- Partnerships @ Work


INFORMATION SECURITY POLICY


“Security is not a product, but a Process”


Document Control


Document Description:

The objective of this document is to elaborate the

information security polices at Information Dynamics.

Document Identification:


Security Classification:


Internal

Location:



Authorization


Name of the person

Date (dd-mmm-yyyy)

Prepared by:

Sankar

09-Jan-2020

Reviewed by:

Soundar

25-Jan 2020

Approved by:

Arun Dani

26-feb 2020


Change

Document Version

Date of Change

Section

A/M/D

Brief description of change

Reviewed

by

1.0

27 Feb 2019


A

Initial Release

Soundar

1.1

26 Feb 2020


A

Updated Security policy to map with the ISO 27001:2013 standards

Soundar

1.2

01 Feb 2021


A

Updated the communication plan

as per the stage 1 audit recommendations

Soundar

1.3

01 Feb 2022


A

Annual Review

Soundar

1.4

01 Feb 2023


A

Annual Review

Soundar


Confidentiality Agreement

This document is copyrighted and all rights are reserved. This document may not, in whole or in part, be copied, photocopied, reproduced, translated, or reduced to any electronic medium or machine-readable form without prior consent, in writing, from an authorized representative of Information Dynamics. This document is for internal use only and may, in whole or in part, be provided to anyone outside of Company, including customer, clients, or prospects after taking an approval from an authorized representative of Information Dynamics.


Table of Contents

  1. Objective(s) 4

  2. Processes 5

  3. Context of the Organization: 6

  4. Leadership: 6

  5. Planning 8

  6. Support 9

  7. Operation 10

  8. Performance Evaluation 10

  9. Improvement 10

  10. Information Security Policies 12

  11. Organization of Information Security 12

  12. Human Resource Security 13

  13. Asset Management 13

  14. Access Control Policy 17

  15. Cryptography 20

  16. Physical and Environmental Security 20

  17. Operations Security 23

  18. Communication Security 27

  19. Supplier Relationships 30

  20. Information security Incident Management 30

  21. Developing and implementing information security aspects in continuity plans 30

  22. Compliance 30

  23. Violation of Policy 31

  24. Policy Exceptions / Waivers 32

  1. Purpose


    The purpose of this Information Security policy is to address the requirements of the Information Security processes of Information Dynamics (ID). This Information Security policy system provides documented policies, procedures and methodologies to achieve processes required to meet the requirements of the international security standards. The purpose of Information Security policy is to identify basic rules & procedures that all ID employees must adhere to, while accessing and handling information assets. These rules must be enforced in order to ensure the confidentiality, integrity and availability of these assets. Furthermore, it puts into writing ID security posture, describes & assigns functions and responsibilities, grants authority to security professionals, and identifies the incident response processes and procedures.


  2. Objective(s)


    Plan

    Act

    Do

    Check

    The objective of the Information Dynamics (ID), Information Security program is to foster direct compliance with company policies, ethical standards, employee honesty and overall business operations. Information security policies define a concise set of behaviors that provide a secure environment within which each Information Dynamics employee may use and manage information resources. Information is a primary asset and as such must be protected in a manner commensurate to its value. It is the policy of Information Dynamics that information must be protected in any format or media whether printed, electronic, verbal, or otherwise from unauthorized or inappropriate access, use, modification, disclosure, or destruction. This applies to all information that exists in Information Dynamics applications, systems, and networks that Information Dynamics owns or operates (processing environments). The program uses the PDCA - Plan Do Check Act cycle for implementation, maintenance and continually improving the system.



    At a high level, the implementation of the information security program focusses on achieving the following objectives:



  3. Processes:

    Key Processes Included under scope for IT-Infrastructure & support:


  4. Context of the Organization:


    The context of the organization plays a vital role in information security program. This determines the factors that affect information security implementation in the organization and also identifies risks that might affect the environment.

    Ref: ISMS Scope document


  5. Leadership:


    The Senior management of Information Dynamics have treated information security as a priority and a critical factor to assist in building a secure environment and also to customer needs.

    To ensure this is followed, the management has allocated resourced and identified key roles to manage the security program.

    Ref: Information Security Roles and Responsibilities document


    ISMS Policy Statement:


    It is the policy of the ID management to establish, implement and maintain an Information Security Management System by:



    1. Data Confidentiality, Privacy & Protection Policy Statement


      It is the responsibility of the management to provide Data Confidentiality, Privacy and Protection in regard to personal sensitive information, company information and client information, which are under our custody. This is achieved through all employees of Information Dynamics following the policy requirements as stated in this document.


