developed applications performed prior to major releases
  • Scan Result Processing: All vulnerability scan results are automatically ingested into a centralized tracking system with review within 1 business day

3.3 Remediation Timeframes

Vulnerabilities must be remediated within the following timeframes based on severity:

Severity CVSS Score Remediation Timeframe
Critical 9.0 - 10.0 30 days
High 7.0 - 8.9 30 days
Medium 4.0 - 6.9 90 days
Low 0.1 - 3.9 180 days

3.4 Exception Management

When vulnerabilities cannot be remediated within standard timeframes, a formal exception process applies:

  • Request: Asset owners submit formal exception requests including business justification, risk analysis, and proposed compensating controls
  • Approval: Exception requests require approval from the Security Lead (e.g., CTO or IT Manager)
  • Documentation: All approved exceptions are documented in a centralized risk register
  • Duration: Approved exceptions are temporary and reviewed quarterly

3.5 Compensating Controls

When remediation is not feasible, documented and testable compensating controls may be implemented to reduce the likelihood or impact of vulnerability exploitation. Compensating controls must be approved through the exception management process.

4. Standards and Controls

This policy maps to the following regulatory and compliance frameworks:

Section Framework Control
3.1 SOC 2 Trust Services Criteria CC7.1 - System Monitoring
3.2 SOC 2 Trust Services Criteria CC7.2 - System Monitoring
3.3 SOC 2 Trust Services Criteria CC7.3 - Evaluation and Response
All SOC 2 Trust Services Criteria CC6.1 - Logical Access Security

5. Definitions

Common Vulnerability Scoring System (CVSS): Industry standard framework for rating the severity of security vulnerabilities.

Compensating Control: Security measure implemented to provide alternative protection when primary controls cannot be applied.

Penetration Testing: Authorized simulated cyber attack to evaluate system security.

Vulnerability: Weakness in a system that could be exploited to compromise security.

Zero-Day Vulnerability: Previously unknown vulnerability for which no patch is available.

6. Responsibilities

Role Responsibility
IT Manager/Security Officer Oversee vulnerability management program, approve remediation plans, coordinate with asset owners, and ensure compliance with remediation timeframes.
IT Department Perform vulnerability scans, maintain scanning infrastructure, track vulnerabilities in central system, and verify successful remediation.
System Administrators Implement vulnerability remediation, apply patches and updates, deploy compensating controls, and maintain system security configurations.
Asset Owners Approve remediation plans for their systems, coordinate remediation activities, submit exception requests when needed, and ensure business continuity during remediation.
All Workforce Members Report suspected vulnerabilities, comply with patch management procedures, and support vulnerability remediation activities as required.