Information Security Policy

1. Requirements of the policy

The objective of this requirement is to ensure that users of IT/IS facilities do not unintentionally place themselves, or the Executive Zone (Company), at risk of prosecution or disciplinary action, by carrying out computer related activities which contravene current policy or legislative restrictions.

Information within the Company is intended to be openly accessible and available to all members of the organization for sharing and processing. Certain information (sensitive information) has to be processed, handled and managed securely and with accountability. This policy outlines the control requirements for all information contained within the Company network and IT systems.

2. Policy Structure

This document forms the Company’s Electronic Information Security Policy. Its purpose is to provide an overarching framework (a commitment of undertaking) to apply information security controls throughout the Company. Supporting policies and guidance documents containing detailed Information security requirements will be developed in support of this policy. Dependent upon the subject matter, supporting policies and guidance will either apply across the Company or to more specific groups or individuals within the Company.

3. Purpose and Scope

All processing of data and collection of information will be processed in accordance with Indian law. This policy defines how the Company will secure electronic information, which is found within:

  • The Company’s IS/IT infrastructure
  • Key Business System data and information
  • Security of information held in electronic form on any Company computer.

And is processed or used by:

  • Company Staff and suppliers who have access to or administer the Company network or IT systems.
  • External users, agents, and guest users authorised to use the Company network or IT Systems.
  • Individuals who process key data and information within Key Business Systems.
4. Objectives

These Information Security objectives are designed to protect the company business information and any client information within its custody or safekeeping by safeguarding its confidentiality, integrity and availability. In doing this the company will:

  1. Establish safeguards to protect all company and client information resources from theft, loss, abuse, misuse and any form of damage
  2. Establish responsibility and accountability for Information Security within the organisation.
  3. Ensure that management and staff have an appropriate level of awareness, knowledge and skill to allow them to minimize the occurrence and severity of Information Security incidents.
  4. Ensure that the organization is able to continue its commercial activities in the event of significant Information Security incidents.

The Company is committed to protecting its employees and Key Business Systems. Controls will therefore be deployed that mitigate the risk of vulnerabilities being exploited which adversely affect the efficient operation of the Company.

5. Applicability

This policy applies to all users of the Company network and IT Services and includes:

  • All full-time, part-time and temporary staff employed by, or working for or on behalf of, the Company;
  • Suppliers working at the Company;
  • Third party contractors and consultants working for or on behalf of the Company;
  • All other individuals and groups who have been granted access to the Company’s network or IT Services.

These categories of persons and agencies are collectively known as the ‘user’ in the policy document.

Each user is responsible for their own actions and must ensure all actions relating to using the Company network and IT Services adheres to the principles and requirements of this policy.

6. Legislation and Policy
a) Legislation

Supply and use of the Company network and IT Services is bound by Indian law.

b) Associated Policies

The company handbook further defines individual responsibilities for data protection and information governance.

c) Information Security – Risk Management

Information security governance is the structure which supports the implementation of this policy. An IT infrastructure will be implemented within the Company to ensure the effective and efficient implementation of this policy across the Company.

d) Ownership and Maintenance of Policy

This policy is owned by the Company and is maintained, reviewed and amended by the Company in accordance with Company policy, procedures and guidance.

This policy will be subject to review each year and considers there to be a new or changed threat to respond to.

e) Risk Management and Electronic Service Incidents

The Company will be responsible for raising an incident message in relation to any reported security incident at the Company. These incidents will be recorded as ‘Electronic Security Incidents’. Electronic Security Incidents will be recorded with a unique reference number. A review of incidents will be conducted at six monthly intervals. Incidents considered to be exhibiting unacceptable levels of risk to the Company network or IT Services will be subject to an investigation to identify the inherent vulnerabilities exposed by this incident.

f) Security of Third-Party Access

Procedures are in place to regulate access to the Company’s information processing facilities by third parties. Such access will be controlled and regulated in order to protect information assets and prevent loss or damage to data through unauthorised access. The Company will consider applications for access to facilities by contractors or third parties based upon a risk assessment of the proposed task.

g) Identification of Risk from Third Party Access

Third parties who require access to the Company’s IT/IS infrastructure will be bound by contracts which define Company security requirements. Prior to being granted any connectivity to the Company’s core internal or hosted systems, they will be required to sign and undertake to adhere to the requirements of the Company policy and where sensitive information or sensitive business / research information is involved they will be required to sign a non-disclosure agreement prior to access.

