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DATA SECURITY

This document provides three major areas of our Data Security Policies that cover key areas of concern. This should not be considered as an exhaustive list but rather each organization should identify any additional areas that require policy in accordance with their users, data, regulatory environment and other relevant factors.

The three policies cover:

1. Data Security Policy: Employee Requirements

2. Data Security Policy: Data Leakage Prevention – Data in Motion

3. Data Security Policy: Workstation Full Disk Encryption

Data Security Policy: Employee Requirements

Definition

This policy outlines behaviours expected of employees when dealing with data and provides a classification of the types of data with which they should be concerned. This should link to your AUP (acceptable use policy), security training and information security policy to provide users with guidance on the required behaviours.

1.0 Purpose

Data Spectors must protect restricted, confidential or sensitive data from loss to avoid reputation damage and to avoid adversely impacting our customers. The protection of data in scope is a critical business requirement, yet flexibility to access data and work effectively is also critical. 

 

It is not anticipated that this technology control can effectively deal with the malicious theft scenario, or that it will reliably detect all data. It’s primary objective is user awareness and to avoid accidental loss scenarios. This policy outlines the requirements for data leakage prevention, a focus for the policy and a rationale.

2.0 Scope

1. Any employee, contractor or individual with access to Data Spectors systems or data. 

2. Definition of data to be protected:

a. PII

b. Financial

c. Restricted/Sensitive

d. Confidential

e. IP

3.0 Employee Requirements

1. You need to complete Data Spectors security awareness training and agree to uphold the acceptable use policy.

2. If you identify an unknown, un-escorted or otherwise unauthorized individual in Data Spectors you need to immediately notify.

3. Visitors to Data Spectors must be escorted by an authorized employee at all times. If you are responsible for escorting visitors you must restrict them appropriate areas. 

4. You are required not to reference the subject or content of sensitive or confidential data publicly, or via systems or communication channels not controlled by Data Spectors. For example, the use of external e-mail systems not hosted by Data Spectors to distribute data is not allowed. 

5. Please keep a clean desk. To maintain information security you need to ensure that all printed in scope data is not left unattended at your workstation.

6. You need to use a secure password on all Data Spectors systems as per the password policy. These credentials must be unique and must not be used on other external systems or services.

7. Terminated employees will be required to return all records, in any format, containing personal information.

8. You must immediately notify in the event that a device containing in scope data is lost

(e.g. mobiles, laptops etc).

9. In the event that you find a system or process which you suspect is not compliant with this policy or the objective of information security you have a duty to inform so that they can take appropriate action.

10. If you have been assigned the ability to work remotely you must take extra precaution to ensure that data is appropriately handled. Seek guidance from if you are unsure as to your responsibilities.

11. Please ensure that assets holding data in scope are not left unduly exposed.

 

12. Data that must be moved within Data Spectors is to be transferred only via business provided secure transfer mechanisms (e.g. encrypted USB keys, file shares, email etc). Data Spectors will provide you with systems or devices that fit this purpose. You must not use other mechanisms to handle in scope data. If you have a query regarding use of a transfer mechanism, or it does not meet your business purpose you must raise this with respective department keeping the management in attention.

13. Any information being transferred on a portable device (e.g. USB stick, laptop) must be encrypted in line with industry best practices and applicable law and regulations. If there is doubt regarding the requirements, seek guidance from the IT Department.

Data Security Policy: Data Leakage Prevention – Data in Motion

Definition

This policy is intended to act as a guideline for organizations looking to implement or update their DLP controls. This policy provides a framework for classes of data that may wish to be monitored. You should expand them to cover the sensitive assets in your business and subject to the types of you hold.

Policy Background

You agree to comply with all applicable laws regarding your use of the Website. You further agree that information provided by you is truthful and accurate to the best of your knowledge. Data leakage prevention is designed to make users aware of data they are transferring which may be sensitive or restricted in nature.

1.0 Purpose

Data Spectors must protect restricted, confidential or sensitive data from loss to avoid reputation damage and to avoid adversely impacting our clients and customers. The protection of in scope data is a critical business requirement, yet flexibility to access data and work effectively is also critical.

 

It is not anticipated that this technology control can effectively deal with the malicious theft scenario, or that it will reliably detect all data. It’s primary objective is user awareness and to avoid accidental loss scenarios. This policy outlines the requirements for data leakage prevention, a focus for the policy and a rationale. 

2.0 Scope

1. Any Data Spectors device which handles customer data, sensitive data, personally identifiable information or company data. Any device which is regularly used for e-mail, web or other work related tasks and is not specifically exempt for legitimate business or technology reasons.

2. The Data Spectors Information Security Policy will define requirements for handling of information and user behaviour requirements. This policy is to augment the information security policy with technology controls.

3. Exemptions: Where there is a business need to be exempted from this policy (too costly, too complex, adversely impacting other business requirements) a risk assessment must be conducted being authorized by security management.

3.0 Policy

1. Data Spectors Data Leakage Prevention (DLP) Technology will scan for data in motion.

2. The DLP technology will identify large volumes of in scope data.

a. E-mail addresses, names, addresses and other combinations of personally identifiable information. 

b. Documents that have been explicitly marked with the Data Spectors‘ Confidential’ string.

