ecoPortal is committed to conducting business in compliance with all applicable laws, regulations, and company policies. ecoPortal has adopted this policy to outline the security measures required to protect electronic information systems and related equipment from unauthorized use.
Objective
This policy and associated guidance establish the roles and responsibilities within ecoPortal, which is critical for effective communication of information security policies and standards. Roles are required within the organization to provide clearly defined responsibilities and an understanding of how the protection of information is to be accomplished. Their purpose is to clarify, coordinate activity, and actions necessary to disseminate security policy, standards, and implementation.
Applicability
This policy is applicable to all ecoPortal infrastructure, network segments, systems, and employees and contractors who provide security and IT functions.
Audience
The audience for this policy includes all ecoPortal employees and contractors who are involved with the Information Security Program. Awareness of this policy applies for all other agents of ecoPortal with access to ecoPortal information and infrastructure. This includes, but is not limited to partners, affiliates, contractors, temporary employees, trainees, guests, and volunteers. The titles will be referred collectively hereafter as “ecoPortal community”.
Roles and Responsibilities
Roles
Responsibilities
Board of Directors
Oversight of Cyber-Risk and internal control for information security, privacy and compliance
Consults with Executive Leadership to understand ecoPortal IT mission and risks and provides guidance to align business, IT, and security objectives
Executive Leadership
Approves Capital Expenditures for Information Security and Privacy programs and initiatives
Oversight over the execution of the information security and Privacy risk management program and risk treatments
Communication Path to ecoPortal Board of Directors
Aligns Information Security and Privacy Policy and Posture based on ecoPortal’s mission, strategic objectives and risk appetite
IT
Manager
Oversight over the implementation of information security controls for infrastructure and IT processes
Responsible for the design, development, implementation, operation, maintenance and monitoring of IT security controls
Ensures IT puts into practice the Information Security Framework
Responsible for conducting IT risk assessments, documenting identified threats and maintaining risk register
Communicates information security risks to executive leadership
Reports information security risks annually to ecoPortal’s leadership and gains approvals to bring risks to acceptable levels
Coordinates the development and maintenance of information security policies and standards
Works with applicable executive leadership to establish an information security framework and awareness program
Serve as liaison to the Board of Directors, Law Enforcement, Internal Audit and General Council
Oversight over Identity Management and Access Control processes
VP of Engineering
Oversight over information security in the software development process
Responsible for the design, development, implementation, operation, maintenance and monitoring of development and commercial cloud hosting security controls
Responsible for oversight over policy development related to systems and software under their control
Responsible for implementing risk management in the development process aligned with company goals
Compliance Manager
Responsible for compliance with the company’s contractual commitments
Responsible for maintaining compliance with relevant data privacy and information security laws and regulations (e.g. GDPR, CCPA)
Responsible for adherence to company adopted information security and data privacy standards and frameworks including SOC 2, ISO 27001 and Microsoft Supplier Data Protection Requirements (DPR)
VP of Global Customer Support
Oversight and implementation, operation and monitoring of information security tools and processes in customer production environments
Execution of customer data retention and deletion processes in accordance with company policy and customer requirements
Systems Owners
Maintain the confidentiality, integrity and availability of the information systems for which they are responsible in compliance with ecoPortal policies on information security and privacy
Approval of technical access and change requests for non-standard access to systems under their control
ecoPortal Employees, Contractors, temporary workers, etc.
Acting at all times in a manner which does not place at risk the health and safety of themselves, other person in the workplace, and the information and resources they have use of
Helping to identify areas where risk management practices should be adopted
Taking all practical steps to minimize ecoPortal’s exposure to contractual and regulatory liability
Adhering to company policies and standards of conduct
Reporting incidents and observed anomalies or weaknesses
Chief Human Resources Officer
Ensuring employees and contractors are qualified and competent for their roles
Ensuring appropriate testing and background checks are completed
Ensuring that employees and relevant contractors are presented with company policies and the Code of Conduct (CoC)
Ensuring that employee performance and adherence the CoC is periodically evaluated
Ensuring that employees receive appropriate security training
COO
Responsible for oversight over third-party risk management process
Responsible for review of vendor service contracts
Policy Compliance
The <role responsible for measuring compliance, e.g., IT Manager> will measure the compliance to this policy through various methods, including, but not limited to—reports, internal/external audits, and feedback to the policy owner. Exceptions to the policy must be approved by the <approver of exceptions to this policy, e.g., IT Manager> in advance. Non-compliance will be addressed with management and Human Resources and can result in disciplinary action in accordance with company procedures up to and including termination of employment.