      Confidentiality of all kinds of data shall be maintained by all employees at all levels by transacting the data only on a need to know and use basis. There shall be a formal Non- Disclosure or confidentially agreements signed during joining process and the same made understood to the prospective employee before employment. In this context, the data is classified and according to the classification in terms of access control and disposition of the same.

      Privacy of all kinds of data shall be maintained by all employees at all levels by knowing to whom, when, where and how the data has to be communicated with respect to personal,company and client information. In this regard, ID shall train and educate people to handle such data or information periodically.


      Protection of data in ID is based on the classification of the data and related treatment and handling of the same. The data shall be segregated according to the classification and divulged to personnel only on need to know and use basis. Methods such as authorized folder

      / access management, password protected files, secure encrypted storage and transmissions, disposals, re-use, etc. shall be enforced and followed by all the employees.


      Organizational roles, responsibilities and authorities

      Roles and responsibilities have been allocated to dedicated personnel/Team to manage the information security program.

      Ref: Information Security Roles and Responsibilities Document.


  6. Planning


    Action to address Risks and Opportunities.

    Information dynamics has identified risks and continually identifies new risks that affect the information. The same is evaluated, analyzed and accordingly appropriate security controls are applied to mitigate the risks.

    Ref:

    Risk Assessment Methodology

    Risk Assessment and Treatment Sheet


  7. Support


    Resources and Competence

    Resources have been allocated by the management to manage and maintain information security controls in the organization. These roles are split across the department and vary based on the domains being managed by the individuals.

    Teams shall be appropriately trained to manage technical and compliance management of information security.


    Awareness

    All employees in the environment shall be provided awareness on information security best practices and how to secure information. This shall be through the following channels, but not limited to:


  8. Operation

    Controls shall be implemented to manage new updates and changes to the current environment. Ref:


  9. Performance Evaluation


    The security controls been implemented are monitored regularly and measured for effectiveness. This shall give the management the effectiveness and the strength of the controls. Based on the results of these checks, management can decide which controls lacks in effectiveness and appropriate action to be taken.


    Ref: The evaluation KPIs are updated in every procedure document.


    Internal Audit

    Internal audits on the implemented security controls shall be done at least once a year.

    Ref: Process Manual for Internal Audit


    Management Review:


    The management reviews the information security program on a regular basis (Once in Six months). This helps management understand where the security program needs attention and continually improve the process. The agenda and frequency has been defined. (Frequency :- Once in Six Months)

    Ref: Information security roles and responsibilities document.


  10. Improvement


    ID is dedicated to continually improve the process of security and service management practices. The audits conducted shall provide areas to be improved. Corrective actions shall be documented for the Non conformities. The findings shall have root cause identified and owner who shall be responsible to close the finding.



  11. Information Security Policies:



  12. Organization of Information Security


    Information Security roles and responsibilities have been defined and shared. To avoid conflict of interest, duties are segregated in various domains. In terms of auditing, an independent body shall conduct this exercise.


    Contact with Authorities



    Information Security in Project Management


    For all projects managed in ID, risks are factored and appropriate planning is done.

    Ref: Guidelines for Project Risk Management


    Mobile device and communications



  13. Human Resource Security


    Any employee joining ID has to go through a formal screening process. Apart from this there are security controls followed by HR during the employee’s tenure in the firm.

    Ref: Human Resource Security Policy


  14. Asset Management


    ID shall maintain a list of information assets which shall be maintained for the department. The information asset shall have following information tagged to the same. All information Assets shall have:


    Acceptable Use of Assets


    ID is the owner of all information assets managed and maintained. All these assets have to be used only for business purpose only. This has been documented.

    Ref: Acceptable use of assets Policy

    Return of Assets


    All assets need to be returned to the respective department during employee leaving the firm.

    Ref: Human Resource Security Policy


    Information Classification:


    Information owned, used, created or maintained by the Information Dynamics Companies is classified into the following three categories:



    Reference: Asset Management Procedure


    Physical Media in Transit


    Media containing information shall be protected against unauthorized access, misuse or corruption during transportation beyond physical boundaries.


  15. Access Control Policy


    Logical access controls shall be deployed with the principle of ‘deny all unless explicitly permitted’ to protect information from unauthorized access.

    Customers, third party vendors/ service providers shall be provided appropriate access to our information assets on the basis of contractual agreement/business need.


    User Access Management User Registration

    User registration and de-registration procedure, which shall be integral to the HR joining and exit processes, for providing and revoking end users access.

