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1.0

Owner

Head of Engineering

Last Updated On

Last Updated by

Bruno Belizario

Approved by

Overview

This Information Security Policy is intended to protect ecoPortal’s employees, partners, and the company from illegal or damaging actions by individuals, either knowingly or unknowingly.

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Effective security is a team effort involving the participation and support of every ecoPortal employee or contractor who deals with information and/or information systems. It is the responsibility of every team member to read and understand this policy and to conduct their activities accordingly.

Purpose

The purpose of this policy is to communicate our information security policies and outline the acceptable use and protection of ecoPortal’s information and assets. These rules are in place to protect customers, employees, and ecoPortal. Inappropriate use exposes ecoPortal to risks including virus attacks, compromise of network systems and services, financial and reputational risk, and legal and compliance issues.

The ecoPortal “Information Security Policy” is comprised of this policy and all ecoPortal policies referenced and/or linked within this document.

Scope

This policy applies to the use of information, electronic and computing devices, and network resources to conduct ecoPortal business or interact with internal networks and business systems, whether owned or leased by ecoPortal, the employee, or a third party. All employees, contractors, consultants, temporary, and other workers at ecoPortal and its subsidiaries are responsible for exercising good judgment regarding the appropriate use of information, electronic devices, and network resources in accordance with ecoPortal policies and standards, and local laws and regulations.

This policy applies to employees, contractors, consultants, temporaries, and other workers at ecoPortal, including all personnel affiliated with third parties. This policy applies to all ecoPortal-controlled company and customer data as well as all equipment, systems, networks, and software owned or leased by ecoPortal.

Security Incident Reporting

All users are required to report known or suspected security events or incidents, including policy violations, and observed security weaknesses. Incidents shall be reported immediately or as soon as possible by sending an email to: issues@ecoportal.com.

In your email please describe the incident or observation along with any relevant details.

Whistleblower Anonymous Fraud Reporting

Our Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns internally so that we can address and correct inappropriate conduct and actions. It is the responsibility of all employees to report concerns about violations of our code of ethics or suspected violations of law or regulations that govern our operations.

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Anonymous reports may be submitted via <anonymous report mechanism (e.g. whistleblower service)>.Google Forms.

Mobile Device Policy

All end-user devices (e.g., mobile phones, tablets, laptops, desktops) must comply with this policy. Employees must use extreme caution when opening email attachments received from unknown senders, which may contain malware.

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  • Devices must be locked with a password (or equivalent control such as biometric) protected screensaver or screen lock after 5 minutes of non-use

  • Devices must be locked whenever left unattended

  • Users must report any suspected misuse or theft of a mobile device immediately to  ecoPortal’s Tech Team

  • Confidential information must not be stored on mobile devices or USB drives (this does not apply to business contact information, e.g., names, phone numbers, and email addresses)

  • Any mobile device used to access company resources (such as file shares and email) must not be shared with any other person

  • Upon termination, users agree to return all company-owned devices and delete all company information and accounts from any personal devices

Clear Screen Clear Desk Policy

Users shall not leave confidential materials unsecured on their desk or workspace and will ensure that screens are locked when not in use.

Remote Access Policy

Laptops and other computer resources that are used to access the ecoPortal network must conform to the security requirements outlined in ecoPortal’s Information Security Policies and adhere to the following standards:

  • To ensure mobile devices do not connect a compromised device to the company network, Antivirus policies require the use and enforcement of client-side antivirus software

  • Antivirus software must be configured to detect and prevent or quarantine malicious software, perform periodic system scans, and have automatic updates enabled

  • Users must not connect to any outside network without a secure, up-to-date software firewall configured on the mobile computer

  • Users are prohibited from changing or disabling any organizational security controls such as personal firewalls, antivirus software on systems used to access ecoPortal resources

  • Use of remote access software and/or services (e.g., VPN client) is allowable as long as it is provided by the company and configured for multifactor authentication (MFA)

  • Unauthorized remote access technologies may not be used or installed on any ecoPortal system

  • If you access it from a public computer (e.g., from a business center, hotel, etc.), log out of the session and don’t save anything. Don’t check “remember me”, collect all printed materials, and do not download files to a non-ecoPortal controlled system

Acceptable Use Policy

ecoPortal proprietary and customer information stored on electronic and computing devices, whether owned or leased by ecoPortal, the employee, or a third party, remains the sole property of ecoPortal for the purposes of this policy.  Employees and contractors must ensure through legal or technical means that proprietary information is protected in accordance with the Data Management Policy. The use of Google Drive for business file storage is required for users of laptops or company-issued devices. Storing important documents on the file share is how you “backup” your laptop.

