C-View Technologies Customer Privacy and Data Protection Policy V2.1, Dec 2018
Policy brief & purpose
Our Data Protection company policy refers to the company’s commitment to treat information of employees, customers, stakeholders or other interested parties with the utmost care and confidentiality.
With this policy we ensure that the company behaves in a fair and moral manner concerning
the gathering, storing and handling of data. This process will be carried out with transparency and respect towards the rights of individuals who entrust it with their information.
This policy applies to all parties (employees, job candidates, customers, suppliers etc.) who provide any amount of information to the company. The policy will be followed by all employees of the company and its subsidiaries as well as contractors, consultants, partners and any other external entity. Generally, it refers to anyone who is in close collaboration with the company or acts on its behalf and may need occasional access to data.
The company will need to obtain and process information of people that will serve its business purposes. The information may refer to any offline or online information that makes a person identifiable such as names, addresses, usernames and passwords, digital footprints, photographs, social security numbers, financial data etc.
The company commits to collect this information in a transparent way and only with the full cooperation and knowledge of interested parties. Once this information is available to the company, the following rules are mandatory:
- The data will be collected fairly and for lawful purposes only
- The data will be processed by the company within its legal and moral boundaries
- The data will not be stored for more than the specified amount of time
- The data will be accurate and kept up-to-date
- The data will not be distributed to any party other than the ones agreed upon by the owner of the data (exempting legitimate requests from law enforcement authorities)
- The data will not be transferred to organizations, states or countries that do not have adequate data protection policies
- The data will not be communicated informally
- The data will be protected against any unauthorized or illegal access by internal or external parties
In addition to ways of handling the data the company has direct obligations towards people to whom the data belongs. Specifically the company must:
- Let people know which of their data is collected
- Inform people about how their data will be processed
- Inform people about who has access to their information
- Allow people to request the modification, erasing, reduction or correction of the data contained in the company’s databases
- Have provisions in cases of lost, corrupted or compromised data
Security Organisation and Leadership
- MD oversight of security matters as Senior Information Risk Owner (SIRO)
- Operational ownership of security matters held by a dedicated Security Manager
- Segregation of duties between Security and Compliance managers and teams
- Board representation in security decisions
- Strong investment in security technologies, personnel and processes
Physical and Environmental Security
- ISO 27001 certified data centres
- Comprehensive CCTV coverage with footage retained for 90 days
- Biometric and/or RFID badge controlled access to data halls
- Physical access limited to specific necessary personnel
- Stand-off fenced perimeters in place
- At least N+1 UPS, generators and HVAC
- FM-200 fire suppression
- Continuous Building Management System monitoring
- Incident management and change control procedures in place
- Active involvement in the security community
- DevOps security model allowing rapid mitigation of security issues
- Strict media sanitisation and destruction procedures
- Role-based access control
- Customer support activity logging
- All staff are BPSS screened prior to commencing employment
- SC vetted staff
- Defined and managed hiring and termination policies
- Mandatory confidentiality agreements for all staff
- On-going security awareness training for all staff
- ISO 27001:2013 certified hosting services and data centres
- ISO 9001 and 14001 certified
- PGA accredited to provide Official (IL2-IL3) services
- Accredited to provide Official classified services via encrypted PSN overlay
ISO 27001:2013 Information Security Management System
A BSI standard which certifies that our management systems conform to their rigorous security standards, especially with regards to managing security risks.
This certification consists of 133 controls and applies to the architecture of the entire Information Security Management System.
We have implemented a complete version of ISO 27001. The Statement of Applicability (SoA), allows certified parties to determine which controls apply to them. We have implemented all 133 controls.
Backup & Encryption
All EP client databases are backed-up overnight to a separate backup server (Memset) and also to an external site (Amazon S3).
All EP traffic is secured using encrypted HTTPS communication sessions.
To exercise data protection the company is committed to:
- Develop transparent data collection procedures
- Establish data protection practices (document shredding, secure locks, data encryption, frequent backups, access authorization etc.)
- Build secure networks to protect online data from cyberattacks
- Include contract clauses or communicate statements on how data will be handled
- Inform individuals of the amount of time that their data will be preserved
- Declare its data protection provisions publicly (e.g. on website)
- Ensure all concerned parties have read the policy and adhere to it
- Train employees in online privacy and security measures
- Restrict and monitor access to sensitive data
- Establish clear procedures for reporting breach of privacy or data misuse
All principles described in this policy must be strictly followed. A breach of data protection guidelines will invoke disciplinary and possibly legal action.