Implementation Checklist (Drizly (FTC 2022))¶

A practical rollout plan with measurable proof for cloud control hardening and FTC-order execution tracking.

0–30 days (stabilize + baseline)¶

Inventory cloud services handling customer data and current boundary controls
Move high-risk cloud/IAM settings into controlled configuration workflow
Centralize cloud audit and auth logs with retention baselines

Deliverables - Cloud control baseline register and owners - High-risk cloud change SOP with approval gates - Cloud telemetry coverage and retention report

30–60 days (control effectiveness)¶

Implement drift detection for cloud boundary and identity controls
Perform least-privilege review for cloud admin and service roles
Deploy detections for unusual cloud data-access patterns

Deliverables - Drift alerting dashboard with monthly metrics - IAM review pack and remediation backlog - Detection engineering test records

60–90 days (evidence readiness)¶

Execute 48-hour evidence-pack dry run for FTC-order support
Add independent testing checkpoints for prioritized cloud controls
Publish quarterly management reporting on order milestones and risk posture

Deliverables - Evidence-pack structure with accountable owners - Readiness drill findings and closure plan - Quarterly order-progress governance template

Ongoing metrics (prove it's real)¶

% high-risk cloud changes approved pre-deploy
Cloud control drift MTTR
Admin privilege reduction trend
Coverage % for cloud audit/auth/data logs
Time to close high-severity control findings