Asset Management Policy

Purpose

The purpose of the IT Asset Management Policy is to maintain accurate records of ecoPortal’s physical and digital computer assets. This document establishes procedures to ensure compliance with government regulations, legal industry standards and to ensure accurate reporting of physical assets. This policy will apply to all computer equipment and related assets purchased and handled by ecoPortal.

Safeguarding Responsibilities - Physical Assets

All items purchased will be recorded and maintained on a Fixed Asset Register by the IT Department. In order to manage the register accurately and efficiently, all employees shall adhere to the following;

1. Employees of ecoPortal shall not remove IT assets supplied by the firm from company premises, except under the following conditions:

   1. IT assets assigned to employees, which may include laptop or tablet computers and Personal Digital Assistant (PDA) or Smartphone devices, may be removed for the following reasons only:

• Teleworking.

• Work that is outside of the office that is a part of an assigned position.

Exceptions to this policy must be requested in writing and approved by the Director of Information Security. Documentation of exceptions shall include the business or technical justification and the duration of the exception.

1. ecoPortal’s employees are responsible for safeguarding any IT assets they remove from the building, including keeping these assets under their direct physical control whenever possible, and physically securing the assets when they are not under the employee’s direct physical control.

2. ecoPortal’s employees must immediately report the loss or theft of any assigned IT assets to the IT Department.

3. ecoPortal’s employees are not allowed to bring their own IT assets into work locations with the purpose of connecting to the firm’s private network and data.

   1. In general, connection of personal IT assets to networks provided by the firm for guest or public access is not allowed.

   2. Exceptions to this policy must be documented in writing and approved by the Director of Information Security. Documentation of exceptions shall include the business or technical justification and the duration of the exception.

Safeguarding Responsibilities - Digital Assets

1. ecoPortal ensures that all client data is:

   1. Stored in a secure facility, both physically as digitally

   2. Accessed end-to-end only in a secure and encrypted manner

   3. Backed up in a secure and encrypted fashion

   4. Not removed unless requested by the client considering the technical abilities
      (nature of the backup system)

1. All ecoPortal employees handling client data must ensure that:

   1. All client data is accessed only over secure channels

   2. (HTTPS or SFTP with or without MFA)

   3. All client data received from or sent to clients is done so in an encrypted manner

   4. (GPG)

   5. All client data is stored on encrypted drives and/or folders

   6. All client data is removed from said drives/folders at the earliest opportunity and the “trash can” is cleared

   7. Any and all devices accessing client data are password locked when they walk away from their device

   8. Any and all mobile devices accessing client data are logged out of ecoPortal at the earliest opportunity

Disposal of Assets

1. Disposal of ecoPortal’s assets, including the sale, transfer, donation, write off or sustainable disposal (recycling), must be done in adherence with all federal, state and local regulations.

2. Computer hardware must have all software and information securely removed prior to disposal.

3. Highly sensitive data must be deleted using secure methods as soon as they are no longer required.

4. Secure methods of removal shall mean the use of software that can be configured to overwrite the data at least three times and or physical destruction of the hard drives to the extent that precludes any possible restoration of the data.