Info. Sec. Organization / Structure (cont.)
|
|
- Myles Mason
- 5 years ago
- Views:
Transcription
1 Info. Sec. Organization / Structure (cont.) Identify Protect Detect Respond Recover
2 Info. Sec. Organization / Structure (cont.) Functions Related to Info. Sec. Program (cont.) Functions Performed by Business Units Outside IT Legal Training identify, protect... Functions Performed by IT Groups, but not Info Sec Systems Administration Network Administration protect, detect
3 Info. Sec. Organization / Structure (cont.) Functions Related to Info. Sec. Program (cont.) Functions Performed by Info Sec Department, or Possibly Outsourced Risk Assessment Vulnerability Assessment Incident Response Audit Functions Performed by Info Sec Department (Security) Policy (Security) Risk Management Data Security,
4 Info. Sec. Organization / Structure (cont.) Example: test your knowledge of security functions
5 Security Policy
6 Policy, Standard, Procedure NIST Cybersecurity Framework: 22 Core Functions (cont.) Protect Information Protection Processes and Procedures: manage protection of information & information systems in accordance to established policies, processes & procedures
7 Policy, Standard, Procedure (cont.) Example: Policy
8 Policy, Standard, Procedure (cont.) Security Policy foundation of an effective info. security system/program What is it? concise and easy to understand statement that: (1) defines a set of conditions that are critical for protecting organization s assets, and its ability to conduct business (2) defines general security practices that management expects employees and other stakeholders to follow Why do we need it? helps organizations demonstrate their commitment to protect their information assets and/or comply with law heightens security awareness of company personnel or third-party users/customers
9 Policy, Standard, Procedure (cont.) Example: Organization without policy Consider scenario: An employee (A) behaves inappropriately at the work place, by reading another employee s . Another employee (B) is aggrieved by this behavior and sues the company. The company does not have policy that prohibits such behavior, hence no legal action against offender (A) can be taken Nevertheless, company may be legally obliged to protect the privacy of employee B. The company loses the lawsuit, and lots of money
10 Policy, Standard, Procedure (cont.) Although least expensive security protection, Policies are often most difficult to implement/enforce. To ensure effectiveness, failure to comply with a Policy should imply a disciplinary action.
11 Policy, Standard, Procedure (cont.) Example: Policy that is hard to implement Employees are not allowed to take out of the company s premise any IP-related documentation.
12 Policy, Standard, Procedure (cont.) conceptual Why? What? How? hands-on
13 Policy, Standard, Procedure (cont.) Security Standard more specific directives that are mandatory describe what to do (or not do) to comply with the policy also, extension of the policy into the real world specifies technology settings, platforms or behaviors it is important to audit adherence to standards to ensure their implementation Security Procedure specify actual steps of how to implement or comply with a standard example: specific instructions on how to download and install centrally managed antivirus software
14 Policy, Standard, Procedure (cont.) Example: Policy vs. Standard vs. Procedure Many Info. Sec. departments have specific protocols for performing backups of server hard drives. Policy: Describes the need for backups, for storage off-site, and for safeguarding the backup media. Standard: Defines the software to be used to perform backups and how to configure this software (e.g. Acronis, SmartSync, etc.) Procedure: Describes how to use the backup software, the timing for making backups, and other ways that humans humans interact with the backup system.
15
16 Policy, Standard, Procedure (cont.) Security Guideline discretionary set of directives designed to achieve a policy/security objectives needed in complex & uncertain situations for which rigid standards cannot be specified examples: company might have a guideline that each new employee should have a background check however, in an emergency, department head might be allowed to hire a person before a background check is completed Security Recommended Practices set of policies / standards / procedures /guidelines recommended by trade associations and government agencies Security Best Practices descriptions of what best firms in the industry are doing about security
17 Policy, Standard, Procedure (cont.) Example: Microsoft Best Security Practices
18 Security Policy Important rule to follow when shaping a policy: Policy should never conflict with existing law. Policy must be able to stand up in court if challenged. Policy must be properly supported and administered. For policies to be effective, they must be: A. Developed using industry-accepted practices. B. Distributed or disseminated using all appropriate methods. C. Read by all employees. D. Comprehended by all employees. E. Formally agreed / complied to by act or affirmation. F. Enforced and applied uniformly.
