Vulnerability Management

Zayo implements application security controls on its internal environment systems and applications. Customers must implement their own security controls to protect their own environments.

Does Zayo deploy application firewalls and block unauthorized access to critical systems?

Yes.

Which controls are included in Zayo secure coding practices?

• Protect applications from insufficient anti-automation
• Protect applications from improper access control
• Protect applications from improper error handling
• Protect applications from insecure communications
• Protect applications from attacks on business logic
• Protect applications from format string attacks
  Protect applications from XML external entities
• Protect applications from insecure deserialization
• Refrain from hard-coding security parameters in source code
• Protect applications from injection flaws
• Protect applications from attacks on data and data structures
• Control user account management
• Restrict direct access of databases to the database administrator
• Protect applications from buffer overflows
• Protect applications from cross-site scripting
• Protect against coding vulnerabilities
• Protect applications from broken authentication and session management
• Protect applications from insecure cryptographic storage
• Protect applications from cross-site request forgery
• Protect databases from unauthorized database management actions
• Refrain from displaying error messages to end users

Which practices are implemented into Zayo’s software development lifecycle?

• Define and document business needs, assess security risks, and establish governance requirements
• Separate development environments from production environments
• Develop secure architecture and establish security controls before development begins
• Ensure secure coding practices and integrate security testing into development
• Implemented separation of duties between developer and production support teams
• Masking/obfuscation of data during testing and destroys data upon completion
• Validate security, compliance, and resilience through rigorous testing
• Ensure secure deployment with change management and monitoring
• Sustain security post-deployment with continuous monitoring and risk management
• Securely retire systems while mitigating risks

Which types of application penetration testing does Zayo perform?

• Web application scanning
• Mobile application penetration testing
• Dynamic code analysis (i.e. DAST, black-box, gray-box testing)
• Static code analysis (i.e. SAST, White-box testing)
• Interactive code analysis (i.e. IAST or RIA)
• Software Composition Analysis
• Application Threat Modeling
• Runtime Application Software Protection (i.e. RASP)

Is security tested as part of the development process for any system or application?

Any new and updated systems must go through testing during the development process. This testing must include the schedule of activities to complete, test inputs, as well as the expected outputs for the conditions being tested. Where applicable, according to the importance and nature of the system, independent acceptance testing must be completed to ensure that the system or code works as expected.

What is covered by application allow listing technology?

Application allow listing technology covers executables, code libraries, and scripts.

How does Zayo control execution of unauthorized software?

Application allow listing technology is deployed on all devices to control software execution and is updated at least bi-annually.

Does Zayo have a policy restricting the installation of software on company-issued devices?

Yes. Software must be approved and installed on company-issued devices by a System Administrator. Internal acceptable use of assets requirements are discussed in the Operational Management Standard. Zayo does not share governance documents in their entirety as they are treated as internal resources that are proprietary in nature. This fosters accountability and confidentiality, guiding teams through crises while ensuring compliance with industry standards. This approach underscores Zayo’s commitment to resilience and security.

Zayo implements security controls on its internal environment, systems, and applications. Customers must implement their own security controls to protect their own environments.

Does Zayo protect all sensitive information at rest?

Data at rest is encrypted, including all removable media (USB sticks, CDs, etc.), and there is a tool in place to prevent and monitor data loss.

Does Zayo protect sensitive information data in transit?

Data in transit encrypted and there is a tool in place to prevent and monitor data loss.

What customer data is collected or processed by Zayo?

Please refer to the Privacy Policy.

Is customer data hosted by Zayo?

No. While Zayo has protections in place to protect all data, Zayo does not host customer data. Processing and/or storage of personal data transferred by customers is limited to contact information (e.g., names, addresses, contact details, IP addresses) of customer employees, representatives, contractors or agents who are involved or interact with Zayo in the provision of services by Zayo to the customer under the agreement.  Zayo is not the controller of customer data. 

Will Zayo affiliates, subsidiaries, or parent companies have access to customer data?

Please refer to the Privacy Policy.  

Will data be shared with any third parties at any point?

Please refer to the Privacy Policy.

Is the organization PCI-DSS certified as its defined Merchant level?

With regards to PCI, Zayo is both a Merchant and a Service Provider. In both instances, the scope of responsibilities the Organization shares in protecting PCI is limited, as Zayo does not store, transmit, process, or dispose of cardholder data or maintain a Cardholder Data Environment (CDE).