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ecoPortal reserves the right to audit networks and systems on a periodic basis to ensure compliance with this policy.

Unacceptable Use

The following activities are, in general, prohibited. Employees may be exempted from these restrictions during the course of their legitimate job responsibilities with properly documented Management approval. Under no circumstances is an employee of ecoPortal authorized to engage in any activity that is illegal under local, state, federal, or international law while utilizing ecoPortal-owned resources or while representing ecoPortal in any capacity. The list below is not exhaustive but attempts to provide a framework for activities that fall into the category of unacceptable use.

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17.  Providing information about, or lists of: ecoPortal employees, contractors, partners, or customers to parties outside ecoPortal without authorization

Email and Communication Activities

When using company resources to access and use the Internet, users must realize they represent the company and act accordingly.

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  1. Sending unsolicited email messages, including the sending of "junk mail", or other advertising material to individuals who did not specifically request such material (email spam)

  2. Any form of harassment via email, telephone, or texting, whether through language, frequency, or size of messages

  3. Unauthorized use, or forging, of email header information

  4. Solicitation of email for any other email address, other than that of the poster's account, with the intent to harass or to collect replies

  5. Creating or forwarding "chain letters", "Ponzi", or other "pyramid" schemes of any type

  6. Use of unsolicited email originating from within ecoPortal networks or other service providers on behalf of, or to advertise, any service hosted by ecoPortal or connected via ecoPortal’s network

Additional Policies and Procedures Incorporated by Reference

Personnel is responsible for reading and complying with all policies relevant to their roles and responsibilities.

Role

Purpose

Access Control Policy

To limit access to information and information processing systems, networks, and facilities to authorized parties in accordance with business objectives.

Asset Management Policy

To identify organizational assets and define appropriate protection responsibilities.

Business Continuity & Disaster Recovery Plan

To prepare ecoPortal in the event of extended service outages caused by factors beyond our control (e.g., natural disasters, man-made events), and to restore services to the widest extent possible in a minimum time frame.

Cryptography Policy

To ensure proper and effective use of cryptography to protect the confidentiality, authenticity and/or integrity of information.

Data Management Policy

To ensure that information is classified and protected in accordance with its importance to the organization.

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To ensure that employees and contractors meet security requirements, understand their responsibilities, and are suitable for their roles.

Incident Response Plan

Policy and procedures for suspected or confirmed information security incidents.

Operations Security Policy

To ensure the correct and secure operation of information processing systems and facilities.

Physical Security Policy

To prevent unauthorized physical access or damage to the organization’s information and information processing facilities.

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To define the process for assessing and managing ecoPortal’s information security risks in order to achieve the company’s business and information security objectives.

Secure Development Policy

To ensure that information security is designed and implemented within the development lifecycle for applications and information systems.

Third-Party Management Policy

To ensure protection of the organization's data and assets that are shared with, accessible to, or managed by suppliers, including external parties or third-party organizations such as service providers, vendors, and customers, and to maintain an agreed level of information security and service delivery in line with supplier agreements.

Policy Compliance

ecoPortal will measure and verify compliance with this policy through various methods, including but not limited to ongoing monitoring and both internal and external audits.

Exceptions

Requests for an exception to this policy must be submitted to the <approver of exceptions to this policy, e.g., IT Manager> CTO for approval.

Violations & Enforcement

Any known violations of this policy should be reported to the <person who should receive reports of violations of this policy, e.g., IT Manager>CTO. Violations of this policy can result in immediate withdrawal or suspension of the system and network privileges and/or disciplinary action in accordance with company procedures up to and including termination of employment.