Version 8.3 - Effective 26th April 2018
Information management is an essential part of good IT governance, which in turn is a cornerstone in corporate governance. An integral part of the IT governance is information security, in particular pertaining to personal information.
This document combines legal requirements and current best practice for an information security management policy. It provides information on security objectives and strategy and defines roles and responsibilities.
Core principles for information security management, as defined in ISO/IEC 27002, are for the following areas:
This document contains Cloud9 Software information security policy. It is based on ISO/IEC 27001 and ISO/IEC 27002, the Director of Cloud9 Software has signed the security policy.
In addition to the information security policy Cloud9 Software have developed several underlying documents detailing how the various aspects of the policy is implemented. These are referenced within in the present document.
The use of Cloud-based solutions is becoming more prevalent, predominantly due to the substantially lower cost of ownership and flexibility offered when compared with traditional "installed" software. However, there is a key concern for customers surrounding the security of their data: both the unauthorised access to data and the loss of any data.
At Cloud9 Software (C9S) we realise the importance of data security to our customers, so we have taken measures so that we and our partners have policies, procedures and systems in place to reduce the security risks relating to your data. We are committed to ensuring that your information is secure and prevent unauthorised access, disclosure or loss of your data. In this product data sheet, we describe the application level security, hosting partner policies and procedures and backup and recovery procedures we have put in place to safeguard and secure the information we hold on your behalf.
intelligentcontract.com is hosted by Amazon Web Services (AWS). AWS is a tier 1 web hosting service. intelligentcontract.com is hosted out of AWS' Dublin facility in Ireland. There are two physical locations (availability zones) which provide a level of redundancy within our architecture. The diagram below provides an overview of the intelligentcontract.com technical platform.
AWS Platform Architecture
We take the security of our application very seriously. We employ an external party on an annual basis to review our application security arrangements. The annual penetration test is completed in the first quarter of each year and the annual results can be provided upon request.
The intelligentcontract.com application has built-in security measures that provide peace of mind to our customers. The table below provides information on the key measures that have been implemented.
|Application is only available over HTTPS (additionally HSTS is enabled and cookies are flagged as HTTPS only).||Prevents attackers from accessing sensitive data by sniffing network traffic.|
|Application is hardened against XSS, clickjacking, CSRF and SQL injection attacks (verified by penetration testing).||Prevents attackers from executing harmful code on the server or tricking legitimate users' browsers into giving away login credentials or data.|
|Customer-configurable login session timeout.||Customers can optionally specify a time after which inactive login sessions should time out.|
|Customer-configurable password strength.||Customers can switch on a "strong passwords" setting which forces users to use complex passwords.|
|5 failed login attempts allowed in 5 minutes before Captcha image is presented. The account is locked if there have been 10 failures in the last 5 minutes.||Prevents non-authorised people (maybe who are using brute force attacks) from attempting to guess passwords.|
|Customer - configurable password options to expire users' password after specified length.||If a customer doesn't restrict access to an ex-employee's login,after the specified period access will automatically be revoked.|
|Forgotten password functionality requires users to confirm password reset via a link sent to their email account.||Prevents attackers from resetting users' passwords without their consent.|
|IP address and time/date of most recent login displayed to user on login.||Alerts users if their account has been logged in to from an IP ata time and date they don't recognise.|
|Read/write access to entities within the system (Contracts, documents etc.) can be locked down to specific users and groups of users.||Allows Customer to control who within their organisation can access which data.|
|User file uploads are restricted to specific file types.||Prevents users from uploading harmful files including as viruses.|
Our hosting partner has security measures in place that adhere to the data security standard ISO270001. A detailed copy of AWS' security white paper can be obtained on request. In addition to AWS hosted environment security measures, we have implemented further security measures designed to prevent.
