Data Management Policy

Purpose

To ensure that information is classified, protected, retained, and securely disposed of in accordance with its importance to the organization.

Scope

All ecoPortal data, information, and information systems.

Policy

ecoPortal classifies data and information systems in accordance with legal requirements, sensitivity, and business criticality in order to ensure that information is given the appropriate level of protection. Data owners are responsible for identifying any additional requirements for specific data or exceptions to standard handling requirements.

Information systems and applications shall be classified according to the highest classification of data that they store or process.

Data Classification

To help ecoPortal and its employees easily understand requirements associated with different kinds of information, the company has created three classes of data.

Confidential

Highly sensitive data requires the highest levels of protection; access is restricted to specific employees or departments, and these records can only be passed to others with approval from the data owner, or a company executive. Examples include:

• Customer Data

• Personally identifiable information (PII)

• Company financial and banking data

• Salary, compensation, and payroll information

• Strategic plans

• Incident reports

• Risk assessment reports

• Technical vulnerability reports

• Authentication credentials

• Secrets and private keys

• Source code

• Litigation data

Restricted

ecoPortal proprietary information requires thorough protection; access is restricted to employees with a “need-to-know” based on business requirements. This data can only be distributed outside the company with approval. This is a default for all company information unless stated otherwise. Examples include:

• Internal policies

• Legal documents

• Meeting minutes and internal presentations

• Contracts

• Internal reports

• Google messages

• Email 

Public

Documents intended for public consumption can be freely distributed outside ecoPortal. Examples include:

• Marketing materials

• Product descriptions

• Release notes

• External facing policies

Labeling

Confidential data should be labeled “confidential” whenever paper copies are produced for distribution.

Data Handling

Confidential Data Handling

Confidential data is subject to the following protection and handling requirements:

• Access to non-preapproved-roles requires documented approval from the data owner

• Access is restricted to specific employees, roles, and/or departments

• Confidential systems shall not allow unauthenticated or anonymous access

• Confidential Customer Data shall not be used or stored in non-production systems/environments

• Confidential data shall be encrypted in transit over public networks

• Mobile device hard drives containing confidential data, including laptops, shall be encrypted

• Mobile devices storing or accessing confidential data shall be protected by a log-on password or passcode and shall be configured to lock the screen after five (5) minutes of non-use

• Backups shall be encrypted

• Confidential data shall not be stored on personal phones, devices, or removable media including USB drives, CDs, or DVDs

• Paper records shall be labeled “confidential” and securely stored and disposed

• Hard drives and mobile devices used to store confidential information must be securely wiped prior to disposal or physically destroyed

• Transfer of confidential data to people or entities outside the company shall only be done in accordance with a legal contract or arrangement, and the explicit written permission of management or the data owner

Restricted Data Handling

Restricted data is subject to the following protection and handling requirements:

• Access is restricted to users with a "need-to-know", based on business requirements

• Restricted systems shall not allow unauthenticated or anonymous access

• Transfer of restricted data to people or entities outside the company or authorized users shall require management approval and shall only be done in accordance with a legal contract or arrangement, or the permission of the data owner

• Paper records shall be securely stored and disposed

• Hard drives and mobile devices used to store restricted information must be securely wiped prior to disposal or physically destroyed

Public Data Handling

No special protection or handling controls are required for public data. Public data may be freely distributed.

Data Retention

ecoPortal shall retain data as long as the company has a need for its use, or to meet regulatory or contractual requirements. Once data is no longer needed, it shall be securely disposed of or archived. Data owners, in consultation with legal counsel, may determine retention periods for their data. Retention periods shall be documented in the Data Retention Matrix in Appendix A of this policy.

Data & Device Disposal

Data classified as restricted or confidential shall be securely deleted when no longer needed.

ecoPortal shall ensure that all restricted and confidential data is securely deleted from company devices prior to, or at the time of disposal.

Annual Data Review

Management shall review data retention requirements during the annual review of this policy. Data shall be disposed of in accordance with this policy.

Legal Requirements

Under certain circumstances, ecoPortal may become subject to legal proceedings requiring retention of data associated with legal holds, lawsuits, or other matters as stipulated by ecoPortal legal counsel. Such records and information are exempt from any other requirements specified within this Data Management Policy and are to be retained in accordance with requirements identified by the Legal department. All such holds and special retention requirements are subject to annual review with ecoPortal’s legal counsel to evaluate continuing requirements and scope.

Policy Compliance

ecoPortal will measure and verify compliance to this policy through various methods, including but not limited to; business tool reports, both internal and external audits.

Exceptions

Requests for an exception to this policy must be submitted to the CTO for approval.

Appendix A - Data Retention Matrix