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Date of approval: 30/03/2022
Text approved on this date by Management.
This Information Security Policy is effective from that date onwards until a new Policy supersedes it.
This document sets out the Information Security Policy of Ivnosys Soluciones S.L. and Signaturit Solutions S.L. (The latter adopts this Information Security Policy as its own), both referred to jointly hereinafter as “Signaturit”, as a set of basic principles and courses of action to which the organisation is committed, within the framework of standard ISO 27001 and the Spanish National Security Framework
The organisation depends on ICT (Information and Communication Technology) systems to achieve its aims. These systems must be managed with diligence, the appropriate measures being taken to protect them against accidental or deliberate damage which may affect the availability, integrity or confidentiality of the information processed or the services provided.
Information is a critical, essential asset of great value for carrying out the company’s activity. This asset must be adequately protected, regardless of the formats, media, means of transmission, systems, or persons being aware of the same, processing or handling it.
The aim of information security is to guarantee the quality of information and the continuous provision of services by acting preventively, overseeing daily activity, and reacting promptly to any incidents, in order to ensure the information’s quality and the continuity of the business, minimise risk and maximise returns on investments and business opportunities.
ICT systems must be protected against rapidly evolving threats with the potential to impact the confidentiality, integrity, availability, intended use and value of information and services. To defend against these threats, and ensure the continuous delivery of services, a strategy that adapts to changes in environmental conditions is required. This implies that departments must apply the minimum security measures required by the Spanish National Security Framework (ENS) and ISO/IEC 27001 standard for Information Security Systems, as well as continuously follow up service delivery levels, monitor, and analyse any vulnerabilities reported and prepare an effective response to incidents to ensure continuity of the services provided.
Different departments must ensure that ICT security is an integral part of every stage of the system’s life cycle, from conception to decommissioning, development or procurement decisions and operational activities. Security requirements and funding needs should be identified and included in planning, when requesting bids from suppliers, and in technical reports for ICT projects. In accordance with Article 7 of ENS and the Business Continuity system of ISO 22301, departments must be prepared to prevent, detect, react to, and recover from any incidents.
Article 7. Prevention, reaction and recovery.
Likewise, the system will keep services available throughout the life cycle of the digital information, using concepts and procedures that act as the foundation for the preservation of digital assets.
The company’s management, aware of the value of information, is deeply committed to the policy described in this document.
Departments should avoid, or at least prevent insofar as is possible, information or services from being harmed by security incidents. To do this, departments must implement the minimum security measures determined by the ENS, as well as any additional controls identified through a threat and risk assessment. Furthermore, and with the clear intention of improving such prevention, departments must also implement all the necessary requirements to comply with ISO 27001. These controls, and the safety roles and responsibilities of all personnel, must be clearly defined and documented.
To ensure compliance with the policy, departments must:
Since services can degrade rapidly due to incidents, ranging from simple slowdowns to stoppages, any services should monitor their operation on an ongoing basis to detect any anomalies in service delivery levels and act accordingly as provided for in Article 9. Periodic re-assessment, of the ENS, which sets out the following: “Security measures will be reassessed and updated periodically, so that their effectiveness can adapt to the constant evolution of risks and protection systems, this would even cover a rethinking of security, if required.”
Monitoring is especially relevant when establishing lines of defence in accordance with Article 8 of the ENS. Detection, analysis and reporting mechanisms will be set to reach those responsible on a regular basis and when there is a significant deviation from pre-set normal parameters.
Article 8 provides:
Article 8. Lines of defence:
For any type of internal and/or external communication, the indications in the Communications Plan, published over the Ivnosys Management System, prepared by the organisation, must be followed.
To ensure the availability of critical services, the organisation has equipped itself with a General Business Continuity Plan (PCN), published over the Management System, which assesses possible disaster scenarios and recovery strategies, and sets periodically reviewed emergency plans.
