Implementation Checklist (Equifax (post-2017 oversight))

A practical rollout plan with measurable proof for consumer-data protection uplift under ongoing settlement and oversight commitments.

0–30 days (stabilize + baseline)

• Refresh inventory of internet-facing and high-risk consumer-data systems
• Baseline vulnerability and boundary control standards with owners
• Centralize security telemetry for critical consumer-data workflows

Deliverables - System inventory and ownership register - High-risk change approval SOP and workflow - Telemetry baseline report and retention target matrix

30–60 days (control effectiveness)

• Implement control drift detection for core boundary and config controls
• Execute least-privilege review for sensitive data access roles
• Deploy anomaly detections for unusual data access behavior

Deliverables - Drift detection alerting and monthly trend metrics - IAM review pack with remediation evidence - Detection rule coverage and test outcomes

60–90 days (evidence readiness)

• Complete 48-hour evidence-pack rehearsal for oversight inquiries
• Run independent control validation checkpoints and track closures
• Issue quarterly remediation and risk posture report to leadership

Deliverables - Evidence-pack folder map with accountable owners - Independent assessment findings tracker - Quarterly oversight reporting template

Ongoing metrics (prove it's real)

• % high-risk changes reviewed pre-production
• Config/control drift MTTR
• Privileged access recertification completion %
• Coverage % for critical security log sources
• High-severity finding closure time