3. DLP will be configured to alert the user in the event of a suspected transmission of sensitive data, and the user will be presented with a choice to authorize or reject the transfer. This allows the user to make a sensible decision to protect the data, without interrupting business functions. Changes to the DLP product configuration will be handled through the Data Spectors IT change process and with security management approval, to identify requirements to adjust the information security policy or employee communications.

4. DLP will log incidents centrally for review. The IT team will conduct first level triage on events, identifying data that may be sensitive and situations where its transfer was authorized and there is a concern of inappropriate use. These events will be escalated to HR to be handled through the normal process and to protect the individual.

5. Where there is an active concern of data breach, the IT incident management process is to be used with specific notification provided to HR, Legal and Security Management.

 

6. Access to DLP events will be restricted to a named group of individuals to protect the privacy of employees. A DLP event does not constitute evidence that an employee has intentionally, or accidentally lost data but provides sufficient basis for investigation to ensure data has been appropriately protected.

4.0 Technical guidelines

Technical guidelines identify requirements for technical implementation and are typically technology specific.

The product or services will be configured to identify data in motion to Browsers, IM Clients, E-mail clients, Mass storage devices and writable CD media. 

5.0 Reporting requirements 

1. Weekly reports of incidents to HR, Legal and Security Management.

2. High priority incidents discovered by IT should be immediately flagged.

3. Monthly report showing % devices compliant with DLP policy.

Data Security Policy: Workstation Full Disk Encryption

Definition

This policy is intended to act as a guideline for organizations looking to implement or update their full disk encryption control policy. We adapt this policy, particularly in line with requirements for usability or in accordance with the regulations or data that needs to be protected. 

1.0 Purpose

Data Spectors must protect restricted, confidential or sensitive data from loss to avoid reputation damage and to avoid adversely impacting our Clients and Customers. A collection of global regulations also require the protection of a broad scope of data, which this policy supports by restricting access to data hosted on devices. 

 

As defined by numerous compliance standards and industry best practice, full disk encryption is required to protect against exposure in the event of loss of an asset. This policy defines requirements for full disk encryption protection as a control and associated processes. 

2.0 Scope

1. All Data Spectors workstations – Desktops and Laptops.

2. All Data Spectors Virtual Machines.

 

3. Exemptions: Where there is a business need to be exempted from this policy (too costly, too complex, adversely impacting other business requirements) a risk assessment must be conducted being authorized by security management.

3.0 Policy

1. All devices in scope will have full disk encryption enabled.

2. Data Spectors Acceptable Use Policy (AUP) and security awareness training must require users to notify HR/ Legal/ Security Management if they suspect they are not in compliance with this policy as per the AUP. 

3. The AUP and security awareness training must require users to notify HR/ Legal/ Security Management of any device which is lost or stolen.

4. Encryption policy must be managed and compliance validated by Security Management. Machines need to report to the central management infrastructure to enable audit records to demonstrate compliance as required.

5. Where management is not possible and a standalone encryption is configured, the device user must provide a copy of the active encryption key to IT.

6. HR/ Legal/ Security Management has the right to access any encrypted device for the purposes of investigation, maintenance or the absence of an employee with primary file system access.

7. The encryption technology must be configured in accordance with industry best practice to be hardened against attacks.

8. All security related events will be logged and audited by Security Management to identify inappropriate access to systems or other malicious use.

9. The Security Management help desk will be permitted to issue an out-of-band challenge/response to allow access to a system in the event of failure, lost credentials or other business blocking requirements. This challenge/response will be provided only in the event that the identity of the user can be established using challenge and response attributes documented in the password policy.

10. A group of sensitive data will be identified by the restricted data policy. Users in this group will require a member of HR/ Legal/ Senior/ Security Management authorization for key changes or challenge response. The help desk will not be permitted to access said systems without authorization. These systems are identified as having access to highly sensitive, restricted use data and have a requirement for separation of duty. Where identified by the authentication and restricted data policy, a system/user will be required to use two factor authentications in accordance with defined IT standards. The authentication will occur in the pre boot environment.

11. Configuration changes are to be conducted through the Security Managements change control process, identifying risks and noteworthy implementation changes to security management.

4.0 Technical Guidelines

1. Strong, industry best practice defined cryptographic standards must be employed. AES-256 is an approved implementation.

2. The BIOS will be configured with a secure password (as defined by password policy) that is stored by IT. The boot order will be fixed to the encrypted HDD. If an override is required by a user for maintenance or emergency use, the helpdesk can authenticate the user and then provide the password for the BIOS. The objective being to avoid an attacker cold booting and attacking the system.

3. Synchronization with Windows credentials will be configured so that the pre boot environment is matched to the user’s credentials and only one logon is required.

4. A pre boot environment will be used for authentication. Credentials will be used to authenticate the user in compliance with password security policy.

5.0 Reporting Requirements

1. A monthly report that identifies the % of encrypted systems versus assets in scope.

2. A monthly report that identifies the compliance status of managed, encrypted systems.

3. A monthly report that identifies the number of lost assets and validation that lost devices have been handled appropriately.

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