• Merchant: Zayo accepts credit card payments from Customers through customer account management portals and an Integrated Voice Response (IVR) system. These mechanisms provide a branded interface (wrapper) and coded redirects where Customers engage directly with third party payment processors. Third party payment processors use tokenized authorization methods to confirm identity and access before accepting, storing, or processing cardholder data on behalf of Zayo. Zayo complies with its PCI requirements and completes an SAQ-A-ER on an annual basis.
• Service Provider: Zayo provides services that may impact the security of Customers who store, transmit, process, or dispose of cardholder data. As a Service Provider, Zayo and its Customers have shared PCI responsibilities. Customers are responsible for protecting its cardholder data and CDE, and Zayo is responsible for protecting the network and service components of the Customer CDE. Zayo complies with its PCI requirements completes Attestations of Compliance (AOCs) for its relevant service provider services annually. For more information about shared PCI responsibilities, refer to the PCI-DSS v4.0 Service Provider Responsibility Matrix.

What are your employees able to access when working remotely?

Virtual applications and desktop solutions, with full access to corporate data, internal and external systems.

Does Zayo classify its data to identify additional controls to safeguard information? (e.g. personally identifiable information, intellectual property, health data)

Data is classified regularly, during significant changes, and includes all use cases.

Does Zayo have a Data Classification Policy?

To ensure appropriate protection and handling of data, the Organization uses two classification criteria: Sensitivity and Criticality. Information owners, data custodians, and the Security Manager are responsible for ensuring that relevant information and systems are classified appropriately. For information on how to label physical assets, reach out to the appropriate team manager for documentation on the procedure. The labels must be easily recognizable and the labeling must be consistent with the classifications defined herein. If an asset or a document is not labeled, it must be considered as “Internal Use”.

The following sensitivity categories shall be used:

• Restricted – This is the highest classification. It applies to information that is highly sensitive and critical to the business. Unauthorized disclosure of this information could result in the inability to conduct business, severely impact the financial stability of the company, attract significant legal liability or place the company at a serious competitive disadvantage. Sensitive personal information of Users, which includes but is not limited to Social Insurance Number (SIN), Social Security Number (SSN) or Government- issued number, date of birth (DOB) and credit card numbers, etc. is also classified as restricted.
• Confidential – Confidential information is shared on a need-to-know basis only, and it must only be shared with those on the distribution list for that information. 
• Internal Use – This classification relates to all Organization business information. Access to this information must be restricted to Users in the Organization, and is not for general distribution outside of the organization. Examples include but are not limited to: general benefits program information, employee wellness descriptions, and other employee content.
• Public – This is information that can be presented to users outside of the Organization. This is data where its disclosure would not adversely affect the company, its Users, its Suppliers, or its customers. Examples include content for public-facing web properties, job postings, and public corporate contact information (e.g., mailing address, monitored phone numbers, and customer service contact information).

Which tools are used to protect data?

• Mobile Device Management, including remote wipe capability and password management, is in place to safeguard against data leakage
• Email monitoring tools to recognize, block, and limit potentially unsafe attachments, links, executables, etc.
• Web, phishing, document isolation through cloud-based virtualization
• Heuristic-based scanning to detect and prevent file encryption

Does Zayo have a cybersecurity Incident Response Plan?

Yes. Zayo’s cybersecurity Incident Response Plan is in place and addresses the following:

• Identification of a cyber security incident
• Investigation of the situation (including triage)
• Taking appropriate action (e.g. containing the incident and eradicating its source)
• Reporting to relevant stakeholders
• Recovering from a cyber security incident

How often does Zayo review and update incident response plans?

Incident response plans are reviewed and updated at least annually.

Are tabletop exercises performed?

Yes. Tabletop exercises are performed with the following requirements:

• Tabletop exercises are based on emerging risks and threats
• Tabletop exercises involve stakeholders listed in an incident response plan
• Tabletop exercises involve senior management
• Lessons learned/improvement actions are documented after tabletop exercises

Has Zayo partnered with any incident response security vendors?

Yes. Zayo has partnered with incident response security vendors for the following purposes:

• Notification & Monitoring
• Breach Prevention

Do you have a documented incident response process and a dedicated incident response team?