    Privilege Management



    Use of Privileged utility programs


    Access to the operating system commands and system utilities shall be restricted to authorized personnel for system administration and management functions.


  16. Cryptography


    Encryption is used to safeguard confidential information.

    Ref: Key Management & Card Data Encryption Policy


  17. Physical and Environmental Security


    Ref: Physical and Environmental Security Policy

    Unattended User Equipment


    All users shall be made aware of the security requirements and procedures for protecting unattended equipment, as well as their responsibilities for implementing such protection which shall include but not be limited to:

    terminate active sessions when finished;

    log-off desktops, Laptops and servers when the session is finished;


    Clear Desk and Clear Screen Policy


    Sensitive or critical business information on paper or on electronic storage media shall be locked when not required

    Computers and terminals shall be left logged off or locked when unattended.

    System shall be locked after 30 minutes of idle time.


    Data retention retrieval and secure disposal


    The entire Information Dynamics records, either physical or digital, are subject to the retention requirements based on business, legal and regulatory requirements. The Information Dynamics requires that all removable storage media (CDs, tapes, memory sticks, hard drives, etc) are clean (which means: it is not possible to read or re-constitute the information that was stored on the device or document) prior to disposal. Specifically:



  18. Operations Security Change Management Policy

    All scheduled change requests must be submitted in accordance with change management procedures so to review the request, determine and review potential failures, and make the decision to allow or delay the request.

    The department head may deny a scheduled or unscheduled change for reasons including, but not limited to, inadequate planning, inadequate blackout plans, the timing of the change will negatively impact a key business process such as yearend accounting, or if adequate resources cannot be readily available

    Customer notification must be completed for each scheduled or unscheduled change following the steps contained in the Change Management Procedure.

    A Change Review must be completed for each change, whether scheduled or unscheduled, and whether successful or not.

    A Change Management Log must be maintained for all the above mentioned changes.


    The log must contain, but is not limited to:

    1. Date of submission and date of change

    2. Owner and custodian contact information

    3. Nature of the change

    4. Indication of success or failure


    Ref: Change Management Procedure


    Capacity Management

    Ref: Capacity Management Policy (Under IT_SMS Policies)


    Protection from Malware

    Control against Malicious Code and Mobile Code

    Detective, preventive, recovery controls, shall be implemented and users shall be made aware

    of protecting information processing facilities against malicious and mobile code. At a minimum, the following shall be observed:

    Prohibiting the use of unauthorized software;

    Installing and regularly updating malicious and mobile code detection and repair software to scan computer and media;

    Regular backup of critical data & software; and

    Implementing controls to block suspicious external sites & filtering electronic mails.



    The anti-virus program would be capable of generating audit logs. The logs should be retained for at least 15days


    Information Backup


    Back-ups shall be taken and tested regularly to ensure that all essential information and

    software can be recovered following a disaster or media failure. The following shall be considered for information backup:



    Ref: Backup Policy


    Audit Logging

    Audit logs recording user activities on critical assets, exceptions, and information security events shall be produced and kept for an agreed period to assist in future investigations. Audit logs shall include but not be limited to:

    User Ids;

    Dates, times and details of key event; Terminal Identity;

    Records of successful and rejected systems access attempt;


    Monitoring System Use


    Procedures for monitoring use of information processing facilities shall be established and the results of the monitoring activities shall be reviewed regularly.


    Areas that shall be considered include but are not limited to: System log exceptions;

    Network management alarms;

    Use of privileged accounts, e.g. root, administrator;

    Access policy violation and notification for network gateways and firewalls;


    Protection of Log Information


    Logging facilities and log information shall be protected against tampering and unauthorized access.

    Controls shall be implemented to protect:

    Alterations to the message types that are recorded; Log files being edited or deleted; and

    Storage capacity of log files media.


    Administrator and Operator Log


    System administrator and system operator activities shall be logged and include following:

    The time at which an event (success or failure) occurred; Information about the event or failure;


    Fault Logging


    Faults reported by users or by system program related to information processing or communications systems shall be logged.

    Review of fault logs shall be conducted to ensure satisfactory resolution and to ensure that the controls have not been compromised.


    Clock Synchronization


    The clocks of all relevant information processing systems within the group companies or security domain shall be synchronized with an agreed accurate time source.


    Patch Management and malicious code prevention Policy



    New vulnerabilities must be identified with updates from external industry sources, known security forums etc. and the vulnerability should be assigned a Risk Ranking. Risk rankings should be based on industry best practices, like adhering to the CVSS scoring system for the risks.