19 Security Policy: Development A. Development of Security Policy - 5 stage process A.1 Investigation Phase. Form the right policy design team consisting of representatives from groups that will be affected by new policy (e.g. legal dept., HR, end users of various IT systems covered by policy) Make an outline of the scope and goals of the policy, as well as the cost and scheduling of its implementation. Obtain general support from senior management. Without enough attention, any policy has a reduced chance of success mid-management and users not likely to implement it. A.2 Analysis Phase. Obtain all recent & relevant information - risk assessment, IT audits, - as well as other references (e.g. past law suits) concerning positive / negative outcome of similar policies.
20 Security Policy: Development (cont.) Why is Analysis Phase performed after Investigation Phase? Wouldn t it be beneficial to approach the management with already gathered legal/audit (reference) information? Sometimes policy documents that affect information security is housed in the HR department, as well as accounting, finances, legal, or corporate security departments.
21 Security Policy: Development (cont.) A. Development of Security Policy: 5 stage process (cont.) A.3 Design / Distribution Planning Phase. Create a plan on how to distribute and verify the distribution of the policy. (e.g. through internet or hard-copy form may impact the content of the policy) A.4 Implementation Phase. Design team actually writes the policy. Can rely on existing policies found on the Web, Government Sites, Professional Literature. A.5 Maintenance Phase. Monitor, maintain, and modify the policy to ensure that it remains effective as a tool against ever changing threats. (ongoing process!)
22 Security Policy: Development (cont.) Example: Policy templates
23 Security Policy: Distribution B. Policy Distribution Getting the policy document into the hands of all employees may require a substantial effort / investment. Techniques of distribution: hard-copy distribution bulletin-board distribution distribution via distribution via intranet (in html or PDF form) Organization must be able to prove distribution of the policy document, e.g. via auditing log in case of electronic distribution.
24 Security Policy: Distribution (cont.)
25 Security Policy: Reading & Comprehension C. & D. Policy Reading and Comprehension Policy must be written/presented in a way that all employees can read and comprehend. illiterate or low-literate workers ESL workers visually impaired, etc. Example: Importance of policy reading & comprehension Assume an employee is fired for failure to comply with a policy. If the organization cannot verify that the employee was in fact properly educated on the policy, the employee could sue the organization for wrongful termination.
26 Security Policy: Compliance E. Policy Compliance (Consequences of not complying with policy should be clearly stated and agreed upon by the employees.) Failure to agree to or follow a policy may jeopardize organization s interests and, thus, be sufficient to decide on termination. However, the legal system may not support such decision. Organization can/should incorporate policy confirmation statement into employment contract or annual evaluation.
27 Security Policy: Enforcement F. Policy Enforcement Because of potential scrutiny during legal proceedings, organizations must establish high standards of policy implementation. example: if policy mandates that all employees wear ID badges in a clearly visible location, and some management members decide not to follow this policy, any action taken against other employees will not withstand legal challenges
28 Security Policy Categories Three types of security policies found in most organizations: 1) Enterprise Information Security Policy (EISP) 2) Issue-specific Security Policy (ISSP) 3) System-specific Security Policy (SysSP)
29 Security Policy Categories: EISP 1) Enterprise Information Security Policy (EISP) Aka as general security policy sets strategic direction, scope, and tone for all security matters and efforts. Short (2 10 page) executive-level document usually drafted by chief IT officer of the organization. Common components of a good EISP: Statement of purpose explains the intent of the document. States info. sec. philosophy for the given enterprise. Explains the importance of info. sec. for the enterprise. Defines the info. sec. organization/structure of the enterprise. Lists other standards that influence and are influenced by this document.