7. Asset Clarification

Information assets are categorized and recorded to enable appropriate management and control.

Inventory of Assets

The Company maintains an inventory, subject to audit, of IR related assets. For each item, the inventory will state the item’s description, make, model, serial number and/or service tag and location. This inventory is in addition to asset records maintained under Company financial regulations. Specific systems and databases are also recorded in this inventory, along with a role responsible for the system/database.

Any system and the data it contains that is not part of the above inventory is the responsibility of the creator of that system. However, the asset will require compliance with this policy and users will be required to adhere to the principles of this document.

All asset identification procedures must be compliant with and support the Company Business Continuity Plan.

8. Personnel Security Issues – Roles and Access Levels

The Company maintains a directory on Office 365, of people and suppliers which are authorised to use the Company network, IT services and applications. All users, staff, suppliers, external users and guest users are subject to the principles of this policy and must confirm that they agree to the terms.

If a user’s relationship with the Company alters, due to a change in role or employment relationship, then the revised level of access must match both the new role and relationship with the Company. All IT account access levels must comply with the requirements of the Company policy.

a) Security in Job Descriptions

Security roles and responsibilities will be included in job descriptions and associated Company books where appropriate. These will include any specific responsibilities for the protection of particular assets, or the execution of particular processes or activities such as data protection.

b) Confidential Personal Data – Sensitive Information

All personal details will be held securely and in accordance with current applicable legislation.

All data classified as sensitive data will be processed and stored in compliance with the current sensitive information guidelines and Company policies and procedures.

c) Confidentiality Undertaking

All suppliers, members of staff and partners are reminded of their obligation to protect confidential information in accordance with the Company’s standard terms and conditions of employment.

All users will be bound by the confidentiality agreement in either their contract or terms of employment.

d) Employee Responsibilities

All staff (including agency and casual staff) must agree to written terms and conditions contained within the Company handbook.

The Company shall ensure that:

  • Confidentiality agreements form part of the terms and conditions of employment;
  • Awareness training about electronic information security forms part of Company staff induction programmes with annual refresher training
  • Information for all staff on electronic information security is maintained in the Company information;

At least 2 references for a period extending to three years prior to the recruitment date are checked by personnel prior to a member of staff’s commencement of employment.

The Company must ensure that where there are specific security roles and responsibilities, they are documented in all relevant job descriptions and that there is appropriate screening of applicants.

e) Staff Leaving Employment

On termination of employment with the Company, any applicable user accounts, accesses and passwords will be changed or removed.

9. Responding to Security Incidents
a) Suspected Security Breach

The Company will be responsible for identifying members of staff who are responsible for security breach investigations.

A security incident is any incident which alters, destroys or amends data within the Key Business Systems without authority. This may cause damage to or reduce the efficiency of the Company network or IT Services. This includes any actions or behaviours which contravenes Company policy, statutory or common law, legal requirements or professional regulation or guidance.

b) Reporting Security Incidents

All staff are made aware of the process to follow in the event of a serious security breach (for example lost or stolen devices). This process is defined below:

  • Report to the management of the Company
  • If you are reporting a stolen item, report to the police
  • If able, initiate a remote wipe of the device (if this is a company credit card report to the bank and cancel this card)
  • Inform colleagues that you no longer have this device
  • The management of the Executive Zone will judge whether to report this loss to clients, based on the risks
  • Update the incident log and other relevant records

All suspected security incidents are to be reported immediately to the management of The Executive Zone.

All reported security incidents and active investigations will be monitored by the management of The Executive Zone. An appropriate investigation and action plan will be prepared and agreed with a representative of the Company Senior Management Team.

