Information Security Policy

1. Purpose

The purpose of this Information Security Policy is to establish a framework for safeguarding the confidentiality, integrity, and availability of [Company Name]’s information assets. This policy outlines responsibilities, controls, and processes to ensure that information is protected against unauthorized access, disclosure, alteration, or destruction.

2. Scope

This policy applies to all employees, contractors, consultants, temporaries, and other personnel (hereafter referred to as “staff”) who have access to companys information assets, regardless of location or device used. It covers all information systems, networks, applications, databases, physical assets, and processing facilities owned, leased, or otherwise used by the organization.

3. Definitions

• Information Asset: Any data, device, or other component of the environment that supports information-related activities.

• Confidential Information: Non-public information that could cause harm to [Company Name] or its stakeholders if disclosed.

• Integrity: Assurance that information is accurate and complete, and that systems operate without unauthorized modification.

• Availability: Assurance that authorized users have timely and reliable access to information and systems.

• Threat: A potential cause of an unwanted incident which may result in harm to a system or organization.

• Vulnerability: A weakness in a system or its design that could be exploited to compromise security.

4. Roles and Responsibilities

1. Executive Management

   • Sponsor and endorse the Information Security Program.

   • Allocate resources and ensure alignment with business objectives.

   • Review and approve the Information Security Policy.

2. Chief Information Security Officer (CISO) (or equivalent)

   • Develop, implement, and maintain the Information Security Program.

   • Ensure policy compliance and perform regular risk assessments.

   • Report security posture to executive management.

3. Information Security Team

   • Define technical and procedural controls based on risk assessment results.

   • Monitor security events, investigate incidents, and coordinate response activities.

   • Provide guidance on secure configuration, vulnerability management, and secure development.

4. IT Operations

   • Implement and maintain technical controls (e.g., firewalls, intrusion detection, patch management).

   • Conduct regular system backups and disaster recovery testing.

   • Manage user accounts, access provisioning, and de-provisioning.

5. Managers and Supervisors

   • Ensure staff under their supervision adhere to this policy and related procedures.

   • Authorize access to information assets based on the principle of least privilege.

   • Coordinate with the Information Security Team on risk mitigation for their departments.

6. Staff (Employees, Contractors, Third-Party Vendors)

   • Comply with all security policies, standards, and procedures.

   • Report any suspected security incidents or policy violations immediately.

   • Complete mandatory security awareness and training programs.

5. Asset Management

1. Asset Inventory

   • Maintain an up-to-date inventory of all information assets (hardware, software, data, and facilities).

   • Assign a designated “Asset Owner” for each major asset class (e.g., servers, network devices, applications).

2. Asset Classification

   • Classify information assets based on sensitivity and criticality (e.g., Public, Internal, Confidential, Restricted).

   • Labels and handling procedures must align with classification (e.g., encryption for Confidential data, restricted printing or storage).

3. Acceptable Use

   • Define acceptable use guidelines for corporate devices, networks, and data.

   • Prohibit unauthorized software installation, usage of unapproved cloud services, and personal use that compromises security.

4. Asset Disposal

   • Implement secure disposal procedures for hardware and media containing sensitive information (e.g., secure wiping, shredding).

6. Access Control

1. User Account Management

   • Provision user accounts based on documented business need and managerial approval.

   • Enforce unique user IDs; prohibit shared/anonymous accounts.

   • Implement a formal offboarding process to promptly revoke access upon employment termination or role change.

2. Authentication and Authorization

   • Enforce strong password requirements (minimum length, complexity, rotation every 90 days).

   • Where technically feasible, implement multi-factor authentication (MFA) for all remote access, privileged accounts, and critical systems.

   • Apply role-based access control (RBAC) or attribute-based access control (ABAC) to limit permissions to the minimum necessary.

3. Privileged Accounts

   • Restrict privileged (administrative/root) accounts to a limited, audited group.

   • Maintain an up-to-date list of all privileged accounts and periodically review necessity.

