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Control Self-Assessment — October 2026

Purpose. A dated, signed-off assessment of every control in the SOC 2 Type 1 checklist: whether it is operating, and if not, what is missing and who has it. It follows the first pass in the SOC 2 Type 1 Readiness form (2026-09-01) and takes in the auditor's spot check (Will Ruskin, GetAgency, 2026-09-24). Repeated quarterly.

A self-assessment that finds nothing was not really done. This one corrects four rows that the 9 September sheet marked Done without the evidence to back them (2, 47, 59, 60).

Assessment date: 13 October 2026 · Assessed by: the ISMS, against the evidence store, the repository and Linear · Reviewed and approved by: the Information Security Manager (approval front-matter)

Summary

🟡 In hand: 8, ✅ Operating: 53, ➖ N/A: 4, 🔴 Gap: 3 of 68 controls.

Rows still 🔴 or 🟡 are tracked in Linear project SOC 2 Type 1 — audit readiness. Each closes when its evidence is filed against the checklist row.

Controls

Row CC Control Status Basis / open item
1 CC1.1 Code of conduct & disciplinary policy 🟡 In hand HR Security Policy (incl. §2.3 disciplinary) and Acceptable Use Policy approved. Signed policy acknowledgements issued to all five people on 13 Oct.
2 CC1.1 Confidentiality agreements (NDAs) 🟡 In hand NDA template approved. Signed confidentiality agreements (founder undertakings, CyberSquad NDA) issued for signature 13 Oct. The 9 Sep pack held only the template.
3 CC1.1 Employment agreements 🟡 In hand Founder Confidentiality & Security Undertaking approved (2026-09-01). One signed copy per founder issued 13 Oct.
4 CC1.1 Contractor agreements 🟡 In hand CyberSquad agreement v0.3 issued for signature 13 Oct (unsigned since 1 Sep).
5 CC1.2 Board / leadership oversight of security ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
6 CC1.2 Board charter ➖ N/A No separate board: four founder-shareholders. Accepted by GetAgency (Tad Kozusko, 24 Sep).
7 CC1.2 Board expertise documented ➖ N/A As row 6. Accepted 24 Sep.
8 CC1.3 Org chart & defined reporting lines 🟡 In hand Dated organisation chart ISMS-DOC-05-5 drafted; approval gives it its date. Undated screenshots set aside.
9 CC1.3 Assign a security owner ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
10 CC1.4 Job descriptions & competence ✅ Operating Roles, Responsibilities & Authorities (ISMS-DOC-05-2 v0.3, approved 2026-09-08) serves as the job descriptions, as the auditor suggested.
11 CC1.4 Background checks 🟡 In hand HR Security Policy §2.1: founders not screened by design; no non-founder hires. External consultant's screening record ISMS-FORM-A06-1-2 awaiting the ISM's completion.
12 CC1.5 Performance reviews & accountability ➖ N/A No employees to review. Accepted 24 Sep.
13 CC2.1 Information Security Policy ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
14 CC2.2 Security awareness training ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
15 CC2.2 Policies shared with all staff ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
16 CC2.2 Whistleblower policy & anonymous channel ➖ N/A No staff to protect anonymously at this size; reporting channels in row 21. Accepted 24 Sep.
17 CC2.2 System changes communicated to staff ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
18 CC2.3 Customer-facing security commitments ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
19 CC2.3 Master Service Agreement (MSA) ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
20 CC2.3 System Description ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
21 CC2.3 Channel for reporting security concerns ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
22 CC2.3 Customer support channel ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
23 CC2.3 Customers notified of critical changes ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
24 CC3.1 Defined business & security objectives ✅ Operating Information Security Objectives & Plan v0.3 approved 2026-09-29.
25 CC3.2 Annual risk assessment ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
26 CC3.3 Fraud risk considered ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
27 CC3.4 Assess impact of major changes ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
28 CC4.1 Periodic control self-assessment ✅ Operating This document.
29 CC4.2 Track and remediate deficiencies ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
30 CC5.1 Controls mapped to risks ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
31 CC5.2 Technology controls selected ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
32 CC5.3 Policies enacted through procedures ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
33 CC6.1 Access control policy & least privilege ✅ Operating Access Control Policy v0.5 approved 2026-09-29.
34 CC6.1 MFA on all critical systems ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
35 CC6.1 Password manager & password policy ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
36 CC6.1 Data classification policy ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
37 CC6.1 Production asset inventory ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
38 CC6.2 Access provisioning on hire ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
39 CC6.3 Access removal on departure & quarterly review ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
40 CC6.4 Physical access / office & devices ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
41 CC6.5 Secure disposal of data & devices ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
42 CC6.5 Data retention & disposal procedures ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
43 CC6.5 Customer data deletion on departure ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
44 CC6.6 Perimeter protection (firewalls, network) ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
45 CC6.6 Network segmentation & diagram 🟡 In hand Network Architecture & Segmentation ISMS-DOC-A08-22-1 drafted from the OpenTofu source; awaiting approval.
46 CC6.6 Annual firewall rule review ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
47 CC6.7 Encryption in transit 🟡 In hand TLS everywhere, but pentest finding #1: legacy CBC/RSA suites still accepted at Cloudflare's edge for app.soon.works (S-607). The API load balancer already refuses them.
48 CC6.7 Encryption at rest ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
49 CC6.7 Encryption key management ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
50 CC6.8 Endpoint protection & malware defense ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
51 CC7.1 Vulnerability & patch management ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
52 CC7.1 Annual penetration test ✅ Operating Penetration test 21–22 Sep 2026, report 24 Sep: low risk, 1 low and 3 informational. Remediation and risk acceptance: ISMS-FORM-A08-8-3.
53 CC7.1 Hardening standards ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
54 CC7.2 Logging in your cloud environment ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
55 CC7.2 Intrusion detection (IDS) ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
56 CC7.2 Infrastructure & performance monitoring ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
57 CC7.3 Security incidents evaluated ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
58 CC7.4 Incident response plan ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
59 CC7.4 Annual incident response test 🔴 Gap Not yet operating. The incident-response test had not been held. The 9 Sep sheet showed this row as Done without evidence; corrected here. Exercise pack ISMS-FORM-A05-30-2.
60 CC7.5 Recovery from incidents (backups & restore test) 🔴 Gap Not yet operating. Backup Policy approved, but the first restore test (S-412) had not been run. Corrected from Done. To be performed live in the ISMS-FORM-A05-30-2 exercise.
61 CC8.1 Change management process ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
62 CC8.1 Infrastructure changes controlled ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
63 CC8.1 SDLC policy ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
64 CC8.1 Configuration management ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
65 CC9.1 Business continuity / disaster recovery plan ✅ Operating Business Continuity & Disaster Recovery Plan ISMS-DOC-A05-30-1 approved 2026-09-01. The 9 Sep pack attached the availability policy instead; corrected.
66 CC9.1 Tabletop disaster recovery test (annual) 🔴 Gap Not yet operating. DR tabletop not yet held; same exercise as rows 59–60.
67 CC9.2 Vendor management & review ✅ Operating Evidenced in the 9 September 2026 pack; no change since.
68 CC9.2 Vendor agreements with confidentiality terms ✅ Operating Evidenced in the 9 September 2026 pack; no change since.

Change log

Version Date Author Change
0.1 2026-10-13 ISMS First quarterly self-assessment, for checklist row 28 (CC4.1).