Yes.

What is Zayo’s process for reviewing and exercising the resiliency plan?

Zayo continuously tests its resiliency protocols and exercises the plans annually and during real-world events that are managed and escalated appropriately.

What is Zayo’s process to ensure customers and external entities (such as government agencies) are notified of an incident when a product or service is impacted?

Customers and external entities are notified by email when an impactful incident occurs. Zayo is also implementing a system of notification in the online Trust Center.

Does Zayo have processes or procedures to recover full functionality, including integrity verification, following a major cybersecurity incident?

Yes.

Do you insure for financial harm from a major cybersecurity incident (e.g., self-insure, third party, parent company, etc.)?

Yes.

Does coverage include financial harm to Zayo customers resulting from a cybersecurity breach which has impacted your company?

Yes, to the extent of Zayo’s liability. Zayo is not the controller of customer data.

Zayo implements logging and monitoring controls on its internal environment. Customers must implement their own security controls to protect their own environments.

Is security and system log data retained and monitored?

Zayo collects logs focused on security related activities and source owner audit purposes. Logs are retained for 365 days and are under continuous review. Alerts are automated as logs are tested against system rules, and actionable events are addressed by the Security Operations Center (SOC).

What does Zayo’s logging process include?

• Logs are synchronized to multiple sources
• Logs are fed to a central security information and event management system (SIEM)
• Logs are reviewed regularly for abnormal events
• SIEM captures source (firewall, IPS, VPN, etc.)
• SIEM captures category (user activity, proxy, etc.)
• SIEM captures information type (IP, name, etc.)
• SIEM outputs are reviewed at least every 24 hours by a member of the IT or Security team
• Security monitoring is conducted 24/7 by an internal or third-party SOC Service

Which administrator activities are logged and monitored?

• Log source (firewall, IPS, VPN, etc.)
• Log category (User Activity, proxy, etc.)
• Information type (IP, name, etc.)
• Use case (authentication, suspicious inbound activity, malicious web site)
• Administrator logging covers AD, network devices, VPN
• Modifications to administrator groups, including adds, modifies, removes, unsuccessful logins

How is usage and capacity of critical assets monitored?

Effective monitoring of asset usage and capacity ensures optimal system performance, minimizes downtime, and supports proactive resource management. This involves implementing key controls to track and manage system health and efficiency:

• Outbound Traffic Monitoring
• Storage Capacity Alerts
• Error and Fault Reporting
• Performance Benchmarking

What other types of monitoring programs does Zayo implement?

Zayo’s monitoring programs also include:

• Controls
• Risk
• Security and threat intelligence
• Compliance
• Threat and file integrity
• Changes in Organizational structure

Zayo implements network security controls on its internal environment. Customers must implement their own security controls to protect their own environments.

How are network devices configured?

• Network devices are deployed using standard approved configurations
• Changes to network devices or configurations are managed via a standard approval process with business justification
• Administrative access is limited on a need to know basis for network devices

Does Zayo have network perimeter defense tools including firewall, IPS, web filtering, malware detection?

Yes.

• Firewalls are deployed at all internet gateways and breakouts
• Intrusion detection and intrusion prevention capabilities are deployed at all internet gateways and internet breakouts
• Malware detection capabilities are deployed at all internet gateways and internet breakout
• Web filtering is deployed at all internet gateways and internet breakouts

How are network devices managed?

• Network Intrusion Prevention Systems deployed to detect and block network based attacks
• Strong egress firewall rules configured to limit everything but web traffic outside of the enterprise
• Web traffic proxied to allowed websites and unknown websites are blocked
• Communications limited to only trusted and known IP addresses
• Communication denied over unauthorized TCP/UDP ports
• System manages excess capacity, bandwidth, or other redundancy to limit the effects of information flooding types of denial-of-service attacks

Are network environments logically separated to ensure protection and isolation of critical systems and data?

Networks are physically or logically separated to ensure protection and isolation of all critical systems and data.

Does Zayo have the capability to detect anomalous or malicious activity within its networks? 

Yes. The Security Information and Event Management (SIEM) system detects anomalous and malicious activity in the Zayo environment by correlating logs and events across the Zayo network. This tool help provide real-time analysis to the Security Operations Center (SOC) to identify patterns that indicate potential security breaches such as unusual access patterns, failed login attempts or data exfiltration. Zayo collects logs focused on security related activities and source owner audit purposes. Logs are retained for 365 days and are under continuous review. Alerts are automated as logs are tested against system rules, and actionable events are addressed by the SOC.