   • Use just-in-time (JIT) administration or time-bound elevation where practical.

4. Remote Access

   • Require secure VPN or equivalent encrypted channel for remote access to internal resources.

   • Monitor and log all remote sessions; enforce session timeouts after inactivity.

5. Physical Access Control

   • Restrict access to data centers, server rooms, and network closets to authorized personnel only.

   • Maintain an access log (badge or keycard swipes) for all secure areas.

   • Secure portable devices (laptops, USB drives, etc.) when not in use (e.g., locking in cabinets).

7. Network and Communications Security

1. Network Segmentation

   • Separate critical systems (e.g., production servers, payment systems) from general office networks via network segmentation or VLANs.

   • Implement firewalls, intrusion detection/prevention systems (IDS/IPS), and secure network design practices (defense in depth).

2. Encryption

   • Require encryption for all sensitive data in transit (e.g., TLS 1.2 or higher for web traffic, SFTP for file transfers).

   • For highly sensitive data (e.g., PII, financial data), mandate encryption at rest (e.g., AES-256) on servers, databases, and backup media.

3. Network Monitoring

   • Continuously monitor network traffic for anomalies, potential intrusions, or suspicious behavior.

   • Retain logs (firewall, IDS/IPS, VPN) for a minimum of 90 days to support incident investigation.

4. Wireless Security

   • Secure wireless networks using WPA3 (or WPA2 with strong pre-shared keys if WPA3 is not feasible).

   • Isolate guest Wi-Fi from internal networks; regularly rotate guest Wi-Fi passwords.

8. System Acquisition, Development & Maintenance

1. Secure Development Lifecycle (SDLC)

   • Integrate security requirements at each phase of software development (requirements, design, coding, testing, deployment).

   • Perform regular code reviews, static analysis, and dynamic testing for vulnerabilities.

2. Change Management

   • Enforce a formal change management process: all changes to production systems must be documented, tested in a non-production environment, and approved by change advisory boards (CAB).

   • Maintain roll-back procedures in case updates introduce issues or vulnerabilities.

3. Patch Management

   • Apply security patches and updates within defined timelines:

     • Critical vulnerabilities (CVSS ≥ 7.0): apply within 15 days.

     • High vulnerabilities (CVSS 4.0–6.9): apply within 30 days.

     • Medium/Low vulnerabilities: apply within 60 days.

   • Document patching activities, including exceptions and compensating controls if patching is delayed.

4. Configuration Management

   • Develop and maintain secure configuration baselines for operating systems, network devices, and applications (e.g., CIS Benchmarks).

   • Periodically audit configurations to detect drift from approved baselines.

9. Operations Security

1. Malware Protection

   • Deploy and regularly update anti-malware/endpoint protection on all workstations, servers, and mobile devices.

   • Configure real-time scanning, scheduled full scans, and automatic signature updates.

2. Backup and Recovery

   • Perform regular backups of critical data (daily incremental, weekly full).

   • Store backups securely offsite or in an isolated network segment; encrypt backups where appropriate.

   • Test restoration procedures quarterly to verify integrity, completeness, and timeliness.

3. Logging and Monitoring

   • Enable logging on critical systems (authentication logs, system events, application logs, firewall/IDS logs).

   • Centralize log data in a Security Information and Event Management (SIEM) system or equivalent for correlation and analysis.

   • Retain logs for at least 90 days (or as required by regulatory/compliance frameworks).

4. Antivirus/Anti-Malware Updates

   • Ensure signatures are updated at least daily.

   • Enable heuristic/behavioral detection capabilities wherever possible.

5. Media Handling

   • Classify removable media (USBs, CDs) based on sensitivity of data they may carry.

   • Prohibit unauthorized use of removable media; encrypt all sensitive data stored on removable media.

   • Sanitize or destroy media in accordance with approved disposal procedures when no longer needed.

10. Human Resources Security

1. Pre-Employment Screening

   • Perform background checks in accordance with local laws and regulations for all new hires who will have access to sensitive information.

