Information Security Management Policy

1. Introduction

This Policy Document encompasses all aspects of security surrounding confidential company information and must be distributed to all company employees. All company employees must read this document in its entirety and ensure they understand this policy fully. This document will be reviewed and updated by Management on an annual basis or when relevant to include newly developed security standards into the policy and distribute it all employees and contracts as applicable.

2. Information Security Policy

The Company handles sensitive information about donors, fundraisers and charities daily. Sensitive Information must have adequate safeguards in place to protect them, to protect donor/ fundraiser privacy, to ensure compliance with various regulations and to guard the future of the organisation. The Company commits to respecting the privacy of all its customers and to protecting any data about customers from outside parties. To this end management are committed to maintaining a secure environment in which to carry out its business processes so that we can meet these promises.

Employees handling customer data should ensure:

• Handle Company and customer information in a manner that fits with their sensitivity;
• Limit personal use of the Company information and telecommunication systems and ensure it doesn’t interfere with your job performance;
• The Company reserves the right to monitor, access, review, audit, copy, store, or delete any electronic communications, equipment, systems and network traffic for any purpose;
• Do not use e-mail, internet and other Company resources to engage in any action that is offensive, threatening, discriminatory, defamatory, slanderous, pornographic, obscene, harassing or illegal;
• Do not disclose personnel information unless authorised;
• Protect sensitive customer information;
• Keep passwords and accounts secure;
• Request approval from management prior to establishing any new software or hardware, third party connections, etc.;
• Do not install unauthorised software or hardware, including modems and wireless access unless you have explicit management approval;
• Always leave desks clear of sensitive company or customer data and lock computer screens when unattended;
• Information security incidents must be reported, without delay, to the individual responsible for incident response locally – Please find out who this is. We each have a responsibility for ensuring our company’s systems and data are protected from unauthorised access and improper use. If you are unclear about any of the policies detailed herein you should seek advice and guidance from your manager.

3. Acceptable Use Policy

The Management’s intentions for publishing an Acceptable Use Policy are not to impose restrictions that are contrary to the Company’s established culture of openness, trust and integrity. Management is committed to protecting the employees, partners and the Company from illegal or damaging actions by individuals, either knowingly or unknowingly.

• The Employees are responsible for exercising good judgment regarding the reasonableness of personal use.
• Employees should ensure that they have appropriate credentials and are authenticated for the use of technologies
• Employees should take all necessary steps to prevent unauthorized access to confidential data.
• Employees should ensure that technologies should be used and setup in acceptable network locations
• Keep passwords secure and do not share accounts.
• Authorized users are responsible for the security of their passwords and accounts.
• All PCs, laptops and workstations should be secured with a password-protected screensaver with the automatic activation feature.
• All POS and PIN entry devices should be appropriately protected and secured so they cannot be tampered or altered.
• Because information contained on portable computers is especially vulnerable, special care should be exercised.
• Postings by employees from a Company email address to newsgroups should contain a disclaimer stating that the opinions expressed are strictly their own and not necessarily those of the Company, unless posting is in the course of business duties.
• Employees must use extreme caution when opening e-mail attachments received from unknown senders, which may contain viruses, e-mail bombs, or Trojan horse code.

4. Disciplinary Action

Violation of the standards, policies and procedures presented in this document by an employee will result in disciplinary action, from warnings or reprimands up to and including termination of employment. Claims of ignorance, good intentions or using poor judgment will not be used as excuses for non compliance.

5. Protect Stored Data

• All sensitive data stored and handled by the Company and its employees must be securely protected against unauthorised use at all times. Any sensitive data that is no longer required by the Company for business reasons must be discarded in a secure and irrecoverable manner.
• It is strictly prohibited to store:
  • The contents of the payment card magnetic stripe (track data) on any media whatsoever.
  • The CVV/CVC (the 3 or 4 digit number on the signature panel on the reverse of the payment card) on any media whatsoever.
  • The PIN or the encrypted PIN Block under any circumstance

6. Information Classification

Data and media containing data must always be labelled to indicate sensitivity level

• Confidential data might include information assets for which there are legal requirements for preventing disclosure or financial penalties for disclosure, or data that would cause severe damage to the Company if disclosed or modified. Confidential data includes cardholder data.
• Internal Use data might include information that the data owner feels should be protected to prevent unauthorized disclosure;
• Public data is information that may be freely disseminated

7. Access to the sensitive user data

All Access to sensitive user should be controlled and authorised. Any Job functions that require access to cardholder data should be clearly defined.

