Risk Management Policy
Policy Owner: Paul Jones
Version: 2.1
Effective Date: 2021-07-06
Last Reviewed: 2026-02-24
1. Purpose
To ensure that information security and operational risks are identified, evaluated, and managed in a manner proportionate to the size and complexity of Crystal Project Inc.
2. Scope
This policy applies to:
- Information systems and infrastructure
- Customer data
- Business-critical processes
- Third-party vendors and service providers
- Software development and deployment practices
3. Risk Management Principles
Crystal Project applies a pragmatic, risk-based approach to security governance.
Risk management activities include:
- Identification of security and operational risks
- Evaluation of likelihood and impact
- Prioritization of remediation efforts
- Documentation of significant risks and treatment decisions
- Periodic review by leadership
Risk evaluation considers potential impact to:
- Confidentiality
- Integrity
- Availability
- Privacy
- Regulatory obligations
- Business continuity
4. Risk Identification Sources
Risks may be identified through:
- Annual third-party penetration testing
- Vulnerability scanning and monitoring tools
- Security incident postmortems
- Formal tabletop exercises conducted regularly (at least annually)
- Vendor risk reviews
- Software design and architecture reviews
- Operational experience and engineering judgment
Tabletop exercises are used to evaluate incident readiness, identify gaps, and improve response procedures.
5. Risk Evaluation
Identified risks are assessed based on:
- Likelihood of occurrence
- Potential operational or security impact
- Exploitability
- Exposure of customer or sensitive data
- Reputational or contractual implications
Risk scoring may be qualitative or quantitative depending on context.
Management retains discretion to adjust automated or third-party severity ratings based on contextual risk.
6. Risk Treatment
For each significant risk, one of the following responses may be selected:
- Mitigate
- Accept
- Transfer
- Avoid
Material risks and their treatment decisions are documented.
Risk remediation prioritization considers:
- Severity
- Resource availability
- Operational impact
- Customer commitments
7. Risk Review and Oversight
Risk posture is reviewed periodically by leadership.
Formal reviews may occur in conjunction with:
- Annual penetration testing
- Tabletop exercises
- Security reviews
- Audit preparation
- Strategic planning discussions
Significant risks are communicated to executive leadership as appropriate.
8. Continuous Improvement
Security incidents, tabletop exercises, and postmortems are used to:
- Identify systemic weaknesses
- Improve controls
- Update policies and procedures
- Reduce recurrence risk
Lessons learned are incorporated into operational practices.
9. Exceptions
Exceptions must:
- Be documented
- Include justification
- Be approved by the Policy Owner
10. Violations and Enforcement
Violations may result in:
- Corrective action
- Disciplinary measures
- Termination of engagement where appropriate
11. Review and Revision History
| Version | Date | Description | Author | |----------|------------|-------------|----------| | 1.0 | 2021-07-06 | Initial Version | Jona Morua | | 2.1 | 2026-02-24 | Simplified and aligned to operational practice | Paul Jones |