2. Security Awareness & Training

   • Provide mandatory security awareness training to all staff upon hire and at least annually thereafter.

   • Topics must include phishing awareness, password best practices, incident reporting, and handling of confidential information.

3. Ongoing Awareness

   • Conduct periodic security bulletins/newsletters to highlight emerging threats and remind staff of key policies.

   • Simulate phishing campaigns to assess staff readiness and provide targeted follow-up training.

4. Termination or Change of Employment

   • Immediately revoke access rights (accounts, badges, keys) upon employee termination or role change.

   • Recover all company-owned devices and assets.

   • Conduct exit interviews to remind departing employees of ongoing confidentiality obligations.

11. Incident Response & Management

1. Incident Response Plan (IRP)

   • Maintain a formal, documented IRP outlining steps for detection, containment, eradication, recovery, and lessons learned.

   • Define roles and responsibilities (e.g., Incident Response Team, Legal, Public Relations).

   • Ensure communication channels are established for both internal and external stakeholders (e.g., law enforcement, regulators, customers).

2. Incident Reporting

   • Require all staff to report suspected security incidents immediately to the Information Security Team via designated channels (e.g., hotline, ticketing system).

   • Define criteria for what constitutes a security incident (e.g., unauthorized access, data breach, malware outbreak).

3. Investigation & Forensics

   • Preserve system images, logs, and other evidence to support root-cause analysis and, if necessary, legal proceedings.

   • Engage third-party forensic experts when internal capabilities are insufficient.

4. Communication and Notification

   • Notify impacted parties (e.g., data owners, senior management, customers) in accordance with legal, contractual, and regulatory requirements.

   • If personal data is compromised, comply with applicable data breach notification laws (e.g., GDPR, state breach laws).

5. Post-Incident Review

   • Conduct a “lessons learned” meeting within 30 days of incident closure to identify deficiencies in controls or processes.

   • Update security controls, policies, or procedures to mitigate recurrence.

12. Business Continuity & Disaster Recovery

1. Business Impact Analysis (BIA)

   • Conduct a BIA at least annually to identify critical business functions, dependencies, and acceptable downtime (RTO/RPO).

2. Business Continuity Plan (BCP)

   • Develop, test, and maintain a BCP that addresses continuation of critical operations in the event of major disruption (natural disaster, cyberattack, etc.).

   • Define alternate work sites, redundant systems, and manual workarounds as needed.

3. Disaster Recovery Plan (DRP)

   • Maintain a DRP focused on IT infrastructure recovery:

     • Identify critical systems and recovery objectives.

     • Document procedures for restoring data, rebuilding systems, and reestablishing network connectivity.

   • Test DRP annually (grid-based or tabletop exercises) and update based on lessons learned.

13. Supplier & Third-Party Security

1. Vendor Risk Assessment

   • Perform a security risk assessment for all third parties with access to [Company Name]’s data or systems before onboarding.

   • Classify vendors based on the sensitivity of data shared and criticality of services provided.

2. Contractual Requirements

   • Include security requirements in vendor contracts, such as:

     • Data protection measures (encryption, access controls).

     • Incident notification timelines (e.g., within 24 hours of discovery).

     • Right to audit or request third-party audit reports (e.g., SOC 2, ISO 27001).

3. Ongoing Monitoring

   • Perform periodic security reviews (quarterly or semi-annually) for high-risk vendors.

   • Require vendors to provide evidence of security posture (penetration test reports, vulnerability scan results).

4. Termination/Offboarding of Vendors

   • Revoke vendors’ access to systems and retrieve any company-owned assets upon contract termination.

   • Ensure secure deletion or return of any company data held by the vendor.

14. Compliance and Legal Requirements

1. Applicable Regulations & Standards

   • Ensure adherence to all relevant laws and regulations (e.g., GDPR, HIPAA, PCI DSS, SOX), industry standards (e.g., ISO/IEC 27001, NIST Cybersecurity Framework), and contractual obligations.