This Security Policy applies to those information systems supporting the installation and operation processes of the following reliable cloud services:
The Information Security Policy is approved by the company’s Management and its contents and that of the rules and procedures developing it, are mandatory:
Signaturit’s information assets, ensuring its availability, integrity, confidentiality, authenticity, and traceability and that of the facilities, systems and resources that process, manage, transmit and store them, always in accordance with business requirements and current legislation.
Information must be protected throughout its life cycle, from its creation to its eventual erasure or destruction. To this end, the following minimum principles are set:
Signaturit has a procedure for managing and organising both internal and external responsibilities in the field of information security, establishing the System Management Committee, whose main mission is approving and overseeing compliance, managing, and circulating the organisation’s rules and policies, as well as monitoring and managing any current incidents and risks, in terms of information security.
The role of the System Management Committee is reflected in the organisation’s Management System.
The System Management Committee meets at least every six months and the mandatory members sitting on it are the Director General, the Director of IT, the person in charge of the Management System and the security manager.
Signaturit has an internal Data Protection Representative, registered with the Spanish Data Protection Agency, a position held by a professional who meets the experience and training requirements necessary to carry out the role.
Furthermore, any other managers/post-holders whose intervention is necessary because they are affected by the National Security Framework, the GDPR or any other regulation related to information security, such as, among others, the service manager, and the security administrator, may attend at the Committee’s request.
Because security must involve all members of the organisation, as reflected in Article 12 and Annex II of the ENS, in section 3.1 of the same, the Security Policy must clearly identify those responsible for ensuring compliance with it and this must be made known to all members of the organisation.
In the Ivnosys Management System there is a section identifying the people who hold the roles comprising the System Management Committee and covering their specific roles.
Management will assign, renew, and communicate the responsibilities, authority, and roles regarding information security, determining in every case the grounds and the term of validity, and will manage any conflicts that may arise. It will also ensure that users are aware of, assume and exercise their assigned responsibilities, authority, and roles.
The mission of the System Management Committee will be the annual review of this Information Security Policy and making proposals to review or uphold it.
The policy will be approved by company Management and, since it is a public document in accordance with the Ivnosys Information Classification Policy (available over the Management System), it will be circulated by the Communications Department so that all affected parties become aware of it and made available to third parties through the company’s website www.signaturit.com.
Furthermore, it may be additionally reviewed when there are significant changes affecting security, the services provided by the organisation, regulatory changes, or any other issue of relevance.
In accordance with the provisions of the applicable data protection regulations (REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL regarding the protection of natural persons with regard to the processing of personal data or the GDPR and Organic Law 3/2018, of 5 December, Protection of Personal Data and Guaranteeing Digital Rights) Ivnosys Soluciones SLU and Signaturit Solutions SL in their capacity as Data Controller or Joint Controllers as appropriate and data Processors of their clients undertake to:
–Process the personal data, both of customers and of other workers and collaborators in accordance with the principles of legality, loyalty, and transparency. The data collected and used will be gathered for explicit and legitimate purposes. The data collected will be relevant, and limited regarding the purposes established for said processing. The principle of accuracy will be complied with, and all necessary measures will be taken to rectify them when necessary. The data will not be kept longer than necessary in relation to the purposes for processing it, except for compliance with legal aims.
– All security measures mentioned in this Information Security Policy will take into account the protection of data privacy.
– Comply with and enforce, regarding those employees acting as Processors, in accordance with their responsibility regarding the personal data being processed, all those measures provided in this Policy that may affect the personal data to which they may have access due to their work activity. The same applies to the personal data being processed by Signaturit in its capacity as Data Controller. Comply with and enforce, regarding those employees acting as Processors, in accordance with their responsibility regarding the personal data being processed, all those measures provided in this Policy that may affect the personal data to which they may have access due to their work activity. The same applies to the personal data being processed by Signaturit in its capacity as Data Controller.