|2-factor authentication required to access back-end C9S administration portal.||Prevents attacker who's acquired a password to the system from gaining access.|
|Access to live servers and database administration interface restricted to C9S office IP address.||Prevents anyone outside the C9S network from accessing the hosting infrastructure.|
|Firewall and load balancer in place.||Clients cannot connect directly to the live servers or database but must come through a load balancer. Only the ports that strictly need to be opened (HTTP/HTTPS) are accessible.|
|Staff with access to the C9S administration portal have signed Non-disclosure agreements, are back ground checked annually (Disclosure Scotland) and are made aware annually of the consequences of breaking the terms of the Non-disclosure agreement.||Because employees have access to data it is important that those staff are able to demonstrate they are trustworthy and also for them to be aware of the consequences of unauthorised disclosure. The NDA agreements apply after an employee has left the business.|
|It is our policy that customer data should not be downloaded to local computers or any type of portable media.||By having a policy that customer data only ever resides in the data centre we are able to minimise the risk of unauthorised access of customer data.|
|The C9S office is physically secured with a combination lock. No one is allowed into the office unless a background checked member of staff is present.||Removes the risk of opportunistic individuals accessing machines which may have access to the data centre.|
|We are able to demonstrate that we comply the UK data protection (acting as a processor).||To give our clients piece of mind that personal data is treated in line with the stipulations of the UK data protection act.|
Customer Meta data
SQL databases in AWS are backed up on an on-going basis with backups retained for 30 days. Point in-time recovery is available with these backups so we can restore to any point in time within the previous 30 days. Additionally, the databases are converted to text files once a day and these are backed up to a file storage area within our AWS account.
Customer Uploaded files
Files uploaded by Customers (for example, contract documents) are incrementally backed up on an hourly and daily basis to the file storage area within our AWS account. These incremental backups cover a period of 2 weeks so in the event of data being lost from our primary file storage, we can restore to the nearest hour at any point within that period.
On a weekly basis, the database dumps and file backups are archived to a weekly backup directory within the AWS file storage area, and these weekly backups are retained for two years. Finally, all data stored within the AWS file storage area (including historical backups) is incrementally backed up on a daily basis to a secure storage area within a separate storage (Google Cloud Storage) account. This is also retained for 2 years.
Note that the AWS file storage is located in Dublin, Ireland and the Google cloud storage is located in Belgium.
Customer data is primarily located our AWS facility in Dublin Ireland. We have reserved space in two physically separate locations – should there be an issue in one location, service will automatically switch over to the other.
We have a documented disaster recovery procedure which covers both the C9S office location and the AWS data centre. The plan is rehearsed on an Annual basis and alterations made if required.
Any changes, edits and updates made to the data Security Policy will be recorded in here. Whenever there is an update, Cloud9 Software requires that the version number be updated and the key reasons for change be recorded.
|Name of Person Making Change||Role of Person Making Change||Date of Change||Version Number||Notes|
|Judy Weeks||Contributor||2-Apr-2016||1.0||Initial version of DSR|
|Paul Darlow||Data Protection Officer / Director||23-Apr-2018||2.0||Updated to take into account the new legislation around GDPR|
Cloud9 Software is committed to safeguard the confidentiality, integrity, and availability of all physical and electronic information assets of the institution to ensure that regulatory, operational and contractual requirements are fulfilled. The overall goals for information security at Cloud9 Software are the following:
Cloud9 Software's current business strategy and framework for risk management are the guidelines for identifying, assessing, evaluating, and controlling information related risks through establishing and maintaining the information security policy (this document).
It has been decided that information security is to be ensured by the policy for information security and a set of underlying and supplemental documents. To secure operations at Cloud9 Software even after serious incidents, Cloud9 Software shall ensure the availability of continuity plans, backup procedures, defence against damaging code and malicious activities, system and information access control, incident management and reporting.
The term information security is related to the following basic concepts:
Confidentiality: The property that information is not made available or disclosed to unauthorised individuals, entities, or processes.
Integrity: The property of safeguarding the accuracy and completeness of assets.
Availability: The property of being accessible and usable upon demand by an authorised entity.
Some of the most critical aspects supporting Cloud9 Software's activities are availability and reliability for network, infrastructure, and services. Cloud9 Software practices openness and principles of public disclosure but will in certain situations prioritise confidentiality over availability and integrity.
Every user of Cloud9 Software's information systems and employees shall comply with this information security policy. Violation of this policy and of relevant security requirements will therefore constitute a breach of contract between the user and Cloud9 Software and may have consequences for employment or customer contractual relationships.
The Managing Director of Cloud has the overall responsibility for managing Cloud9 Software's values in an effective and satisfactory manner according to current laws, requirements, and contracts.
The Director has the overall responsibility for information security at Cloud9 Software, including information security regarding personnel and IT security.
2.1 Owner of the Security Policy The Managing Director is the owner of the security policy (this document). The Director delegates the responsibility for security-related documentation to the CSO (Chief Security Officer). All policy changes must be approved and signed by the CSO. Paul Darlow is the Managing Director.
