Security & Compliance Checklist for Incentive Programs

By following this Security & Compliance Checklist for Incentive Programs, your organization will proactively minimize data risks and meet critical regulatory standards, building trust with participants and stakeholders.

Identify Applicable Regulations

• GDPR (EU), CCPA (California), HIPAA (if dealing with health data), PCI DSS (if handling credit card transactions), other local regulations.
• Have you mapped out all applicable regulations for your incentive program?

Scope of Data & Processes

• Determine which data types you collect (name, email, financial details) and how they are stored or transferred.
• List all data points you collect from participants (e.g., PII, transaction history).

Document Risk Factors

• Identify high-risk processes (e.g., storing payment info, awarding prepaid cards).
• Describe the top 3 risks associated with your current incentive setup.

Data Collection & Consent

• Use clear opt-in forms, privacy notices, and disclaimers for participants.
• Is a consent management process in place for collecting personal data?

Storage & Encryption

• Store sensitive data in encrypted databases; use secure servers or cloud environments (SOC 2, ISO 27001 certified).
• Are all sensitive data fields encrypted at rest?

Retention & Deletion Policies

• Define how long you retain participant data and have a process for deletion upon request.
• Describe your data retention timeline and deletion policy.

Privacy Policy Updates

• Ensure your public-facing privacy policy covers your incentive program data use and adheres to the latest regulations.
• Have you updated your privacy policy in the last 12 months?

Role-Based Access

• Grant only necessary privileges to employees and vendors (principle of least privilege).
• Do you use role-based access control (RBAC) for the incentive platform?

Multi-Factor Authentication (MFA)

• Require MFA for administrators, program managers, and any user with access to sensitive data.
• Is MFA enabled for all admin-level accounts?

Password Policies

• Enforce strong passwords, periodic resets, and account lockouts after multiple failed logins.
• Are password complexity requirements enforced?

Audit Trails & Logging

• Maintain logs of all administrative actions, data exports, and system changes.
• Describe your process for reviewing and storing audit logs.

Vendor Assessment

• Verify that third-party reward providers (e.g., gift card platforms, payment processors) meet security and compliance standards.
• Have you reviewed security documentation from all vendors?

Service-Level Agreements (SLAs)

• Include data protection clauses in contracts with vendors; define breach notification protocols.
• List key SLAs or contractual obligations you require from vendors (e.g., data breach reporting within X hours).

Ongoing Vendor Monitoring

• Schedule periodic reviews or audits of third-party systems and processes.
• Do you conduct vendor security audits at least annually?

Compliance Documentation

• Maintain updated records: data flow diagrams, GDPR/CCPA compliance checklists, PCI-DSS self-assessments, etc.
• Do you maintain documented proof of compliance (e.g., DPIAs, self-assessments)?

Incident Response Plan (IRP)

• Outline steps for containing and reporting data breaches or security incidents; identify responsible stakeholders.
• Provide a brief summary of your incident response plan (who, what, when, how).

Breach Notification Process

• Comply with required timelines and communication protocols (e.g., 72-hour reporting for GDPR).
• Does your IRP outline breach notification processes per regulatory requirements?

Deployment Best Practices

• Test your incentive platform in a staging environment; conduct pen testing before launch.
• Have you conducted vulnerability scans or penetration tests prior to going live?

Employee & Participant Training

• Provide ongoing training for staff on data handling, phishing awareness, and compliance updates.
• Describe how you train employees (e.g., annual security training, monthly bulletins).

Key Security Controls

• Firewalls, intrusion detection, anomaly detection, and regular patching cycles.
• Are critical security controls (e.g., IDS/IPS, patch management) in place?

Regular Audits

• Schedule audits (internal or external) to confirm continued adherence to security policies and regulatory guidelines.
• Have you defined a routine schedule for internal audits (quarterly, bi-annually)?

Completion Status

• Mark each section’s status: Completed, In Progress, Not Started

Action Items & Timelines

• List priority tasks (e.g., encrypting certain data fields, implementing MFA) and their deadlines.
• Outline your next steps for addressing any uncovered gaps or risks.

Validation & Sign-off

• Secure approvals from  compliance teams, CIO, or legal counsel.