General Data Protection Regulation (GDPR)

Elixir Bathrooms
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21 May 2018
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Introduction

This Policy Document encompasses all aspects of security surrounding confidential company information and General Data Protection Regulation (GDPR) Measures. All company employees must read this document in its entirety and sign a form confirming they have read and 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.

Information Security Policy

Elixir Bathrooms handles sensitive cardholder information daily. Sensitive Information must have adequate safeguards in place to protect them, to protect cardholder privacy, to ensure compliance with various regulations.
Elixir Bathrooms 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 process cardholder information so that we can meet these promises.
Employees handling Sensitive cardholder data should ensure:

Handle Company and cardholder information in a manner that fits with their sensitivity;
Limit personal use of anglia self storage information and telecommunication systems and ensure it doesn’t interfere with your job performance;
Elixir Bathrooms 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 cardholder 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 data and lock computer screens when unattended;
Information security incidents must be reported, without delay, to the individual responsible for incident response locally.
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 line manager.

Acceptable Use Policy

The Management’s intentions for publishing an Acceptable Use Policy are not to impose restrictions that are contrary to Elixir Bathrooms 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. Anglia self storage will maintain an approved list of technologies and devices and personnel with access to such devices as detailed in Appendix B.

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 card holder 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.
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 Elixir Bathrooms, 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.

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.

Protect Stored Data

All sensitive data stored and handled by company and its employees must be securely protected against unauthorised use at all times. Any sensitive data that is no longer required by anglia self storage for business reasons must be discarded in a secure and irrecoverable manner.

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 anglia self storage 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.
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 card holder data.
Employees should ensure that technologies should be used and setup in acceptable network locations
A list of devices that accept payment card data should be maintained.
The list should include make, model and location of the device
The list should have the serial number or a unique identifier of the device
The list should be updated when devices are added, removed or relocated
POS devices surfaces should be periodically inspected to detect tampering or substitution.
Personnel using the devices should be trained and aware of handling the POS devices
Personnel using the devices should verify the identity of any third party personnel claiming to repair or run maintenance tasks on the devices, install new devices or replace devices.
Personnel using the devices should be trained to report suspicious behaviour and indications of tampering of the devices to the appropriate personnel.
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 cardholder 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 cardholder information.
Procedures must be in place to help all personnel easily distinguish between employees and visitors, especially in areas where cardholder data is accessible. “Employee” refers to full-time and part-time employees, temporary employees and personnel, and consultants who are “resident” on anglia self storage sites. 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.
Strict control is maintained over the storage and accessibility of media
All computers that store sensitive cardholder data must have a password protected screensaver enabled to prevent unauthorised use.

Disposal of Stored Data

All data must be securely disposed of when no longer required by anglia self storage, 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 cardholder data must be manually destroyed as when no longer required for valid and justified business reasons. A quarterly process must be in place to confirm that all non-electronic cardholder data has been appropriately disposed of in a timely manner.
Anglia self storage 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 cardholder information awaiting destruction must be held in lockable storage containers clearly marked “To Be Shredded” – access to these containers must be restricted.

Security Awareness and Procedures

The policies and procedures outlined below must be incorporated into company practice to maintain a high level of security awareness. The protection of sensitive data demands regular training of all employees and contractors.

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. It is required that all employees confirm that they understand the content of this security policy document by signing an acknowledgement form (see Appendix A)
Company security policies must be reviewed annually and updated as needed.

System and Password Policy

All users, including contractors and vendors with access to Elixir Bathrooms systems, are responsible for taking the appropriate steps, as outlined below, to select and secure their passwords.

All unnecessary default accounts must be removed or disabled before installing a system on the network.
All users must use a password to access the company network or any other electronic resources
All user ID’s for terminated users must be deactivated or removed immediately.
All system and user level passwords must be changed on at least a quarterly basis.
A minimum password history of four must be implemented.
A unique password must be setup for new users and the users prompted to change the password on first login.
Group, shared or generic user account or password or other authentication methods must not be used to administer any system components.
The responsibility of selecting a password that is hard to guess generally falls to users. A strong password must:

Be as long as possible (never shorter than 6 characters).
Include mixed-case letters, if possible.
Include digits and punctuation marks, if possible.
Not be based on any personal information.
Not be based on any dictionary word, in any language.

If an operating system without security features is used (such as DOS, Windows or MacOS), then an intruder only needs temporary physical access to the console to insert a keyboard monitor program. If the workstation is not physically secured, then an intruder can reboot even a secure operating system, restart the workstation from his own media, and insert the offending program.

Anti-virus policy

All machines must be configured to run the latest anti-virus software as approved by Elixir Bathrooms. The preferred application to use is ….. Anti-Virus software, which must be configured to retrieve the latest updates to the antiviral program automatically on a daily basis. The antivirus should have periodic scanning enabled for all the systems.
The antivirus software in use should be cable of detecting all known types of malicious software (Viruses, Trojans, adware, spyware, worms and rootkits)
All removable media (for example floppy and others) should be scanned for viruses before being used.
All the logs generated from the antivirus solutions have to be retained as per legal/regulatory/contractual requirements or at a minimum of 3 months online and 1 year offline.
Master Installations of the Antivirus software should be setup for automatic updates and periodic scans
End users must not be able to modify and any settings or alter the antivirus software
E-mail with attachments coming from suspicious or unknown sources should not be opened. All such e-mails and their attachments should be deleted from the mail system as well as from the trash bin. No one should forward any e-mail, which they suspect may contain virus.