2.2 Chief Security Officer (CSO) The Chief Security Officer (CSO) holds the primary responsibility for ensuring the information security at Cloud9 Software. Paul Darlow, Managing Director, has this role.
2.3 System Owner The system owner, in consultation with the IT department, is responsible for purchasing requirements, development and maintenance of information and related information systems. All systems and all types of information has a defined owner. The system owner defines which users or user groups are allowed access to the information and what authorised use of this information consists of.
Mike Edwards Technical Director is owner of the intelligentcontract.com system (This includes the front-end portal and the back end application)
2.4 System Administrator System administrators are persons administrating Cloud9 Software's information systems and the information entrusted to Cloud9 Software by other parties. Each type of information and system may have one or more dedicated system administrators. These are responsible for protecting the information, including implementing systems for access control to safeguard confidentiality, and carry out backup procedures to ensure that critical information is not lost. They will further implement, run, and maintain the security systems in accordance with the security policy. Each system must have one or more system administrators.
Mike Edwards Technical Director is the System Administrator for intelligentcontract.com
2.5 Internal Technical Staff Employees are responsible for getting acquainted and complying with Cloud9 Software's IT regulations. Questions regarding the administration of various types of information are posed to the system owner of the relevant information, or to the system administrator.
2.6 Consultants and Contractual Partners Contractual partners and contracted consultants must sign a confidentiality agreement prior to accessing sensitive information. The System owner is responsible for ensuring that this is implemented.
3.1.1 Cloud9 Software's approach to security will be based on risk assessments.
3.1.2 Cloud9 Software will continuously assess the risk and evaluate the need for protective measures. Measures will be evaluated based on Cloud9 Software's role and with regards to efficiency, cost, and practical feasibility.
3.1.3 An overall risk assessment of the information systems will be performed annually.
3.1.4 Risk assessments will identify, quantify, and prioritise the risks according to relevant criteria for acceptable risks.
3.1.5 Risk assessments will be carried out when implementing changes impacting information security. Recognised methods of assessing risks will be employed, such as ISO/IEC 27005.
3.1.6 The CSO is responsible for ensuring that the risk management processes at Cloud9 Software are coordinated in accordance with the policy.
3.1.7 The system owners are responsible for ensuring that risk assessments within their area of responsibility are implemented in accordance with the policy.
3.1.8 Risk management is to be carried out according to criteria approved by the management at Cloud9 Software.
3.1.9 Risk assessments will be approved by the management at Cloud9 Software and/or the system owners.
3.1.10 If a risk assessment reveals unacceptable risks, measures will be implemented to reduce the risk to an acceptable level.
3.2.1 The CSO will ensure that the information security policy, as well as guidelines and standards, are utilised and acted upon.
3.2.2 The CSO will ensure the availability of sufficient training and information material for all users, to enable the users to protect Cloud9 Software's data and information systems.
3.2.3 The security policy shall be reviewed and updated annually or when necessary, in accordance with principles described in ISO/IEC 27001.
3.2.4 All important changes to Cloud9 Software's activities, and other external changes related to the threat level, will result in a revision of the policy and the guidelines relevant to the information security.
Security responsibility is distributed as follows:
Cloud9 Software has established a forum for information security consisting of the system owner, the Human Resource manager and others if required. The security forum will advise the CSO about measures furthering the information security of the Organisation. The security forum has the following responsibilities, among others:
3.4.1 "Assets" include both information assets and physical assets.
3.4.2 Information and infrastructure will be classified according to security level and access control.
3.4.3 Information as mentioned in item 3.4.1 will be classified as one of three categories for confidentiality:
Information of a sensitive variety where unauthorised access (including internally) may lead to considerable damage for individuals, Customers or their interests. This type of information must be secured in "red" zones, see chapter 3.6.
Information which may harm Cloud9 Software or be inappropriate for a third party to gain knowledge of. The System owner decides who may access and how to implement that access.
Other information is open.
3.4.4 Cloud9 Software shall carry out risk analyses to classify information based on how critical it is for operations (criticality).
3.4.5 Routines for classification of information and risk analysis have been developed.
3.4.6 Employees administrating information on behalf of Cloud9 Software will treat said information according to classification.
3.4.7 Sensitive documents are all clearly marked.
3.4.8 Classification of equipment according to criticality will be discussed in chapter 3.6.
3.4.9 A plan for electronic storage of essential documentation should be developed.
3.4.10 Information that is vital for operations should be accessible independent of which systems the information was created or processed in.