1. Any display of the card holder should be restricted at a minimum of the first 6 and the last 4 digits of the cardholder data.
2. Access rights to privileged user information should be restricted to least privileges necessary to perform job responsibilities
3. Privileges should be assigned to individuals based on job classification and function (Role based access control)
4. Access to sensitive user information such as personal information and business data is restricted to employees that have a legitimate need to view such information.
5. No other employees should have access to this confidential data unless they have a genuine business need.
6. The Company will ensure a written agreement that includes an acknowledgement is in place that the Service Provider will be responsible for the for the cardholder data that the Service Provider possess.
7. The Company will do proper due diligence is in place before engaging with a Service provider.
8. The Company will ensure the Service provider is PCI DSS compliant

8. Physical Security

Access to sensitive information in both hard and soft media format must be physically restricted to prevent unauthorised individuals from obtaining sensitive data.

• Employees are responsible for exercising good judgment regarding the reasonableness of personal use.
• Employees should ensure that they have appropriate credentials and are authenticated for the use of technologies
• Employees should take all necessary steps to prevent unauthorized access to confidential data which includes user information.
• Employees should ensure that technologies should be used and setup in acceptable network locations
• A “visitor” is defined as a vendor, guest of an employee, service personnel, or anyone who needs to enter the premises for a short duration, usually not more than one day.
• Keep passwords secure and do not share accounts. Authorized users are responsible for the security of their passwords and accounts.
• Media is defined as any printed or handwritten paper, received faxes, floppy disks, back-up tapes, computer hard drive, etc.
• Media containing sensitive user information must be handled and distributed in a secure manner by trusted individuals.
• Visitors must always be escorted by a trusted employee when in areas that hold sensitive user information.
• Strict control is maintained over the external or internal distribution of any media containing user data and has to be approved by management.
• Strict control is maintained over the storage and accessibility of media.
• All computer that store sensitive cardholder data must have a password protected screensaver enabled to prevent unauthorised use.

9. Protect Data in Transit

All sensitive user data must be protected securely if it is to be transported physically or electronically.

• Sensitive financial data must never be sent over the internet via email, instant chat or any other end user technologies.
• If there is a business justification to send financial data via email or via the internet or any other modes then it should be done after authorization and by using a strong encryption mechanism (i.e. – AES encryption, PGP encryption, SSL,TLS,IPSEC, GSM, GPRS, Wireless technologies etc.,).

10. Disposal of Stored Data

• All data must be securely disposed of when no longer required by the Company, regardless of the media or application type on which it is stored.
• An automatic process must exist to permanently delete on-line data, when no longer required.
• All hard copies of sensitive data must be manually destroyed as when no longer required for valid and justified business reasons.
• The Company will have procedures for the destruction of hardcopy (paper) materials. These will require that all hardcopy materials are crosscut shredded, incinerated or pulped so they cannot be reconstructed.
• All sensitive user information awaiting destruction must be held in lockable storage containers clearly marked “To Be Shredded” - access to these containers must be restricted.
• The Company will have documented procedures for the destruction of electronic media. These will require:
  • All sensitive data on electronic media must be rendered unrecoverable when deleted e.g. through degaussing or electronically wiped or the physical destruction of the media;
  • If secure wipe programs are used, the process must define the industry accepted standards followed for secure deletion.

11. Security Awareness and Procedures

The policies and procedures outlined below must be incorporated into company practice to maintain a high level of security awareness.

• Review handling procedures for sensitive information and hold periodic security awareness meetings to incorporate these procedures into day to day company practice.
• Distribute this security policy document to all company employees to read.
• All third parties with access to credit card account numbers are contractually obligated to comply with card association security standards (PCI/DSS).
• Company security policies must be reviewed annually and updated as needed