25 SEC Information Security Program Policies

25 SEC Information Security Program Policies
Photo by Scott Graham / Unsplash

For easy configuration, each policy comes with a standard Docx Template. Moreover, a questionnaire accompanies each policy to extract necessary information and stimulate critical thinking for the team to meet the policy requirements.

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November 20th, 2023 Updated

The 8-K Filing: Navigating Disclosure Requirements During a Breach
In the wake of a cybersecurity incident, public companies in the U.S. face not only the immediate challenges of containment and remediation but also a myriad of regulatory and disclosure obligations. One such requirement is the filing of a Form 8-K with the U.S. Securities and Exchange Commission

SEC Compliance and Integrity Policy: Ensuring overall adherence to SEC regulations, focusing on integrity in financial reporting and internal controls.

Insider Trading and Securities Compliance Policy: Establishing rules to prevent and monitor illegal insider trading and to report transactions in line with SEC regulations.

Financial Reporting Accuracy Policy: Implementing controls for accurate, complete, and timely financial reporting, complying with SEC requirements.

Disclosure and Transparency Policy: Developing robust disclosure controls to ensure material company information is correctly disclosed.

Fair Public Communication and Social Media Policy: Regulating public communications, including social media, to comply with SEC disclosure rules and Reg FD.

Record Retention and Management Policy: Outlining specific requirements for record retention, ensuring compliance with SEC regulations.

Corporate Governance and Ethics Policy: Establishing guidelines for corporate governance practices, including board responsibilities, ethical conduct, and alignment with SEC regulations.
Whistleblower Protection Policy: Safeguarding whistleblowers under the SEC’s program, encouraging reporting of violations of securities laws.

Investor Relations and Engagement Policy: Standardizing communications with investors to ensure consistency, transparency, and compliance with SEC regulations.

Cybersecurity Risk and Incident Disclosure Policy: Outlining procedures for disclosing cybersecurity risks and incidents as per SEC guidance.

Audit Committee Oversight Policy: Defining roles and responsibilities of the audit committee, including oversight of financial reporting and compliance with SEC requirements.

Internal Controls over Financial Reporting (ICFR) Policy: Ensuring effective internal controls over financial reporting in compliance with SOX.

Material Information Management Policy: Setting procedures for managing and disclosing material information in compliance with SEC rules.

Regulatory Filing and Reporting Policy: Ensuring timely and accurate submission of all required regulatory filings to the SEC.

Compliance with Sarbanes-Oxley Act (SOX) Policy: Adhering to SOX regulations, particularly focusing on management and auditors’ responsibilities.

Securities Trading and Blackout Policy: Guidelines for trading in the company's securities, blackout periods, and pre-clearance procedures.

Executive Compensation and Disclosure Policy: Transparent and accurate disclosure of executive compensation as per SEC requirements.

Related Party Transactions Disclosure Policy: Identifying, monitoring, and disclosing related party transactions in line with SEC regulations.

Proxy Statement and Shareholder Communication Policy: Procedures for proxy statement preparation and shareholder communication that meet SEC standards.

Regulation S-K Compliance Policy: Adhering to Regulation S-K for non-financial statement disclosures in SEC filings.

Investment Advisory and Broker-Dealer Compliance Policy: For firms offering advisory services or broker-dealer operations, ensuring compliance with relevant SEC rules and FINRA regulations.

Market Conduct and Anti-Manipulation Policy: Policies addressing market conduct, anti-money laundering, and prevention of market manipulation.

Emergency and Contingency Planning Policy: Developing emergency operation plans, including contingency planning for significant disruptions.

Data Protection and Privacy Policy (SEC Focus): Protecting financial and investor data, ensuring privacy and security as per SEC guidance.

Risk Assessment and Compliance Monitoring Policy: Identifying, assessing, and managing risks related to SEC compliance and monitoring adherence to these policies.

The 8-K Filing in the Crosshairs of Compliance and Fines
When a publicly traded company in the U.S. faces a significant cybersecurity incident, the immediate aftermath involves a whirlwind of containment, remediation, and communication efforts. Central to this is the Form 8-K filing with the U.S. Securities and Exchange Commission (SEC). But beyond the 8-…

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The Executive Order on Strengthening and Promoting Innovation in the Nation’s Cybersecurity, signed by President Biden

The Executive Order on Strengthening and Promoting Innovation in the Nation’s Cybersecurity, signed by President Biden

The Executive Order on Strengthening and Promoting Innovation in the Nation’s Cybersecurity, signed by President Biden on January 16, 2025, is a comprehensive document outlining various measures aimed at bolstering cybersecurity across the United States. BidenEOCyberBidenEOCyber.pdf205 KBdownload-circle Key points include: 1. Enhancing Accountability for Software Providers: * Requirements for

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