3.5.1 Prior to employment
188.8.131.52 A background check (Disclouse Scotland, Basic) is carried out of all appointees to positions at Cloud9 Software according to relevant laws and regulations.
184.108.40.206 A confidentiality agreement is signed by employees, contractors or others who may gain access to sensitive and/or internal information.
220.127.116.11 IT regulations should be accepted for all employment contracts and for system access for third parties.
3.5.2 During employment
18.104.22.168 The IT regulations refer to Cloud9 Software's information security requirements and the employees' responsibility for complying with these regulations.
22.214.171.124 The IT regulations should be reviewed regularly with all employees and with all new hires.
126.96.36.199 All employees and third-party employees receive adequate training and updating regarding the Information security policy and procedures. The training requirements may vary.
188.8.131.52 Breaches of the Information security policy and accompanying guidelines will normally result in sanctions.
184.108.40.206 Cloud9 Software's information, information systems and other assets will only be utilised for their intended purpose. Necessary private usage is permitted.
220.127.116.11 Private IT equipment in Cloud9 Software's infrastructure may only be connected where explicitly permitted. All other use must be approved in advance by the IT department.
18.104.22.168 Use of Cloud9 Software's IT infrastructure for personal commercial activities is under no circumstances permitted.
22.214.171.124 Employee background checks are completed annually (January of each year)
3.5.3 Termination or change of employment
126.96.36.199 The responsibility for termination or change of employment is defined as a separate process.
188.8.131.52 Cloud9 Software's assets should be handed in at the end of the need for the use of these assets.
184.108.40.206 Cloud9 Software should change or terminate access rights at termination or change of employment.
220.127.116.11 Notification on employment termination or change should be carried out through the procedures defined in the human resource system.
3.6.1 Security areas
18.104.22.168 IT equipment and information that require protection will be placed in secure physical areas. Secure areas have suitable access control to ensure that only authorised personnel have access. The following zones s be utilised:
|Green||No access restrictions.||No access control during ordinary office hours. Internal and sensitive information should not be printed out in this zone.|
|Yellow||Areas where internal information may be found during office hours. Offices, meeting rooms, some archives, some technical rooms like labs, printer rooms.||All printouts should be protected with "Follow me" function. Access control: Key card.|
|Red||Restricted areas requiring special authorisation. Computer rooms, server rooms, archives, etc. containing sensitive information.||All printouts should be protected with "Follow me" function. Access control: Key card.|
22.214.171.124 Outside our data centre we have a single office (the technical room) which is currently a restricted area. This is a physically combination lock on the door. Our policy is that only Cloud9 Software staff have access to the combination. Visitors must be accompanied by a member of staff.
126.96.36.199 The IT security manager is responsible for approving physical access to technical room.
188.8.131.52 The Physical security manager is responsible for the approval of physical access to areas other than technical room.
184.108.40.206 All of Cloud9 Software's buildings are secured according their classification by using adequate security systems.
220.127.116.11 Red zones are properly secured against damage caused by fire and water.
18.104.22.168 All external doors and windows must be closed and locked at the end of the work day.
22.214.171.124 Access cards may be supplied to workers, technicians, and others after proper identification.
126.96.36.199 Anyone receiving visitors in the yellow zone is responsible for the supervision of their visitors.
188.8.131.52 Visitors in the red zone must be signed in and out and must carry visible guest cards or personal access cards.
184.108.40.206 Visitors in the red zone are escorted.
3.6.2 Securing equipment
220.127.116.11 IT equipment classified as "high" is protected against environmental threats (fires, flooding). Classification of equipment should be based on risk assessments.
18.104.22.168 Information classified as "sensitive" must not be stored on portable computer equipment (e.g. laptops, cell phones, memory sticks, etc.). If it is necessary to store this information on portable equipment, the information must be password protected and encrypted in compliance with guidelines from the IT department.
22.214.171.124 During travel, portable computer equipment should be treated as carry-on luggage.
126.96.36.199 Areas classified as "red" must be secured with suitable fire extinguishing equipment with appropriate alarms.