2. Audit and Assessment

   • Conduct annual internal audits against the Information Security Policy and applicable standards.

   • Engage independent external auditors (e.g., for SOC 2, ISO 27001 certification) as required.

3. Privacy and Data Protection

   • Limit collection and retention of personally identifiable information (PII) to what is necessary.

   • Implement data subject rights procedures (e.g., access, correction, deletion).

   • Conduct data protection impact assessments (DPIAs) when processing high-risk personal data.

4. Recordkeeping

   • Maintain documentation of security policies, procedures, risk assessments, audits, incident reports, and training records for a minimum of three years (or as required by regulation).

15. Training & Awareness

1. Onboarding Training

   • Provide all new staff with security orientation that covers:

     • Key policies and procedures (e.g., acceptable use, incident reporting).

     • Data handling and classification requirements.

     • Recognizing and reporting phishing attempts.

2. Ongoing Education

   • Require annual refresher training covering evolving threats (social engineering, ransomware), policy updates, and role-specific security practices.

   • Deliver quarterly micro-training modules or security newsletters to highlight recent incidents, new best practices, and emerging threats.

3. Specialized Training

   • Provide advanced security training for staff in technical roles (developers, system administrators) covering topics such as secure coding, vulnerability management, and secure architecture principles.

16. Physical and Environmental Security

1. Facility Access Controls

   • Restrict entry to office premises and data centers via keycards, badges, or biometric controls.

   • Maintain visitor logs; visitors must be escorted at all times.

2. Secure Workstations

   • Enforce screen-locking policies after a defined period of inactivity (e.g., five minutes).

   • Prohibit leaving sensitive documents unattended on desks.

3. Environmental Controls

   • Ensure physical infrastructure (server rooms, network closets) has environmental protections:

     • Fire detection and suppression systems.

     • Uninterruptible Power Supplies (UPS) and backup generators.

     • Temperature and humidity monitoring.

4. Equipment Security

   • Mark all company-owned equipment with asset tags.

   • Require staff to report lost or stolen devices immediately.

   • Encrypt all laptops and mobile devices containing sensitive data.

17. Risk Management

1. Risk Assessment Process

   • Conduct formal risk assessments at least annually and whenever major changes occur (e.g., new product launch, merger/acquisition).

   • Identify assets, threats, vulnerabilities, likelihoods, and potential impacts.

   • Document and prioritize risks based on risk scores (e.g., Likelihood × Impact).

2. Risk Treatment

   • Determine risk treatment strategies: accept, mitigate, transfer, or avoid.

   • Develop and implement action plans for risk mitigation, assign ownership, and track progress.

3. Continuous Monitoring

   • Monitor risk indicators (e.g., vulnerability scan results, threat intelligence) to identify new or changing risks.

   • Update risk register and reprioritize controls as necessary.

18. Policy Compliance & Enforcement

1. Policy Review

   • Review and update this policy at least annually or when significant organizational or technological changes occur.

   • The Information Security Team is responsible for drafting revisions; final approval rests with Executive Management.

2. Non-Compliance

   • Violations of this policy may result in disciplinary action, up to and including termination of employment or legal action.

   • Managers must report confirmed or suspected policy violations to Human Resources and the Information Security Team for investigation.

3. Exceptions

   • Any exceptions to this policy must be formally documented, justified, approved by the CISO (or designated authority), and periodically reviewed.

4. Documentation & Recordkeeping

   • Keep records of policy acknowledgments (signed or electronic) for all staff.

   • Retain historical policy versions to demonstrate adherence to audit requirements.

19. Definitions of Key Controls/Standards Referenced

• Least Privilege: Granting only the access necessary for users to perform their job functions.

• Defense in Depth: Layered security approach that employs multiple controls to protect information assets.

• Segregation of Duties (SoD): Dividing critical tasks among multiple personnel to reduce the risk of error or unauthorized actions.

• Patch Management: The process of regularly applying updates to software and systems to fix known vulnerabilities.

• Encryption: Converting data into a coded form to prevent unauthorized access.