Blue Sky eLearn's policies and practices around our Information Security Program and describes the steps we take to ensure our company and clients' information is secure.
Path LMS takes accessibility seriously to ensure that all of our users are able to have a great experience on the platform. View our latest VPAT report on how Path LMS adheres to WCAG 2.1 AA accessibility compliance.
Security Whitepaper
This whitepaper provides a comprehensive overview of Blue Sky eLearn's Trust and Security programs, policies, and controls.
21 CFR Part 11 Attestation
Path eClinical is an LMS tailored for Clinical Trial Training. As part of our commitment to excellence, we maintain robust FDA 21 CFR Part 11 controls on the platform to ensure reliable and high quality outcomes for our clients.
PCI Compliance
Path LMS utilizes a PCI Level 1 Compliant payment processor to ensure compliance and security of payments on the platform. We also maintain PCI 4.0.1 SAQ A.
SOC 2 Report
Path LMS is reviewed annually by independent third party auditors for SOC 2 Type 2 certification.
Privacy
Link to our Privacy Policy which includes information on our privacy policies, cookie policies, as well as GDPR, CCPA, and DPF.
Monitoring
Change Management
Configuration and Asset Management Policy
A Configuration and Asset Management Policy governs configurations for new sensitive systems
Production Data Use is Restricted
Production data is not used in the development and testing environments, unless required for debugging customer issues.
Approval for System Changes
System changes are approved by at least 1 independent person prior to deployment into production.
Secure Development Policy
A Secure Development Policy defines the requirements for secure software and system development and maintenance.
Change Management Policy
A Change Management Policy governs the documenting, tracking, testing, and approving of system, network, security, and infrastructure changes.
Availability
Business Continuity and Disaster Recovery Policy
Business Continuity and Disaster Recovery Policy governs required processes for restoring the service or supporting infrastructure after suffering a disaster or disruption.
Organizational Management
Performance Review Policy
A Performance Review Policy provides personnel context and transparency into their performance and career development processes.
Information Security Policy
An Information Security Policy establishes the security requirements for maintaining the security, confidentiality, integrity, and availability of applications, systems, infrastructure, and data.
Organizational Chart
Management maintains a formal organizational chart to clearly identify positions of authority and the lines of communication, and publishes the organizational chart to internal personnel.
Background Checks
Background checks or their equivalent are performed before or promptly after a new hires start date, as permitted by local laws.
Disciplinary Action
Personnel who violate information security policies are subject to disciplinary action and such disciplinary action is clearly documented in one or more policies.
Acceptable Use Policy
An Acceptable Use Policy defines standards for appropriate and secure use of company hardware and electronic systems including storage media, communication tools and internet access.
Independent Advisor
The board of directors or equivalent entity function includes senior management and external advisors, who are independent from the company's operations. An information security team has also been established to govern cybersecurity.
Roles and Responsibilities
Information security roles and responsibilities are outlined for personnel responsible for the security, availability, and confidentiality of the system.
Internal Control Monitoring
A continuous monitoring solution monitors internal controls used in the achievement of service commitments and system requirements.
Cybersecurity Insurance
Cybersecurity insurance has been procured to help minimize the financial impact of cybersecurity loss events.
New Hire Screening
Hiring managers screen new hires or internal transfers to assess their qualifications, experience, and competency to fulfill their responsibilities. New hires sign confidentiality agreements or equivalents upon hire.
Security Awareness Training
Internal personnel complete annual training programs for information security to help them understand their obligations and responsibilities related to security.
Internal Control Policy
An Internal Control Policy identifies how a system of controls should be maintained to safeguard assets, promote operational efficiency, and encourage adherence to prescribed managerial policies.
Performance Reviews
Internal personnel are evaluated via a formal performance review at least annually
Personnel Acknowledge Security Policies
Internal personnel review and accept applicable information security policies at least annually.
Code of Conduct
A Code of Conduct outlines ethical expectations, behavior standards, and ramifications of noncompliance.
Confidentiality
Data Retention and Disposal Policy
A Data Retention and Disposal Policy specifies how customer data is to be retained and disposed of based on compliance requirements and contractual obligations.
Data Classification Policy
A Data Classification Policy details the security and handling protocols for sensitive data.
Vulnerability Management
Third-Party Penetration Test
A 3rd party is engaged to conduct a network and application penetration test of the production environment at least annually. Critical and high-risk findings are tracked through resolution.
Vulnerability and Patch Management Policy
A Vulnerability Management and Patch Management Policy outlines the processes to efficiently respond to identified vulnerabilities.
Incident Response
Lessons Learned
After any identified security incident has been resolved, management provides a "Lessons Learned" document to the team in order to continually improve security and operations.
Incident Response Plan
An Incident Response Plan outlines the process of identifying, prioritizing, communicating, assigning and tracking confirmed incidents through to resolution.
Tracking a Security Incident
Identified incidents are documented, tracked, and analyzed according to the Incident Response Plan.
Risk Assessment
Risk Assessment and Treatment Policy
A Risk Assessment and Treatment Policy governs the process for conducting risk assessments to account for threats, vulnerabilities, likelihood, and impact with respect to assets, team members, customers, vendors, suppliers, and partners. Risk tolerance and strategies are also defined in the policy.
Vendor Risk Assessment
New vendors are assessed in accordance with the Vendor Risk Management Policy prior to engaging with the vendor. Reassessment occurs at least annually.
Vendor Risk Management Policy
A Vendor Risk Management Policy defines a framework for the onboarding and management of the vendor relationship lifecycle.
Risk Assessment
Formal risk assessments are performed, which includes the identification of relevant internal and external threats related to security, availability, confidentiality, and fraud, and an analysis of risks associated with those threats.
Risk Register
A risk register is maintained, which records the risk mitigation strategies for identified risks, and the development or modification of controls consistent with the risk mitigation strategy.
Vendor Due Diligence Review
Vendor SOC 2 reports (or equivalent) are collected and reviewed on at least an annual basis.
Network Security
Network Security Policy
A Network Security Policy identifies the requirements for protecting information and systems within and across networks.
Access Security
Asset Inventory
A list of system assets, components, and respective owners are maintained and reviewed at least annually
Encryption and Key Management Policy
An Encryption and Key Management Policy supports the secure encryption and decryption of app secrets, and governs the use of cryptographic controls.
User Access Reviews
System owners conduct scheduled user access reviews of production servers, databases, and applications to validate internal user access is commensurate with job responsibilities.
Unique Access IDs
Personnel are assigned unique IDs to access sensitive systems, networks, and information
Access to Product is Restricted
Non-console access to production infrastructure is restricted to users with a unique SSH key or access key
Access Control and Termination Policy
An Access Control and Termination Policy governs authentication and access to applicable systems, data, and networks.
Physical Security
Physical Security Policy
A Physical Security Policy that details physical security requirements for the company facilities is in place.
Communications
Communication of Security Commitments
Security commitments and expectations are communicated to both internal personnel and external users via the company's website.
Terms of Service
Terms of Service or the equivalent are published or shared to external users.
Privacy Policy
A Privacy Policy to both external users and internal personnel. This policy details the company's privacy commitments.
Communication of Critical Information
Critical information is communicated to external parties, as applicable.