– That when both Signaturit and its employees and external collaborators in order to provide the services contracted by its customers, require access to personal data, for whose storage in files and processing the customer will be the Data Manager (data access conditions applicable to the Processor), the terms contained in the document “Processing activity to be undertaken” for each contracted service, which will be sent to the client, as ANNEXES to the “Conditions Applicable to Accessing Personal Data”, will apply.
– That Signaturit, its staff and external collaborators will proactively join and use the internal and external communication channels established in the Communications Plan and share information about any incident or security breach of which they become aware, above all about those that may affect personal data. They will cooperate to manage and resolve them according to the degree of responsibility assigned to them.
Likewise, regarding anything not expressly covered by this Policy, Signaturit commits itself and all personnel forming part of it, to strictly comply with all the provisions and principles set out in the data protection regulations currently in force, mentioned at the beginning of this section, and those regulations modifying or replacing them.
Signaturit has an information security management system (ISMS) implementing best practice for managing information security in accordance with standard UNE-ISO / IEC 27001. It applies to all data processing carried out within the framework of contracts formalised with customers and monitoring and measures aimed at guaranteeing the security of personal data, which are the responsibility of customers, whom have access to them under the contract.
The organisation guarantees that it will carry out regular monitoring and security audits necessary to verify that the controls and security measures implemented to handle risk effectively have been implemented in every case.
All systems subject to this Policy must perform a risk analysis, assessing the threats and risks to which they are exposed. This analysis will be carried out regularly, at least once a year. Furthermore, it may be repeated in the following cases:
• When the information handled changes.
• When the services provided change.
• When a serious security incident occurs.
• When serious vulnerabilities are reported.
To align risk analyses, the System Management Committee will set a baseline assessment for the different types of information handled and the different services provided.
The methodology used for risk assessment is MAGERIT which allows the incidents that could arise in the different information assets and affect any of the principles of confidentiality, integrity, availability, authenticity, and traceability, to be effectively managed.
The System Management Committee will boost the availability of resources to meet the security needs of the different systems, promoting horizontal investments.
This Information Security Policy supplements Signaturit’s security policies in different fields:
This Policy will be developed by means of security regulations addressing specific aspects. The security regulations will be made available to all members of the organisation who need to be aware of them, and in particular, to those who use, operate, or manage information and communications systems.
These regulations (processes, procedures, work instructions and any other necessary documentation) will be published on the Confluence Management System, as well as the Signaturit Corporate Wiki.
All members of Signaturit, have the obligation to be aware of and comply with this Information Security Policy and the Security Regulations, the System Management Committee being responsible for providing the necessary means so that the information reaches those affected by it.
All Sig. members, within the framework of the Annual Training Plan, will attend an ICT security awareness session at least once a year. A continuous awareness programme, based on the regular dissemination of emails on information security, will be set up to serve all Signaturit members, particularly those newly recruited. Additionally, for such personnel, specific training and assessment of the knowledge acquired will be carried out, as part of the process of their incorporation into the organisation.
Everybody responsible for using, operating, or administering ICT systems will be trained in the secure operation of the systems to the extent required in order to carry out their work. Training will be mandatory before assuming a responsibility, whether it is a first assignment or a change of job or the responsibilities of the same.
When Signaturit provides services to other agencies or handles information from other agencies, they will be made stakeholders for this Information Security Policy, channels will be set up for reporting and coordinating the managers concerned and action procedures will be set, in accordance with the organisation’s Incident Management Procedure, regarding reacting to any possible security incidents
When Signaturit uses outsourced services or transfers information to outsourced parties, they will be adhered to this Security Policy and the Security Regulations applicable to services or information. As outsourced parties they will be subject to the obligations established in these regulations, having the ability to develop their own operating procedures to satisfy then. Specific procedures for reporting and resolving incidents will be set. It will be ensured that outsourced personnel are appropriately aware of security, at least to the same level as set out in this Policy. When any aspect of the Policy cannot be satisfied by an outsourced party as indicated in the paragraphs above, the Security Manager, together with the person responsible for the service, will meet them to define and specify the risks incurred and how they should be handled.