    Installation of software on operational systems


    Employees shall not have access to install any software on their systems. All software installation requests shall be routed through a request. Software shall be installed only after line manager approval.


    Information Systems Audit Considerations


    Systems shall be audited on a regular basis. This shall be compliance auditing and technical auditing. Based on the audit results, corrective action shall be taken and areas shall be fixed. Ref: Process Manual for Internal Audit

  19. Communication Security Network Security Management

    Network Controls shall be implemented to ensure the security of information in networks, and the protection of connected services from unauthorized access. At a minimum, the following shall be implemented:



    Ref: Email Security Policy

    System Acquisition, development and maintenance


  20. Supplier Relationships


    Ref: Supplier Management policy


    Business Information System


    Policies and procedures shall be documented and implemented to protect information associated with the interconnection of business information systems.


  21. Information security Incident Management


    Ref: Incident Management Policy


  22. Developing and implementing information security aspects in continuity plans.


    Plans shall be developed and implemented to maintain or restore operations and ensure availability of information at the required level and in the required time scales following interruption to, or failure of, critical business processes.

    Refer: Business Continuity and Disaster Recovery Policy


  23. Compliance


    Application laws and legislations


    A list of laws have been documented which are applicable for geographical areas that are in scope.

    Ref: ISMS Scope document


    Intellectual Property Rights

    Protection of Personally identifiable information


    Ref: Compliance Policy


    Information Security Reviews

    Information Security Reviews are done on a regular basis.


    Technical Reviews: VA and PT exercises are done to understand the security posture of the firm.

    These exercises are conducted at least once in 12 months.

    Compliance Reviews: Compliance reviews are done to verify compliance level w.r.t ISMS documentation and implementation. This is done atleast once a year


  24. Violation of Policy


    Not reporting a known security incident – Employee who is witness to a non- compliance instance to this policy and does not report this to the appropriate authority, ITteam.

    Allowing/Leaving any information exposing to irrelevant person or third party person or organization in the form of soft/hard copy e.g.; paper documents near a work station or printer, or viewable soft data on an individual’s computer screen.

    Copying of classified Information Dynamics Information to the Internet or removable media – Transferring data from the Information Dynamics environment to any Internet sites or removable media e.g.: official data transfer or source code being captured to third-party removable devices.

    Installation of software without defined authorization – Installing any software on individual terminals without the approval of the IT Infrastructure team.

    Password sharing (LDAP) - The unique individual LDAP password belonging to an employee that is shared with any other IT person or employee or individual.

    Allowing a laptop or other devices to the network without authorization – Entering the Information Dynamics network via a personal laptop, Mobile and PDA Devices or other third-party device without prior approval/authorization.

    Leaking of confidential information– Any document which is defined as confidential information, leaking or transfer of any such document via any means i.e., chat mode, over a phone call, by SMS or MMS, ftp transferred, photographs, or word of mouth disclosure inpublic.

    Copy/transmit client-related data to the Internet or removable media device – Intentional act of transferring confidential or sensitive customer data to any external body or removable device such as a CD, pen drive and/or any other source.

    Hacking external or internal systems by using Information Dynamics facilities – Hacking of external systems, transferring data inward through an improper mode, and clear violation of any Intellectual property right (IPR) using Information Dynamics resources. Intentional act of hacking data, systems, and internal or external devices covered by confidentiality and proprietary act. Surfing unethical sites such as hackers.com.

    Sharing a customer’s confidential information to unauthorized people – Any Information asset which is defined as confidential customer information, leaking or transfer of any

    such document via any means i.e., chat mode, over a phone call, ftp transferred, photographs, or word of mouth disclosure in public.

    Accessing customer or Partners IT infrastructure from Information Dynamics or from outside without approval or NDA from customer and Information Dynamics Management


    Consequence Management


    A breach of this policy could have severe consequences to Information Dynamics and its ability to provide services, or maintain the integrity, confidentiality, or availability of services.

    The employee and any other parties involved will be & (or) subject to face legal proceedings through the cyber crime department or local police authorities.


  25. Policy Exceptions / Waivers


If, for any reason, the terms of this policy and those listed in the Policy Manual and other supporting security policies cannot be complied with, a documented waiver must be granted from the designate and the person designated as head of the particular business unit. Waivers of varying duration can be granted when acceptable compensating or alternative controls are in place. A manager (or their designee) seeking an exception must assess the risks that non-compliance causes Companies IT Resources and business processes. If the manger believes the risk is reasonable, then the manager prepares a written request describing the risk analysis and request for an exception.