Within the provisions of the Indian Law, the Company reserves the right at any time to intercept and monitor communications. The above legislation will be implemented in compliance with the Company monitoring provisions.

Monitoring and recording of electronic communication and data will be carried out in accordance with current Company Policy and interception / monitoring of individual activity shall normally only take place with prior express approval of the Compan management, but may be undertaken without any prior notice to the users of the Company systems.

Permission for undertaking monitoring or surveillance of user activity may in the first instance be given verbally. Any such permission must be recorded in writing as soon as practical.

This requirement is to ensure an auditable investigatory process exists for a subsequent disciplinary or criminal proceeding.

c) Security Incident Management / Investigation

The senior member of staff identified as being responsible for investigating the incident will ensure that all steps are taken to limit damage and loss of data whilst preserving the reputation of the Executive Zone.

The management will maintain written procedures for the operation (e.g. start up, backup, show down and change control) of those Company Key Business Systems where threat, risk and organizational impact would adversely affect the operational effectiveness or organisational reputation.

10. Physical and Environmental Security

Controls will be implemented as appropriate to prevent unauthorized access to, interference with, or damage to information assets.

a) Physical Security

Computer systems and networks will be protected by suitable physical, technical, procedural and environmental security controls.

File servers and machines that hold or process high criticality, high sensitivity or high availability data are managed by specialist third parties, and contracts with these third parties include a requirement to locate hardware in suitable environments with suitable physical security . All Key Business Systems will be subject to security measures which support the Company’s Continuity Plan.

b) Communications and Operations Management

Controls will be implemented to enable the correct and secure operation of information processing facilities.

c) Documented Operating Procedure

Design, build and configuration documentation will be produced in respect of system platforms. Sensitive documentation will be held securely and access restricted to staff on a need to know basis.

d) Segregation of Duties

Access to Key Business Systems and key data and information will only be granted based on the user role and access clarification.

When deemed necessary segregation of duties between operations and development environment shall be strictly maintained and all work on Key Business Systems will be strictly segregated.

Permanent and full access to live operating environments will be restricted to staff on role-based requirements

11. System Planning and Acceptance
a) System Changes

All changes to live Key Business Systems will follow a predefined change management process, to ensure that activities are undertaken in accordance with stringent change control processes and with, where relevant, client sign-of

b) Controls Against Malicious Software

All systems must be protected by a multi-level approach involving firewall, email scanning, and virus and spy/malware protection on all workstations on the Company network.

All Company workstations will have the appropriate anti-virus software installed and set up to update anti-virus signatures automatically. This must not be turned off by users. Any device found to pose a threat to data or the provision of the Company network will be isolated from the Company network until the security issues are resolved.

Clients and suppliers may use their own PC hardware to connect to the Company systems. Network traffic will be monitored for any anomalous activity which may indicate a security threat to the network.

c) Virus Protection

A Virus Protection procedure will be implemented to prevent the introduction and transmission of computer viruses both within and from outside the Company. Failure to maintain a device in a state which prevents or detects virus infection will leave the device liable to exclusion from the Company network until the security issue is resolved.

d) Security Patches Fixes and Workarounds

The companies will be responsible ensuring that suppliers of all cloud based services are implementing security patches and fixes in a timely manner to reduce vulnerabilities to devices within the Company network.

12. IT Housekeeping and Storage
a) Data Storage

System backups will be performed automatically by the relevant systems. The procedure will include keeping backups off site. Periodic checks will be made to ensure backup media can be read and files restored.

Backups protect electronic information from major loss or failure of system software and hardware. Backups are not designed to guard against accidental deletion or overwriting of individual user data files backup and recovery of individual user files is the responsibility of the information owner.

b) Network Management

Controls will be implemented to achieve, maintain and control access to computer networks, including wireless LANs.

c) Devices Disposal

Redundant computer equipment will be disposed through secure and auditable means.

d) Software Usage and Control

Software will be used, managed and controlled in accordance with legislative and Company policy requirements in relation to asset management and licence agreements. All major software upgrades and in house systems development for Key Business Systems will be appropriately controlled and tested through a managed process before live implementation and Deployment. All software used on devices managed by the Company must be installed in compliance with current software licensing policies.

e) Information Exchange Requests

Use of the Company network will be governed by the Electronic Information Security Policy and the Policy for using IT Resources. Failure to comply with these requirements will leave a user liable to disciplinary and/or possible criminal legal penalties.