188.8.131.52 Fire drills are carried out on a regular basis.
3.7.1 Operational procedures and areas of responsibility
184.108.40.206 Any purchase and installation of IT equipment must be approved by the System Owner.
220.127.116.11 Purchase and installation of software for IT equipment must be approved by the System Owner.
18.104.22.168 The System Owner should ensure documentation of the IT systems according to Cloud9 Software's standards.
22.214.171.124 Changes in System should only be implemented if well-founded from a business and security standpoint.
126.96.36.199 The System Owner should have emergency procedures to minimise the effect of unsuccessful changes to the IT systems.
188.8.131.52 Operational procedures should be documented. Documentation must be updated following all substantial changes.
184.108.40.206 Before a new IT system is put in production, plans and risk assessments are in place to avoid errors. Additionally, routines for monitoring and managing unforeseen problems are in place.
220.127.116.11 Duties and responsibilities should be separated in a manner reducing the possibility of unauthorised or unforeseen abuse of Cloud9 Software's assets.
18.104.22.168 Development, testing and maintenance should be separated from operations to reduce the risk of unauthorised access or changes, and to reduce the risk of error conditions.
3.7.2 Third party services
22.214.171.124 All contracts regarding outsourced IT systems (i.e. Our sub-processors) are GDPR compliant. They are checked annually to be sure they continue to meet the obligations of GDPR.
3.7.3 System planning and acceptance
126.96.36.199 Requirements for information security are taken into consideration when designing, testing, implementing, and upgrading IT systems, as well as during system changes. Processes have been developed for change management and system development/maintenance.
188.8.131.52 IT systems are dimensioned according to capacity requirements. The load is monitored to apply upgrades and adjustments in a timely manner.
3.7.4 Protection against malicious code
184.108.40.206 Computer equipment must be safeguarded against virus and other malicious code. This is the responsibility of the System Administrator.
220.127.116.11 The System Administrator is responsible for carrying out regular backups and restore of these backups, as well as data storage on Cloud9 Software's IT systems according to their classification.
18.104.22.168 Backups are stored externally in a separate, protected zone.
3.7.6 Network administration
22.214.171.124 The System Administator has the overall responsibility for protecting Cloud9 Software's internal network.
126.96.36.199 All access to Cloud9 Software's networks is logged.
3.7.7 Management of storage media
188.8.131.52 There are procedures in place for the management of removable storage media. Implementation is the responsibility of each employee.
184.108.40.206 Storage media should be disposed of securely and safely when no longer required, using formal procedures.
3.7.8 Exchange of information
220.127.116.11 Procedures and controls have been established for protecting exchange of information with third parties and information transfer. Third party suppliers must comply with these procedures.
18.104.22.168 Cloud9 Software has the right to access personal e-mail and other personal data stored on Cloud9 Software's computer networks in line with relevant national legal requirements.
3.7.9 Use of encryption
22.214.171.124 Storage and transfer of sensitive information is encrypted or otherwise protected.
3.7.10 Electronic exchange of information
126.96.36.199 Information exchanged across public networks in connection with e-commerce, is protected against fraud, contractual discrepancies, unauthorised access, and changes.
188.8.131.52 The system owner ensures that publicly accessible information, e.g. on Cloud9 Software's web services, is adequately protected against unauthorised access. Each year a 3rd party completes a formal penetration test. Those tests attempt to gain unauthorised access to our systems. The results are presented back to Cloud9 Software and any threats are mitigated.
3.7.11 Monitoring of system access and usage
184.108.40.206 Access and use of IT systems should be logged and monitored to detect unauthorised information processing activities.
220.127.116.11 Usage and decisions should be traceable to a specific entity, e.g. a person or a specific system.
18.104.22.168 The IT department should register substantial disruptions and irregularities of system operations, along with potential causes of the errors.
22.214.171.124 Capacity, uptime and quality of the IT systems and networks should be sufficiently monitored to ensure reliable operation and availability.
126.96.36.199 The IT department should log security incidents for all essential systems.
188.8.131.52 The IT department should ensure that system clocks are synchronized to the correct time.
184.108.40.206 [Usage of information systems containing personal information may be regulated. Check your local legislation...]
3.8.1 Business requirements
220.127.116.11 Written guidelines for access control and passwords based on business and security requirements should be in place. Guidelines should be re-evaluated on a regular basis.
18.104.22.168 Guidelines should contain password requirements (frequency of change, minimum length, character types which may/must be utilised, etc.) and regulate password storage.