Does Zayo have the capability to supply details of normal/baseline system and traffic behaviour to enable customers to update asset management and network monitoring systems relating to services supplied?

Zayo utilizes a suite of monitoring and analytical tools to monitor and assess baseline traffic for security purposes. Network traffic monitoring tools, such as intrusion detection and prevention systems, machine learning algorithms, SIEM logs and events, audits and threat hunting, and anomaly detection tools ensure the integrity and security of systems that host and support customer equipment. 

How are wireless networks protected?

• Any unauthorized wireless network devices/access points are detected and removed
• Default passwords and SSID are changed on all wireless devices
• Access is restricted on all wireless devices
• Minimum standard of WPA encryption is utilized
• Host-based intrusion detection firewall is installed on all devices
• Wireless access is disabled on devices that do not have a business purpose for wireless access
• A separate wireless network is created for personal and untrusted devices

Does the system manage excess capacity, bandwidth, or other redundancy to limit the effects of information flooding types of denial-of-service attacks?

It is the responsibility of all Zayo asset owners globally to ensure that resources are monitored and tuned. Projections must be made for future capacity requirements to ensure the required system performance.

Depending on the criticality of the system, capacity requirements must be identified, tuned, and monitored to ensure availability and efficiency of systems. Projections must take into account new business, system, trends, and requirements for Zayo’s information processing. Monitoring must include identifying trends and utilization to identify and avoid potential bottlenecks and dependence on specific individuals within the Organization. 

Managing capacity includes:

• Deletion of obsolete data (disk space) following proper Media Sanitation procedures outlined
• Decommissioning of applications, systems, databases or environments
• Optimizing batch processes and schedules
• Optimizing application logic or database queries
• Denying or restricting bandwidth for resource-hungry services if these are not business critical

Does Zayo utilize full disk encryption (i.e. laptop/desktop/mobile)?

Full disk encryption is deployed for all endpoints and updated to align technology with emerging risks.

Does Zayo utilize endpoint protection (EPP) which includes anti-virus?

Endpoint software is installed on all devices and is updated regularly with latest signatures. Multiple endpoint detection and response tools are in place providing detection, enterprise logging and compromise indicators of vulnerability. Notifications of incidents creates response tasks tracked and managed in ServiceNow and responded to by the Security Operations Center (SOC).

Does Zayo utilize endpoint software which detects threats or vulnerabilities for unknown files?

Endpoint software is installed on all mobile devices, configured not to auto-run content from removable media, and sends malware detection events to enterprise central team.

Can the malware protection solution provide forensics capabilities for incident response and/or remediation?

Endpoint software is configured to provide forensics capabilities on all devices and is updated regularly with latest signatures.

Does Zayo utilize an endpoint protection, detection and prevention solution (EDR, MDR, XDR, etc)?

Endpoint software is installed on all devices and is updated regularly with latest signatures.

Does Zayo employ a host-based intrusion Prevention/Detection System?

Host IDS is configured on all devices and regularly reviewed for updates.

Which security systems are in place to monitor email?

• Our email solution is cloud-based
• Our email solution stops malware in email (URL, attachments, etc.)
• Our email solution measures number of threats blocked per day
• Our email solution alerts employees when an email originates from outside the organization
• Our email solution automatically disables macros

What is the difference between a risk and an issue?

A risk is a potential event or condition that, if it occurs, could impact Zayo’s ability to achieve its business objectives. A risk represents uncertainty about what may or may not happen in the future. A risk rarely goes away, but the level of risk may change based mitigation strategies to lower the impact to the business and likelihood of it occurring.

An issue is is a current problem or situation that is affecting the Organization right now. It’s something that has already occurred or is currently happening and requires resolution.

Does collaboration exist between relevant related functions including Internal Audit, Information Technology, Security, Legal / Compliance, Risk Management, and Business Continuity to measure and manage cyber risks?

Yes, there is formal and consistent collaboration between functions. Zayo’s Risk Management program aligns with the Three Lines of Defense model, consisting of operational units (1st line), risk management and compliance functions (2nd line), and internal audit (3rd line). This multi-layered defense model enhances our ability to identify and address risks and promotes accountability, transparency, and resiliency across the Organization.

