Information Security Policy
This top-level information security policy is a key component of D. M. Keith’s overall information security management framework and should be considered alongside more detailed information security documentation including, system level security policies, security guidance and protocols or procedures.
2. Objectives, Aim and Scope
The objectives of the D. M. Keith Information Security Policy are to preserve:
• Confidentiality - Access to Data shall be confined to those with appropriate authority.
• Integrity – Information shall be complete and accurate. All systems, assets and networks shall operate correctly, according to specification.
• Availability - Information shall be available and delivered to the right person, at the time when it is needed.
2.2. Policy aim
The aim of this policy is to establish and maintain the security and confidentiality of information, information systems, applications and networks owned or held by D. M. Keith.
• Ensuring that all members of staff are aware of and fully comply with the relevant legislation as described in this and other policies.
• Describing the principles of security and explaining how they shall be implemented in the organisation.
• Introducing a consistent approach to security, ensuring that all members of staff fully understand their own responsibilities.
• Creating and maintaining within the organisation a level of awareness of the need for Information Security as an integral part of the day to day business.
This policy applies to all information, information systems, networks, applications, locations and users/staff of D. M. Keith or supplied under contract to it.
3. Responsibilities for Information Security
3.1. Ultimate responsibility for information security rests with the Managing Directors of D. M. Keith Ltd, but on a day-to-day basis the GDPR TFT (TFT) shall be responsible for managing and implementing the policy and related procedures.
3.2. Line Managers are responsible for ensuring that their permanent and temporary staff and contractors are aware of:-
• The information security policies applicable in their work areas
• Their personal responsibilities for information security
• How to access advice on information security matters
3.3. All staff shall comply with information security procedures including the maintenance of data confidentiality and data integrity. Failure to do so may result in disciplinary action.
3.4. The Information Security Policy shall be maintained, reviewed and updated by the GDPR TFT.
3.5. Line managers shall be individually responsible for the security of their physical environments where information is processed or stored.
3.6. Each member of staff shall be responsible for the operational security of the information systems they use.
3.7. Each system user shall comply with the security requirements that are currently in force, and shall also ensure that the confidentiality, integrity and availability of the information they use is maintained to the highest standard.
3.8. Contracts with external contractors that allow access to the organisation’s information systems shall be in operation before access is allowed. These contracts shall ensure that the staff or sub-contractors of the external organisation shall comply with all appropriate security policies.
4.1. D. M. Keith is obliged to abide by all relevant UK and European Union legislation. The requirement to comply with this legislation shall be devolved to employees and agents of D. M. Keith, who may be held personally accountable for any breaches of information security for which they may be held responsible. D. M. Keith shall comply with the following legislation and other legislation as appropriate:
• The Data Protection Act (1998)
• The Data Protection (Processing of Sensitive Personal Data) Order 2000
• Computer Misuse Act (1990)
• Freedom of Information Act (2000)
• Health and Safety at Work Act (1974)
• General Data Protection Regulation (2018)
5. Policy Framework
5.1. Management of Security
• At board level, responsibility for Information Security shall reside with the GDPR TFT.
• D. M. Keith’s Security Officer shall be responsible for implementing, monitoring, documenting and communicating security requirements for the organisation.
5.2. Information Security Awareness Training
• Information security awareness training shall be included in the staff induction process.
• An ongoing awareness programme shall be established and maintained to ensure that staff awareness is refreshed and updated as necessary through regular communications.
5.3. Contracts of Employment
• Staff security requirements shall be addressed at the recruitment stage and all contracts of employment shall contain a confidentiality clause.
• Information security expectations of staff shall be included within appropriate job definitions.
5.4. Security Control of Assets
Each IT asset, (hardware, software, application or data) shall have a named custodian who shall be responsible for the information security of that asset.
5.5. Access Controls
Only authorised personnel who have a justified and approved business need shall be given access to restricted areas containing information systems or stored data.
5.6. User Access Controls
Access to information shall be restricted to authorised users who have a bona-fide business need to access the information.