3.8.2 User administration and responsibility
22.214.171.124 Employees accessing systems must be authenticated according to guidelines.
126.96.36.199 Employees should have unique combinations of usernames and passwords.
188.8.131.52 Employees are responsible for any usage of their usernames and passwords. Employees should keep their passwords confidential and not disclose them unless explicitly authorised by the CSO.
3.8.3 Access control/Authorization
184.108.40.206 Access to information systems should be authorised by immediate superiors in accordance with the system owner directives. This includes access rights, including accompanying privileges. Authorisations should only be granted on a "need to know" basis and regulated according to role.
220.127.116.11 The immediate superior should alert the system administrator about granting access and changes in accordance with the directives from the system owner.
18.104.22.168 Roles and responsibilities with accompanying access rights should be described based on the following classifications.
3.8.4 Network access control
22.214.171.124 The IT department is responsible for ensuring that network access is granted in accordance with access policy.
126.96.36.199 Employees should only have access to the services they are authorised for.
188.8.131.52 The access to privileged accounts and sensitive areas should be restricted.
184.108.40.206 Employees should be prevented from accessing unauthorised information.
3.8.5 Mobile equipment and remote workplaces
220.127.116.11 Remote access to Cloud9 Software's computer equipment and services is only permitted if the security policy has been read and understood and the IT regulations signed.
18.104.22.168 Remote access to Cloud9 Software's network may only take place through security solutions approved by the IT department.
22.214.171.124 Mobile units should be protected using adequate security measures.
126.96.36.199 Information classified as sensitive must be encrypted if stored on portable media, such as memory sticks, PDAs, DVDs and cell phones. [The use of cryptography may be subject to local legislation.]
3.9.1Security requirements for information systems
188.8.131.52 Definitions of operational requirements for new systems or enhancements to existing systems always contain security requirements.
3.9.2 Cryptographic controls
184.108.40.206 Guidelines for administration and use of encryption for protecting information is in place.
3.9.3 Security of system files
220.127.116.11 All changes to production environments comply with existing processes.
18.104.22.168 The implementation of changes to the production environment is controlled by formal procedures for change management, to minimise the risk of damaged information or information systems.
3.9.4 Security in development and maintenance
22.214.171.124 Systems developed for or by Cloud9 Software satisfy definite security requirements, including data verification, securing the code before being put in production, and use of encryption.
126.96.36.199 All software is thoroughly tested and formally accepted by the system owner before being transferred to the production environment.
3.9.5 Risk assessment
188.8.131.52 Prior to new systems classified as "high", or substantial changes in systems classified as "high" are put in production, a risk assessment is carried out.
3.10.1 Responsibility for reporting
184.108.40.206 All breaches of security, along with the use of information systems contrary to routines, are treated as incidents.
220.127.116.11 All employees are responsible for reporting breaches and possible breaches of security. Incidents should be reported to management or directly to the CSO.
18.104.22.168 Process have been developed for incident management and reporting. The routines contain measures for preventing repetition as well as measures for minimising the damage.
22.214.171.124 The CSO should ensure that process are in place for defining the cost of security incidents.
3.10.3 Collection of evidence
126.96.36.199 The system administrator is familiar with simple routines for collecting evidence.
3.11.1 Continuity plan
188.8.131.52 A plan for continuity and contingencies covering critical and essential information systems and infrastructure has been developed.
184.108.40.206 The continuity plan is consistent with Cloud9 Software's overall contingencies and plans.
220.127.116.11 The continuity plan is tested on a regular basis (annually) to ensure adequacy, and to ensure that management and employees understand the implementation.
18.104.22.168 Production systems and other systems classified as "high" have backup solutions.
3.12.1 Compliance with legal requirements
22.214.171.124 Cloud9 Software must comply with current laws, as well as other external guidelines, such as (but not limited to):
3.12.2 Safeguarding personal information according to the legal requirements
126.96.36.199 As a data processor we are GDPR Compliant.
With the introduction of new European Union (EU) legislation regarding the collection, storage and processing of personal data, Cloud9 Software (C9S) has been working to ensure that the intelligentcontract.com service is compliant in advance of its introduction. The General Data Protection Regulation (GDPR) is due for introduction across the EU in May 2018 and places additional obligations on Data Processors of personal data. At Cloud9 Software we take these obligations very seriously. We have produced this short summary paper to outline how we will fulfil our GDPR (as Data Processor) Obligations. Below are the key GDPR obligations for data processors and how C9S fulfils each.