How is the senior cyber security leader engaged during reviews of strategic decisions including significant capital investment, new market entry, new product development, or M&A activity?

• Provides insight into risks before a decision is made
• Provides insight into risks after a decision has been made
• Assists in evaluating commercial impact to the business risk profile
• Provides recommendations for risk remediation strategies and action plans once a decision is made

How are risks identified?

The 1st line of defense, our operational managers and staff, is responsible for identifying risks and issues within their areas and ensuring that the processes and activities are controlled.

How are risks assessed?

The risk assessment process is coordinated by the 2nd line of defense, our Risk Management and Compliance teams. When a risk is identified by the 1st line of defense, the 2nd line ensures the risk is added to the Risk Register. The risk is then assigned to the appropriate 1st line operational unit, who then formally assesses the risk to determine a risk rating based on impact and likelihood.

How are risks treated?

Once a risk has been identified and assessed, one or more risk treatment options is then applied to the risk:

Treatment: Response from 1st line on how they will manage the risk
Accept	Accept risk within risk tolerance levels without the need for additional action. Where the risk acceptance relates to non-compliance with a policy or standard, a policy exception is completed to document the risk acceptance.
Avoid	Apply responses to ensure that the risk does not occur. Avoiding a risk may be the best option if there is not a cost-effective method for reducing the risk to an acceptable level. The cost of lost opportunity associated with such a decision is considered as well.
Mitigate	Apply actions (controls) that reduce the threats, vulnerabilities, and impacts of a given risk to an acceptable level. Responses may include those that help prevent a loss or limit such a loss by decreasing the amount of damage and liability.
Transfer	For risks that fall outside of the tolerance levels, the level of risk may be reduced to an acceptable level by sharing a portion of the consequences with another party. While some of the financial consequences may be transferable, there are often consequences that cannot be transferred.

Does Zayo have processes relating to remediation of security risks and vulnerabilities, and how does Zayo intend to use these processes to remediate any security-related issues discovered in relation to systems holding or processing customer data? 

Processing and/or storage of personal data transferred by customers is limited to contact information (e.g., names, addresses, contact details, IP addresses) of customer employees, representatives, contractors or agents who are involved or interact with Zayo in the provision of services by Zayo to the customer under the agreement.  Zayo is not the controller of customer data. The risk assessment process is coordinated by the Security Team, identification of threats and vulnerabilities is performed by asset owners, and assessment of consequences and likelihood is performed by risk owners. Risk treatment is implemented in response to each risk and is conducted by the teams relevant to the risk.  

What is the Unified Compliance Framework (UCF)?

The UCF is one of the largest frameworks for aggregating Authority Documents into a collective whole. It then aligns and harmonizes the requirements within set of de-duplicated common controls. For more information about the UCF, refer to  https://www.unifiedcompliance.com/home.

How is Zayo’s Security Governance Framework structured?

Using a Common Control Framework (CCF) based upon the UCF, Zayo is able to ensure compliance with regulatory requirements, industry best practices, and other authoritative sources as defined by various leading global organizations. The Organization’s CCF is structured around various control families or domains, with each family representing a group of related controls from multiple regulations or standards, aligning them based on their common objectives and functional areas. This ensures the Organization’s compliance with a multitude of global industry standards, regulations, and best practices.

Does Zayo share its governance documentation with customers?

No. Zayo does not share governance documents in their entirety as they are treated as internal resources that are proprietary in nature. This fosters accountability and confidentiality, guiding teams through crises while ensuring compliance with industry standards.

Is there a process used to verify that information is categorized according to legal, regulatory, or internal sensitivity requirements?

Yes. Information is categorized using data classification standards and document retention policies. 

Do you follow operational standards or frameworks for managing Information Security/Cybersecurity?

Zayo’s security program is based upon the Unified Compliance Framework (UCF) and structured around a set of control objective categories addressing controls from a multitude of authoritative industry standards and requirements. For more information about the UCF, refer to https://www.unifiedcompliance.com/home.

Do you have company-wide, publicly available security policies in place covering privacy?

Yes. You can find publicly available policies under the Governance category of the Trust Center. For privacy information, please refer to Zayo’s Privacy Policy.

