Findings drafted by the Twin
Findings Register (Module M7)
Every finding drafted by the Twin requires human review and confirmation before it can enter the official report (BR-2).
Of 212 employees who left between 1 Nov 2025 and 31 Oct 2026, 9 had active directory accounts more than 24 hours after their leaving date. The longest delay was 41 days.
Access Control Policy section 4.3: access must be removed within 24 hours of the leaving date.
Not confirmed. Exit interviews suggest contractors and outsourced staff are not part of the HR feed that drives automatic disablement.
Former staff held live credentials for the corporate directory and email, with potential reach into core banking support systems.
42 critical vulnerabilities raised in the period remained open beyond the 14-day remediation deadline, with a median delay of 63 days. 11 of them sit on internet-facing payment gateways. No risk acceptance is recorded for any of the 42.
Vulnerability Management Standard v3.1, section 5: critical vulnerabilities must be remediated within 14 calendar days, or formally accepted by the CISO.
Not confirmed. Ticket comments suggest a change-freeze between March and May backlogged remediation with no exception handling.
Exploitation of a known critical issue on an internet-facing payment service could lead to data breach or service outage.
6 of 47 critical systems listed in the CMDB do not appear in the log source inventory. No Q3 log review record exists for the SIEM, although the procedure requires monthly review with sign-off.
Logging and Monitoring Procedure v2.0 sections 3.2 and 4.1.
Unknown.
Blind spots reduce detection of and response to security incidents on critical systems.
Leaver removal relies on a nightly HR feed. Contractor exits are notified by email to the service desk and are not reconciled monthly.
Beyond requirement — good practice reference ISO/IEC 27002:2022 5.18 and the banking pack reconciliation pattern.
Process design, not a lapse.
Repeat of the A.5.18 condition if contractor volumes grow.
A quarterly phishing simulation programme runs with role-specific follow-up training triggered automatically for repeat clickers. Click rate fell from 11.4% to 3.1% over three quarters.
Recognised good practice under ISO/IEC 27002:2022 7.3.
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