Cyber Security Policy

Last Reviewed Aug 2019

POLICY BRIEF & PURPOSE

PVTL LTDs’ cyber security policy outlines our guidelines and provisions for preserving the security of our data and technology infrastructure Internally and where applicable with client data.

The more we rely on technology to collect, store and manage information, the more vulnerable we become to severe security breaches. Human errors, hacker attacks and system malfunctions could cause financial damage and may jeopardize our company’s reputation.

For this reason, we have implemented a number of security measures to combat this. We have also prepared instructions that may help mitigate security risks. We have outlined both provisions in this policy.

SCOPE

This policy applies to all our employees, contractors, volunteers and anyone who has permanent or temporary access to our systems and hardware.

POLICY ELEMENTS

CONFIDENTIAL DATA

Confidential data is secret and valuable. Common examples are:

Unpublished financial information Data of customers/partners/vendors Patents, formulas or new technologies

Customer lists (existing and prospective)

Correspondence between clients that’s covered and protected by NDA

All employees are obliged to protect this data. In this policy, we will give our employees instructions on how to avoid security breaches.

PROTECT PERSONAL AND COMPANY DEVICES

When employees use their digital devices to access company emails or accounts, they introduce security risk to our data. We enforce our employees to keep both their personal and company-issued computer, tablet and cell phone secure.

They can do this if they:

  • Keep all devices password protected.
  • ESET Security Services are kept fully up to date.
  • Ensure they do not leave their devices exposed or unattended.
  • Automatically Install security updates of browsers and systems as soon as updates are available.
  • Log into company accounts and systems through secure and private networks only. All internal infrastructure is accessed via VPN’s only where applicable and possible.

We prohibit our employees accessing internal systems and accounts from other people’s devices or lending their own devices to others without supervision and monitoring.

When a new employee receives company-issued equipment they will receive equipment that has been prepared internally before for security purposes.

KEEPING EMAILS SAFE

Emails often host scams and malicious software (e.g. worms.) To avoid virus infection or data theft, all staff have received internal training on how to spot spam, and an internal policy t o check with senior staff if you’re unsure. Some of the key points relating to our training are:

  • Avoid opening attachments and clicking on links when the content is not adequately explained (e.g. “watch this video, it’s amazing.”)
  • Be suspicious of clickbait titles (e.g. offering prizes, advice.)
  • Check email and names of people they received a message from to ensure they are legitimate.
  • Look for inconsistencies or give-aways (e.g. grammar mistakes, capital letters, excessive number of exclamation marks.)

If an employee isn’t sure that an email they received is safe, they can refer specified internal staff for assistance.

PASSWORD MANAGER

Password leaks are dangerous since they can compromise our entire infrastructure. Not only should passwords be secure so they won’t be easily hacked, but they should also remain secret. For this reason, we enforce our employees to:

Choose passwords with at least eight characters (including capital and lower-case letters, numbers and symbols) and avoid information that can be easily guessed (e.g. birthdays.)

Remember passwords instead of writing them down. If employees need to write their passwords, they are obliged to keep the paper or digital document confidential and destroy it when their work is done.

Exchange credentials only when absolutely necessary, and via secure means only. We have internal systems to facilitate this.

Change their passwords every two months where possible.

Remembering a large number of passwords can be daunting. We supply a password management tool which generates and stores passwords. Employees are obliged to create a secure password for the tool itself, following the above mentioned advice.

TRANSFER DATA SECURELY

Transferring data introduces security risk. Employees must:

  • Avoid transferring sensitive data (e.g. customer information, employee records) to other devices or accounts unless absolutely necessary. When mass transfer of such data is needed, we request employees to use our secure internal file transfer tools.
  • Share confidential data over the company network/ system and not over public Wi-Fi or private connection. 
  • Ensure that the recipients of the data are properly authorized people or organizations and have adequate security policies.
  • Report scams, privacy breaches and hacking attempts

Our Operations manager / Security specialists / Directors need to know about scams, breaches and malware so they can better protect our infrastructure. For this reason, we advise our employees to report perceived attacks, suspicious emails or phishing attempts as soon as possible internally. An appropriate team of staff will investigate promptly, resolve the issue and send a companywide alert when necessary.

Our Security Specialists internally are responsible for advising employees on how to detect scam emails. We encourage our employees to reach out to them with any questions or concerns.

ADDITIONAL MEASURES

To reduce the likelihood of security breaches, we also instruct our employees to:

  • Turn off their screens and lock their devices when leaving their desks.
  • Report stolen or damaged equipment as soon as possible to the relevant party.
  • Change all account passwords at once when a device is stolen.
  • Report a perceived threat or possible security weakness in company systems.
  • Refrain from downloading suspicious, unauthorized or illegal software on their company equipment.
  • No public or personal device access to our internal networks
  • PCI DSS Compliance.
  • DPIA (Data protection Impact Assessments) undertaken where required.
  • We also expect our employees to comply with our social media and internet usage policy. Our Security Specialists have:
  • Installed firewalls, anti malware software and access authentication systems.
  • Inform employees regularly about new scam emails or viruses and ways to combat them. 
  • Arrange for security training to all employees as applicable.
  • Investigate security breaches thoroughly.
  • Follow this policies provisions as other employees do.
  • Our company will have all physical and digital shields to protect information.

REMOTE EMPLOYEES

Remote employees must follow this policy’s instructions too. Since they will be accessing our company’s accounts and systems from a distance, they are obliged to follow all data encryption, protection standards and settings, and ensure their private network is secure.

We encourage them to seek advice from our Security Specialists as required.

DISCIPLINARY ACTION

We expect all our employees to always follow this policy and those who cause security breaches may face disciplinary action:

First-time, unintentional, small-scale security breach: We may issue a verbal warning and train the employee on security.

Intentional, repeated or large scale breaches (which cause severe financial or other damage): We will invoke more severe disciplinary action up to and including termination. We will examine each incident on a case-by-case basis.

Additionally, employees who are observed to disregard our security instructions will face progressive discipline, even if their behavior hasn’t resulted in a security breach.

TAKE SECURITY SERIOUSLY

Everyone, from our customers and partners to our employees and contractors, should feel that their data is safe. The only way to gain their trust is to proactively protect our systems and databases. We can all contribute to this by being vigilant and keeping cyber security top of mind.