What mechanisms are in place to ensure Zayo policy and standards are enforced within your supply chain?

Zayo is a global corporation and rigorously assesses all Suppliers by strictly enforcing Inherent Risk Questionnaires (IRQs), Office of Foreign Assets Control (OFAC) and Committee on Foreign Investment in the United States (CFIUS) reviews, and Data Processing Addendums (DPAs). Agreements with Suppliers must include requirements to address the information security risks associated with information and communications technology services and the Organization’s product supply chain, which includes cloud computing services. It is the responsibility of Users to work with Suppliers to understand the information and communication technology supply chain so that the Organization knows the components that could have an important impact on the products and services being provided.  Supplier agreements state that Suppliers must adhere to the security requirements specified in the Supplier Relationships Policy they are required to sign, security requirements and practices specified are propagated throughout the supply chain, and relevant Organization teams associated with the Supplier and Supplier contract must ensure that monitoring is in place for validating that delivered information and communication technology products and services are adhering to the stated security requirements. Associated Organization teams must obtain assurance that the delivered information and communication technology products are functioning as expected without any unexpected or unwanted features. All third parties are assessed and re-assessed as service agreements change. If violations of contractual Third Party Risk Management (TPRM) requirements or TPRM-related incidents occur, remediation activities are managed as issues. Information that Users share with a Supplier must only be shared based on a need-to-know and need-to-use basis throughout the supply chain, and this method of information sharing must be used by the Supplier in the case that the Supplier uses any other Suppliers for the services provided to the Organization. 

Do the Board and Executive Management establish a clear ‘tone from the top’ on the importance of cybersecurity?

There is a distinct ‘tone from the top’ from the Board and Executive Management that is consistent, visible, and achieved on a sustained basis.

Does a relevant Board Committee (with risk management oversight or audit responsibilities) receive cybersecurity reports?

Yes. Reports include:

• Key threats and associated cyber security activities
• Cyber incidents and underlying causes
• Ownership responsibilities and accountabilities
• Roadmaps, action plans, and progress
• Key Risk Indicators, tolerances and financial thresholds / limits
• Cyber security performance metrics and trends
• Information on emerging threats

How often does the Board receive reporting on Zayo’s cyber risk profile?

Board reporting occurs quarterly or more frequently as needed.

Is there an executive-level sponsor (e.g., CTO, CIO, CISO, GC) to promote cybersecurity or dedicated roles with accountability for cyber security?

Yes. Zayo’s CIO, CFO, and CSO act as executive-level sponsors to promote Zayo’s security programs and posture.

Does Zayo have network access control policies and procedures in place for your information systems that are aligned with industry standards or control frameworks?

Yes. Zayo’s security program is based upon the Unified Compliance Framework (UCF) and structured around a set of control objective categories addressing controls from a multitude of authoritative industry standards and requirements. For more information about the UCF, refer to https://www.unifiedcompliance.com/home.

What are Zayo practices for items such as federation, privileged users, and role-based access control for end-user devices?

Access controls include role-based access controls (RBAC), Single Sign On (SSO), and Identity Access Management.

How does Zayo ensure remote access is managed for end-user devices or employees and suppliers, including deactivation of accounts? (e.g. Multi-factor authorization, encryption, protection from malware, etc.)

Remote access is managed using MFA, local disk encryption, VPN and ZIA internet protection, and malware protection.

Is cybersecurity training required for personnel who have administrative rights to your enterprise computing resources?

Yes.

What is the frequency for verifying personnel training compliance?

Training compliance takes place upon hire and on an annual basis.

What cybersecurity training is required for your third-party stakeholders (e.g., suppliers, customers, partners, etc.) who have network access?

Vendor workers and contractors are required to complete Organizational security training, which is administered, monitored, and tracked. Suppliers are responsible for their own security training programs.

Does Zayo include contractual obligations to protect information and information systems handled by your suppliers?

Yes.

What standard cybersecurity standards or frameworks are the contractual supplier terms for information protection aligned to, if any?

Agreements with Suppliers must include, based on the need, the requirements to address the information security risks associated with information and communications technology services. Based on the security requirements agreed upon when signing the Supplier contract, the Organization reserves the right to conduct formal and regular reviews of the adherence to the specified requirements, which can include Supplier review and product validation.

