mirror of
https://github.com/strongdm/comply
synced 2024-11-23 08:04:54 +00:00
100 lines
3.6 KiB
Markdown
100 lines
3.6 KiB
Markdown
name: Confidentiality Policy
|
|
acronym: CP
|
|
satisfies:
|
|
TSC:
|
|
- C1.1
|
|
- C1.2
|
|
majorRevisions:
|
|
- date: Jun 1 2018
|
|
comment: Initial document
|
|
---
|
|
|
|
# Purpose and Scope
|
|
|
|
a. This policy outlines expected behavior of employees to keep confidential information about clients, partners, and our company secure.
|
|
|
|
a. This policy applies to all employees, board members, investors, and contractors, who may have access to confidential information. This policy must be made readily available to all whom it
|
|
applies to.
|
|
|
|
# Background
|
|
|
|
a. The company's confidential information must be protected for two reasons:
|
|
|
|
i. It may be legally binding (i.e. sensitive customer data)
|
|
|
|
i. It may be fundamental to our business (i.e. business processes)
|
|
|
|
a. Common examples of confidential information in our company includes, but is not limited to:
|
|
|
|
i. Unpublished financial information
|
|
|
|
i. Customer/partner/vendor/external party data
|
|
|
|
i. Patents, formulas, new technologies, and other intellectual property
|
|
|
|
i. Existing and prospective customer lists
|
|
|
|
i. Undisclosed business strategies including pricing & marketing
|
|
|
|
i. Materials & processes explicitly marked as “confidential”
|
|
|
|
a. Employees will have varying levels of authorized access to confidential information.
|
|
|
|
# Policy
|
|
|
|
a. *Employee procedure for handling confidential information*
|
|
|
|
i. Lock and secure confidential information at all times
|
|
|
|
i. Safely dispose (i.e. shred) documents when no longer needed
|
|
|
|
i. View confidential information only on secure devices
|
|
|
|
i. Disclose information only when authorized and necessary
|
|
|
|
i. Do not use confidential information for personal gain, benefit, or profit
|
|
|
|
i. Do not disclose confidential information to anyone outside the company or to anyone within the company who does not have appropriate privileges
|
|
|
|
i. Do not store confidential information or replicates of confidential information in unsecured manners (i.e. on unsecured devices)
|
|
|
|
i. Do not remove confidential documents from company's premises unless absolutely necessary to move
|
|
|
|
a. *Offboarding measures*
|
|
|
|
i. The Hiring Manager should confirm the off-boarding procedure has been completed by final date of employment.
|
|
|
|
a. *Confidentiality measures*
|
|
|
|
i. The company will take the following measures to ensure protection of confidential information:
|
|
|
|
1. Store and lock paper documents
|
|
|
|
1. Encrypt electronic information and implement appropriate technical measures to safeguard databases
|
|
|
|
1. Require employees to sign non-disclosure/non-compete agreements
|
|
|
|
1. Consult with senior management before granting employees access to certain confidential information
|
|
|
|
a. *Exceptions*
|
|
|
|
i. Under certain legitimate conditions, confidential information may need to be disclosed. Examples include:
|
|
|
|
1. If a regulatory agency requests information as part of an audit or investigation
|
|
|
|
1. If the company requires disclosing information (within legal bounds) as part of a venture or partnership
|
|
|
|
i. In such cases, employee must request and receive prior written authorization from their hiring manager before disclosing confidential information to any third parties.
|
|
|
|
a. *Disciplinary consequences*
|
|
|
|
i. Employees who violate the confidentiality policy will face disciplinary and possible legal action.
|
|
|
|
i. A suspected breach of this policy will trigger an investigation. Intentional violations will be met with termination and repeated unintentional violations may also face termination.
|
|
|
|
i. This policy is binding even after the termination of employment.
|
|
|
|
|
|
|
|
|
|
|