Maintain an information security programme with administrative, technical and physical safeguards appropriate to the size and complexity of operations, the nature and scope of activities, and the sensitivity of data processed.
Designate staff with responsibility for information security and risk management.
Regularly monitor, review and update the security programme to ensure safeguards remain appropriate.
Policies and Governance
Maintain comprehensive written information security policies and procedures covering:
commitment to information security;
classification, labelling, and handling of information;
acceptable use of systems, networks, and messaging;
incident management and breach response;
authentication and password rules;
access controls and periodic rights reviews; and
disciplinary measures for non-compliance.
Review and update policies periodically and when fundamental changes occur.
Maintain a code of ethics, acknowledged annually by staff.
Asset and Information Management
Maintain inventories of information assets, systems and data.
Apply classification and handling rules, including encryption of sensitive information, including personal data, in storage and in transit.
Apply secure data destruction standards (e.g. NIST SP 800-88 or equivalent).
Physical and Environmental Security
Provide physical entry controls for areas where sensitive information, including personal data, is stored, processed or accessed.
Restrict entry to authorised personnel only.
Maintain environmental controls (fire suppression, HVAC, power, emergency systems) and monitoring of sensitive areas.
Personnel Security
Conduct background checks prior to providing personnel access to sensitive information, including personal data, subject to local law.
Provide mandatory security, data protection, and privacy training on hire and refresh annually.
Maintain formal user registration and de-registration processes, with access revoked promptly on termination.
Communications and Operations
Perform regular data backups, test restorations quarterly, and encrypt all backup media.
Maintain up-to-date malware protection, firewalls, intrusion detection, and patch management.
Encrypt mobile devices used to access or store sensitive information, including personal data.
Prevent unauthorised storage, replication or transfer of sensitive information, including personal data.
Access Control
Enforce best practices for authentication (e.g. unique IDs, MFA for critical systems).
Two of the four character types (upper, lower, digits, special), not to be easily associated with an individual or process, not found in a dictionary, and not to represent a pattern. It is strongly recommended that passwords contain three of the four character types.
Maximum password lifetime
At most 90 days
Minimum password history
One day
Protection in transit
Mandatory. Passwords must be encrypted in transit.
Protection in storage.
Mandatory. Passwords must be hashed using an approved has algorithm.
Review access rights at least annually.
Prevent unattended exposure of sensitive information, including personal data, in physical or digital form.
Secure Development and Testing
Apply secure development lifecycle methods and coding standards.
Conduct secure code reviews before deployment.
Perform quarterly vulnerability scans of external-facing systems.
Perform annual penetration tests by an independent provider.
Remediate vulnerabilities within agreed timeframes (e.g. 30 days for critical/high).
Contractor and Third-Party Management
Select contractors capable of maintaining equivalent security standards.
Put in place written contracts requiring appropriate safeguards no less protective than these Security Measures.
Conduct periodic reviews of contractor security practices.
Maintain a register of all third parties involved in processing sensitive data, including personal data.
Audit and Assurance
Facilitate periodic security audits, including penetration testing and vulnerability assessments, by authorised parties in line with contractual obligations.
Cooperate with supervisory authorities and regulators during audits or investigations related to data protection and security.
Address and remediate any findings and weaknesses identified during audits within reasonable timeframes.
Incident Response
Maintain and test an incident response process, including evidence preservation, engagement with law enforcement, and forensic analysis.
Provide timely notification of incidents within 48 hours, with investigation, mitigation and corrective action.
Produce final reports within 10 days following an incident, including root cause, corrective actions, and prevention measures.
Business Continuity
Maintain and test a business continuity plan covering technology and operations.
Ensure capability to restore services within defined recovery times.