Remote Access policy

It is the responsibility of the Company employees, contractors, vendors and agents with
remote access privileges to the Company’s corporate network to ensure that their remote
access connection is given the same consideration as the user’s on-site connection to the Company.
Secure remote access must be strictly controlled. Control will be enforced by two factor authentication via one-time password authentication or public/private keys with strong pass-phrases.
Vendor accounts with access to the company network will only be enabled during the time period the access is required and will be disabled or removed once access is no longer required.
Remote access connection will be setup to be disconnected automatically after 30 minutes of inactivity
All hosts that are connected to the Company internal networks via remote access technologies will be monitored on a regular basis.
All remote access accounts used by vendors or 3rd parties will be reconciled at regular interviews and the accounts will be revoked if there is no further business justification.
Vendor accounts with access to the Company network will only be enabled during the time period the access is required and will be disabled or removed once access is no longer required.
Incident Response Plan

‘Security incident’ means any incident (accidental, intentional or deliberate) relating to your communications or information processing systems. The attacker could be a malicious stranger, a competitor, or a disgruntled employee, and their intention might be to steal information or money, or just to damage your company.

The Incident response plan has to be tested once annually. Copies of this incident response plan is to be made available to all relevant staff members, and take steps to ensure that they understand it and what is expected of them.

Employees of the company will be expected to report to the security officer for any security related issues.

The anglia self storage security incident response plan is as follows:

Each department must report an incident to the Manager.
The manager will investigate the incident and assist the potentially compromised area.
The manager will resolve the problem to the satisfaction of all parties involved, including reporting the incident and findings to the appropriate parties as necessary.
The manager will determine if policies and processes need to be updated to avoid a similar incident in the future, and whether additional safeguards are required in the environment where the incident occurred, or for the institution.

Incident Response Notification

In the event of a suspected security breach, alert the information security officer or your line manager immediately.
The security officer will carry out an initial investigation of the suspected security breach.
Upon confirmation that a security breach has occurred, the security officer will alert management and begin informing all relevant parties that may be affected by the compromise.

Access Control Policy

Access Control systems are in place to protect the interests of all users of Elixir Bathrooms computer systems by providing a safe, secure and readily accessible environment in which to work.
Anglia self storage will provide all employees and other users with the information they need to carry out their responsibilities in as effective and efficient manner as possible.
Every user should attempt to maintain the security of data at its classified level even if technical security mechanisms fail or are absent.
Users are obligated to report instances of non-compliance to the anglia self storage CISO
Password issuing, strength requirements, changing and control will be managed through formal processes
Users are expected to become familiar with and abide by anglia self storage policies, standards and guidelines for appropriate and acceptable usage of the networks and systems.

Privacy Policy
All programmes used by Elixir Bathrooms are password protected. The information kept is not used for marketing purposes. Information about customers and their account activity is kept for 7 years after they have left as required by HM Revenue and Customs.
In particular, Sage is password protected. Details kept on this programme include the name of the customer, their address, their phone number and email address. It also contains details of account activity.
Access is password protected. It holds details of companies throughout Lincoln that may be interested in services provided by Elixir Bathrooms. The information is drawn from open sources off the internet.
Net2 is password protected. It provides information concerning the use of the gate and the Unit number of the person who is on site at a particular time who has opened the gate. It can be used in conjunction with the CCTV to confirm who/what was happening at the time of an incident. The CCTV footage is deleted automatically at the 12 day point.
End of year accounts are archived for 7 years in a secure out of office location. Once the 7 year period is completed then they will be destroyed by shredding.
The new GDRP regulations require a more rigorous monitoring of data. Breaches of policy must be reported to the manager as soon as possible. When data is deleted through normal work processes a record must be kept however the right to be forgotten is not a right until the 7 year exclusion with HRMC is concluded.

Data Subjects Rights
Be informed (clear data protection notice)
Access (complying with subject access requests)
Rectification (ensure data is accurate)
Restrict processing (allow some processing but not others)
Erase (the right to be forgotten)
Data portability (transferring data from one device to another, such as a fitbit)
Object (not allow processing of data)
Rights in relation to automated decision-making and profiling

Keeping Employees Data Safe

GDPR has greater emphasis on demonstrating appropriate security measures in place. You must be able to show you know where the information is held, how it is used or who has access to it, this includes data held on paper – so it is important to ensure documents are not left lying around, or filing cabinets unlocked. Some major software suppliers have historically only ever archived data, rather than physically deleting it, under GDPR that is no longer appropriate. There are Lawful purposes to maintain data, such as processing salaries and passing to HRMC. You may hold a personal file to protect you against litigation however after 7 years the right to hold this data is lost.

Lawful Purposes for Data Processing

Legitimate interest of the data controller
Necessity for the performance of a contract
Compliance with a legal obligation
Protecting the vital interests of the data subject or of another natural person
Necessity for the performance of a task carried out in the public interest

GDPR requires risk assessment to be ongoing. Constantly monitoring new data, discovering new risks, re-evaluating risk levels, taking mitigation action and updating the action plan.