5.7. Computer Access Control
Access to computer facilities shall be restricted to authorised users who have business need to use the facilities.
5.8. Application Access Control
Access to data, system utilities and program source libraries shall be controlled and restricted to those authorised users who have a legitimate business need e.g. systems or database administrators. Authorisation to use an application shall depend on the availability of a licence from the supplier.
5.9. Computer and Network Procedures
Management of computers and networks shall be controlled through standard documented procedures that have been authorised by the GDPR TFT.
5.10. Information Risk Assessment
The core principle of risk assessment and management requires the identification and quantification of information security risks in terms of their perceived value of asset, severity of impact and the likelihood of occurrence.
Once identified, information security risks shall be managed on a formal basis. They shall be recorded within a baseline risk register and action plans shall be put in place to effectively manage those risks. The risk register and all associated actions shall be reviewed at regular intervals. Any implemented information security arrangements shall also be a regularly reviewed feature of the D. M. Keith risk management programme. These reviews shall help identify areas of continuing best practice and possible weakness, as well as potential risks that may have arisen since the last review was completed.
5.11. Information security events and weaknesses
All information security events and suspected weaknesses are to be reported to the GDPR TFT who can be contacted at taskforce@D.M.keith.com. All information security events shall be investigated to establish their cause and impacts with a view to avoiding similar events.
5.12. Classification of Sensitive Information.
The D. M. Keith Task Force shall implement appropriate information classifications controls, based upon the results of formal risk assessments.
Information, Documents and Data classified as sensitive as a result of a formal risk assessment will be treated securely inline with the risk assessment.
5.13. Protection from Malicious Software
The organisation shall use software countermeasures and management procedures to protect itself against the threat of malicious software. All staff shall be expected to co-operate fully with this policy. Users shall not install software on the organisation’s property without permission from the GDPR TFT. Users breaching this requirement may be subject to disciplinary action.
5.14. User media
Removable media of all types that contain software or data from external sources, or that have been used on external equipment, require the approval of the GDPR TFT before they may be used on D. M. Keith systems. Such media must also be fully virus checked before being used on the organisation’s equipment. Users breaching this requirement may be subject to disciplinary action.
5.15. Monitoring System Access and Use
An audit trail of system access and data use by staff shall be maintained and reviewed on a regular basis.
D. M. Keith has in place routines to regularly audit compliance with this and other policies. In addition it reserves the right to monitor activity where it suspects that there has been a breach of policy. The Regulation of Investigatory Powers Act (2000) permits monitoring and recording of employees’ electronic communications (including telephone communications) for the following reasons:
· Establishing the existence of facts
· Investigating or detecting unauthorised use of the system
· Preventing or detecting crime
· Ascertaining or demonstrating standards which are achieved or ought to be achieved by persons using the system (quality control and training)
· In the interests of national security
· Ascertaining compliance with regulatory or self-regulatory practices or procedures
· Ensuring the effective operation of the system.
Any monitoring will be undertaken in accordance with the above act and the Human Rights Act
5.16. Accreditation of Information Systems
The organisation shall ensure that all new information systems, applications and networks include a security plan and are approved by the GDPR TFT before they commence operation.
5.17. System Change Control
Changes to information systems, applications or networks shall be reviewed and approved by the GDPR TFT.
5.18. Intellectual Property Rights
D. M. Keith shall ensure that all information products are properly licensed and approved by the GDPR TFT. Users shall not install software on the organisation’s property without permission from the IT department and the GDPR TFT. Users breaching this requirement may be subject to disciplinary action.
5.19. Business Continuity and Disaster Recovery Plans
The organisation shall ensure that business impact assessment, business continuity and disaster recovery plans are produced for all mission critical information, applications, systems and networks.
The Information Security Officer shall keep the GDPR TFT informed of the information security status of the organisation by means of regular reports and presentations.
5.21. Policy Audit
This policy shall be subject to audit by the GDPR TFT.