13. Access Control
a) Policy Statement

Procedures for the registration and deregistration of users and for managing access to all information systems shall be established to ensure that all users’ access rights match their authorizations. These procedures shall be implemented by the Executive Zone. A periodic review will be conducted to verify user access and roles.

b) Operational Policy

Access to Key Business Systems will be appropriately controlled and comply with the access rights of the user.

Access to the Company network and IT Services will be restricted according to the access classification of the user.

Company staff, clients, suppliers and external users may use:

  • Standard software portfolio;
  • Shared file store;
  • Email, calendar and public folders;
  • Company Business Systems;
  • Internet.
c) User Responsibilities

Users of the Company network must comply with Company Policies and the Electronic Information Security Policy.

All staff and clients (including agency and temporary staff) must agree to written terms and conditions covering use of IT when they register to use Company IT services.

Personnel Services shall ensure that:

  • Confidentiality Agreements form part of the terms and conditions of Employment;
  • Awareness training about electronic information security forms part of Company Staff Induction Programmes;
  • Information for all staff on electronic information security is maintained in the staff handbook;

The Company must ensure that where there are specific security roles and responsibilities, they are documented in all relevant job descriptions and that there is appropriate screening of applicants.

Access to Company systems may be withdrawn and Company disciplinary procedures invoked where a serious or deliberate breach of the policy is made

14. Company Key Business System Access
a) Subject Access Management and Administration

Formal procedures will be implemented for granting access to both the Company network and IT services. This will be supported by a formal review of user privileges on a regular basis to ensure that they remain appropriate to the role and relationship with the Company.

Accounts identified as dormant will be closed.

b) Password Management

Users are required to follow good security practices in the selection, use and management of their password and to keep them confidential.

Authorization of access to Key Business Systems and to the data held by them is the responsibility of the system owner.

System administrator passwords will be issued on the express authority of the IT personnel on a need to know basis. Such passwords will be changed regularly and when authorized systems administrator staff leave.

For all systems the following must be enforced:

  • Network password must be a minimum of eight characters;
  • Network password will be subject to enforced periodic change.
  • Network password history will prevent reuse of the last three password changes;
  • Accounts will be locked on the third failed login attempt.

Policy on network password complexity will be reviewed periodically.

The account type should at all times reflect the business relationship existing with the member of staff.

As a staff member moves to a less formal relationship with the Company then the account associated with that person should reflect this new relationship.

The Company will maintain a list of staff with access to key business systems and services.

c) Unattended User Equipment

Users of the Company network and IT services are responsible for safeguarding Key Business System Data and sensitive information. In order to protect these information assets, users are required to ensure that devices are not left logged on when unattended and that portable equipment in their custody is not exposed to opportunistic theft, unauthorised access or observation of sensitive information.

Where available, password protected screensavers and automatic log out mechanisms are to be used on systems to prevent individual accounts being used by persons other than the account holders.

15. Compliance
Compliance with Legal and Company Policy

Supply and use of the Company network and IT services is bound by Indian law current at the time of any reported incident. The policy for using IT resources provides guidance on the most common legal and policy requirement pertaining to Company network use.

The Executive Zone will maintain and monitor, at six monthly intervals, reports of records of electronic security incidents. Reports will be considered by the Company. It will then be decided if further action or investigation is required.

People who are neither staff nor suppliers do not normally have an automatic right to use the Company network or IT services. Authorisation for such external users will be subject to sponsorship from a member of Company staff along with written agreement from the user to abide by the Company policies.

All applications for external users will be subject to approval by the Executive Zone.

Any outsourcing must include express provisions with respect to IT security and control and any applicable Indian law in relation to data processing and confidentiality.