Do you have an organizational policy on the use of encryption that conforms with industry standards or control frameworks?

Yes.

Are incident detection and reporting practices defined and documented which outline the actions that should be taken in the case of an information security or cybersecurity event?

Yes. The Security Information and Event Management (SIEM) system detects anomalous and malicious activity in the Zayo environment by correlating logs and events across the Zayo network. This tool help provide real-time analysis to the Security Operations Center (SOC) to identify patterns that indicate potential security breaches such as unusual access patterns, failed login attempts or data exfiltration. Zayo collects logs focused on security related activities and source owner audit purposes. Logs are retained for 365 days and are under continuous review. Alerts are automated as logs are tested against system rules, and actionable events are addressed by the SOC.

What industry standards or controls frameworks are followed for encryption and key management?

Zayo’s security program is based upon the Unified Compliance Framework (UCF) and structured around a set of control objective categories addressing controls from a multitude of authoritative industry standards and requirements. For more information about the UCF, refer to https://www.unifiedcompliance.com/home.

Does Zayo have hardening standards in place for network devices (e.g., wireless access points, firewalls, etc.)?

Yes.

What protections exist to provide network segregation where appropriate (e.g., intrusion detection systems)?

Customer and Corporate Production, Telemetry (monitoring), and Business systems are segmented and isolated from one another.

What controls exist to continuously monitor changes to your network architecture?

Zayo’s security program is based upon the Unified Compliance Framework (UCF) and structured around a set of control objective categories addressing controls from a multitude of authoritative industry standards and requirements. For more information about the UCF, refer to https://www.unifiedcompliance.com/home.

How does Zayo manage prioritization and mitigation of threats discovered on your networks?

Security Operations is active 24/7. Multiple endpoint detection and response tools are in place providing detection, enterprise logging and compromise indicators of vulnerability. Notifications of incidents creates response tasks that are tracked and managed.

How does Zayo track changes to software versions on your servers?

Changes are tracked using reports from our scanning agents.

How does Zayo convey cloud security requirements to your suppliers/sub-contractors?

Requirements are agreed upon through contractual language and Data Processing Addendums.

Does Zayo run automated scans to detect vulnerabilities?

Multiple endpoint detection and response tools are in place providing detection, enterprise logging and compromise indicators of vulnerability. Notifications of incidents creates response tasks tracked and managed and responded to by the Security Operations Center (SOC).

How does Zayo obtain information about vulnerabilities?

Threat hunting, machine learning, and threat intelligence is used.

Does Zayo you configure and refresh systems/endpoints using a standard image build?

A defined standard build exists and is enforced as appropriate.

How does Zayo manage critical patches?

Per policy, based on severity ratings, the patch policy priority schedule is as follows:

• Critical: Review within seven (7) business days with deployment based on review
• High: Review within 30 days with deployment based on review
• Medium: Review within 90 days with deployment based on review
• Low: 180 days

Are there policies and procedures in place to ensure that the environment providing service to customers is not capable of being accessed from or reliant upon equipment present within a Restricted Country?

Zayo allows access from those locations/countries where our employees, contractors, and vendors are located. Zayo’s Threat Intelligence infrastructure will always block specific sources of high risk or active threats, regardless of location. Zayo determines high risk countries based on the following criteria:

• https://ofac.treasury.gov/
• https://www.bis.doc.gov/index.php/policy-guidance/country-guidance/sanctioned-destinations
• https://www.eeas.europa.eu/eeas/european-union-sanctions_en#10710

The following high risk countries are not permitted for inbound traffic:

• China
• Cuba
• Iran
• Iraq
• North Korea
• Russia/Ukraine

Does Zayo engage a third party for external penetration testing on your physical properties?

No external penetration testing is conducted on physical properties.

Does Zayo perform inspections for physical tampering or alteration of hardware components within the system?

Yes, inspections are performed for physical tampering on some systems.

Does Zayo have protective monitoring (e.g. SOC services) enabled for all remote assets?

Proactive monitoring is in place for all endpoints using advanced tooling; protective monitoring and response enabled to manage incidents such as network access control (NAC), privileged access management (PAM), managed detection and response (MDR), and data loss prevention (DLP).

Does Zayo engage a third party for external penetration testing on your network?