Establish a representative in the EU, if the organisation is not located within the EU (in accordance with Article 27). Because Cloud9 Software Limited is based in Liverpool, United Kingdom, we are not required to nominate a Representative. Our registered address is: Suite 9, 1 Derby Square, Liverpool, L2 9QR.
Only Act on the written instructions of the controller (Article 29). We commit to only complete any data related actions with the written instructions from the nominated key user for each customer account. This instruction will be accepted either electronically (email, helpdesk ticket response) or in written form. If the key user is no longer available at the customer organisation, we provide an offline process for the nomination of a new key user. Please contact support for more information about this process.
Nominate a data protection officer if required in accordance with Article 37. Cloud9 Software Limited have nominated Paul Darlow (Director) as our Data Protection Officer. He can be contacted by email (firstname.lastname@example.org), by Phone (+44 (0) 151 928 8811) or by writing to: Suite 9, 1 Derby Square, Liverpool, L2 9QR
Restrict the appointment of sub-data processors (Article 28.2). We maintain a list of Sub-data processors that support the intelligentcontract.com service. As part of the terms of service, the data processing agreement details the current list of sub-processes. The current list of data sub-processors can be found here: https://www.intelligentcontract.com/en-gb/sub-processors/ If C9S add a new data sub-processor we will notify the key user and the nominated data protection officer (which may be the same person) of each account by email of the details (country of operation, purpose and name of service/organisation) of the new data sub-processor. Each customer has the right to not accept any new data processor and they will be able to terminate their use of the service.
Keep a Record of Processing activities in accordance with Article 30.2. Cloud9 Software are obligated to keep records relating to the processing of data as part of the intelligentcontract.com service. Specifically, we maintain:
Co-operate with the supervisory Authorities (such as the ICO) in accordance with Article 31. We are committed to fulfilling our data processing obligations under the GDPR rules. As such we commit to cooperate and comply with all instructions issued by a GDPR supervisory authority.
Implement Adequate Data Security in accordance with Article 32. In addition to security processes (both physical and electronic) offered by our hosting partner (Amazon Web Services), Cloud9 Software has active Data Security Policies and Procedures. This includes our Business Continuity Plan. On an annual basis, all key staff are required to undertake Data Security training. As part of this annual session we also take the Opportunity to review the policies and procedures and update them if required. A summary of the current security policies and procedures can be found here: https://support.intelligentcontract.com/solution/articles/22000180240-data-security
Notify personal data Breaches to the Data Controller. For each of our customers we maintain the name of the Key user. In addition, we ask our customers to nominate a data protection officer. This may be the same person. In the event that we become aware of a data breach, we will inform both the nominated key user and data protection officer for each customer. We will communicate by email detailing the nature of the data breach and, if we are aware, detail the scope of the breach. We will communicate as soon as practically possible. It is the responsibility of our customers to update C9S if the key user or the data protection officer details we hold (including incorrect email addresses) change.
3.12.3 Compliance with security policy
188.8.131.52 All employees must comply with the Information security policy and guidelines. Enforcement is the responsibility of system owner.
184.108.40.206 Employees are aware that evidence from security incidents will be stored and may be handed over to law enforcement agencies following court orders.
3.12.4 Controls and audits
220.127.116.11 Audits are planned and arranged with the involved parties to minimise the risk of disturbing the activities of Cloud9 Software.
|1.0||Employee Confidentiality agreement||Paul Darlow|
|1.0||GDPR Compliance (as a Processor) Overview||Paul Darlow|
|2.0||Business Continuity Plan||Judy Weeks|
|[ISO27001]||ISO 27001: 2005. Information security – Security techniques – Information security management systems – Requirements. [ISO27002] ISO/IEC 27002: 2005 Information security – Security techniques – Code of practice for information security management.|
|[ISO27005]||ISO/IEC 27005: 2008 Information security – Security techniques – Information security risk management.|
|[OECD]||OECD Guidelines for the Security of Information Systems and Networks: Towards a Culture of Security. http://www.oecd.org/dataoecd/16/5/15584616.pdf|
|[BPD107]||Power Supply Requirements for ICT Rooms. Best Practice Document. http://www.terena.org/activities/campus-bp/pdf/gn3-na3-t4-ufs107.pdf|
|[BPD108]||Ventilation and Cooling Requirements for ICT Rooms. Best Practice Document. http://www.terena.org/activities/campus-bp/pdf/gn3-na3-t4-ufs108.pdf|