Yes, although much of our penetration testing is done internally. The following tests are performed internally on a regular cadence to identify potential vulnerabilities and assess the Organization’s security posture:

• Network penetration testing
• Web application penetration testing
• Mobile application penetration testing

A third party is engaged for external penetration testing on our network on an ad hoc basis.

Does Zayo have documented policies or procedures for identification and detection of cyber threats?

Yes.

What processes does Zayo have in place to promptly detect cyber threats?

Multiple endpoint detection and response tools are in place providing detection, enterprise logging, and compromise indicators of vulnerability.

Does Zayo have defined and documented incident detection practices that outline which actions should be taken in the case of an information security or cybersecurity event? 

Yes.

Are cybersecurity events centrally logged, tracked, and continuously monitored?

Yes. The Security Information and Event Management (SIEM) system detects anomalous and malicious activity in the Zayo environment by correlating logs and events across the Zayo network. This tool help provide real-time analysis to the Security Operations Center (SOC) to identify patterns that indicate potential security breaches such as unusual access patterns, failed login attempts or data exfiltration. Zayo collects logs focused on security related activities and source owner audit purposes. Logs are retained for 365 days and are under continuous review. Alerts are automated as logs are tested against system rules, and actionable events are addressed by the SOC.

Are incident detection practices continuously improved?

Yes.

Does Zayo require vulnerability scanning of software running within the enterprise prior to acceptance?

Yes.

What procedures or policies exist, if any, for detecting vulnerabilities in externally obtained software (such as penetration testing of enterprise and non-enterprise software)?

Architecture reviews/acceptance criteria, vulnerability scans, and penetration testing.

Does Zayo manage updates, version tracking of new releases, and patches (including patching history) for your software and software services offerings?

Yes.

Does Zayo deploy anti-malware software?

Yes.

How does Zayo manage the identification of threats within your supply chain, including suppliers and sub-contractors?

Suppliers must immediately report any security or other event that creates reasonable suspicion that there may be a violation of the above requirements and take appropriate steps to immediately address any security incident and cooperate with the Organization in respect to the investigation of such incident.

What processes are in place to act upon external credible cyber security threat information received?

Security Operations is active 24/7. Multiple endpoint detection and response tools are in place providing detection, enterprise logging and compromise indicators of vulnerability. Notifications of incidents automatically create response tasks that are tracked and managed.

Does Zayo address the interaction of cybersecurity operational elements (e.g., SOC, CSIRT, etc.) with the physical security operational elements protecting the organization’s physical assets?

Yes.

How does Zayo ensure that physical security incidents and suspicious events are escalated to cybersecurity operations staff?

Incident response for both physical security and cyber security are managed by Security Operations.

Are cybersecurity vulnerabilities for industrial control systems, including physical access controls and video monitoring systems, tracked?

Yes.

What standards or frameworks are followed for management of IT and OT system interactions?

Zayo’s security program is based upon the Unified Compliance Framework (UCF) and structured around a set of control objective categories addressing controls from a multitude of authoritative industry standards and requirements. For more information about the UCF, refer to https://www.unifiedcompliance.com/home.

Does Zayo have a policy or procedure for the handling of information that is consistent with its classification?

Yes.

What is Zayo’s process to verify that information is classified according to legal, regulatory, or internal sensitivity requirements?

We have adopted a zero-trust control and principles of least privilege.

How does Zayo convey requirements for data retention, destruction, and encryption to your suppliers?

Through contractual language and Data Processing Addendums.

Does Zayo have documented policies or procedures for internal identification and management of vulnerabilities within your networks and enterprise systems?

Yes.

What industry standards or frameworks are followed for vulnerability management?

Zayo’s security program is based upon the Unified Compliance Framework (UCF) and structured around a set of control objective categories addressing controls from a multitude of authoritative industry standards and requirements. For more information about the UCF, refer to https://www.unifiedcompliance.com/home.

How does Zayo identify vulnerabilities in your supply chain (suppliers/subcontractors) before they pose a risk to your organization?

The Supplier must immediately report any security or other event that creates reasonable suspicion that there may be a violation of the above requirements and take appropriate steps to immediately address any security incident and cooperate with the Organization in respect to the investigation of such incident.

How does Zayo assess and prioritize the mitigation of vulnerabilities discovered on your internal networks and systems?

Upon discovery, Security Operations creates an incident ticket for remediation.