30
31 Security Policy Categories: ISSP 2) Issue-Specific Security Policy (ISSP) Provides detailed, targeted guidance concerning the use of a particular process, technology or a system. ISSP may cover one or more of the following: use of electronic mail use of the Internet and WWW use of company-owned computer equipment use of personal equipment on company networks
32 Security Policy Categories: ISSP (cont.) 2) Issue-Specific Security Policy (ISSP) (cont.) Components of a typical ISSP : 1) Statement of Purpose what is the scope of the policy what technology and issue it addresses who is responsible and accountable for policy implementation 2) Authorized Access and Usage who can use the technology governed by the policy what the technology can be used for what constitutes fair and responsible use of technology and it may impact personal information and privacy 3) Prohibitive Use of Equipment - unless a particular use is clearly prohibited, the company cannot penalize its employees for misuse what constitutes disruptive use, misuse, criminal use what other possible restrictions may apply
33 Security Policy Categories: ISSP 2) Issue-Specific Security Policy (ISSP) (cont.) Components of a typical ISSP : 4) Systems Management which kind of authorized employer monitoring is involved (e.g. electronic scrutiny of & other electronic documents) 5) Violation of Policy what specific penalties, for each category of violation, will apply how to report observed or suspected violations openly or anonymously 6) Limitation of Liability company does not want to be liable if an employee is caught conducting illegal activity with company s asset how is liable if an employee violates a company policy or law
34 Security Policy Categories: SysSP 3) System-Specific Security Policy (SysSP) Both EISP and ISSP are formalized as written documents readily identifiable as policy. SysSP has a look of a standard or a procedure to be used when configuring / maintaining a system intended for (not regular users but) information security personnel Managerial Guidance SysSP created by management to guide implementation / configuration of technology as well as to address people behavior in ways to support EISP and ISSP. Technical Specifications SysSP in some cases system administrators need to create / implement their own policy in order to enforce EISP, ISSP or managerial policy.
35 Security Policy Categories: SysSP (cont.) Example: EISP vs. ISSP vs. Managerial SysSP EISP: ISSP 1: ISSP 2: Company s IT system should only be used to access and/or exchange corporate information. server should/will discard/quarantine all s with non-corporate sender/receiver addresses. Firewall should/will be set in a way to prevent access to outside web-sites. Managerial SysSP: All outgoing IP packets carrying HTTP content and port numbers x, y, z should be dropped.
INFORMATION AND CYBER SECURITY POLICY V1.1
Future Generali 1 INFORMATION AND CYBER SECURITY V1.1 Future Generali 2 Revision History Revision / Version No. 1.0 1.1 Rollout Date Location of change 14-07- 2017 Mumbai 25.04.20 18 Thane Changed by Original
More informationNATIONAL RECOVERY AGENCY COMPLIANCE INFORMATION GRAMM-LEACH-BLILEY SAFEGUARD RULE
NATIONAL RECOVERY AGENCY COMPLIANCE INFORMATION GRAMM-LEACH-BLILEY SAFEGUARD RULE As many of you know, Gramm-Leach-Bliley requires "financial institutions" to establish and implement a Safeguard Rule Compliance
More informationTRAVELTOKENS SALE PRIVACY POLICY Last updated:
TRAVELTOKENS SALE PRIVACY POLICY Last updated: 23.11.2017 STATUS AND ACCEPTANCE OF PRIVACY POLICY 1. This Privacy Policy (hereinafter referred to as the Policy ) sets forth the general rules of Participant
More informationMarch 1. HIPAA Privacy Policy
March 1 HIPAA Privacy Policy 2016 1 PRIVACY POLICY STATEMENT Purpose: The following privacy policy is adopted by the Florida College System Risk Management Consortium (FCSRMC) Health Program and its member
More informationRegenstrief Center for Healthcare Engineering HIPAA Compliance Policy
Regenstrief Center for Healthcare Engineering HIPAA Compliance Policy Revised December 6, 2017 Table of Contents Statement of Policy 3 Reason for Policy 3 HIPAA Liaison 3 Individuals and Entities Affected
More informationCyber ERM Proposal Form
Cyber ERM Proposal Form This document allows Chubb to gather the needed information to assess the risks related to the information systems of the prospective insured. Please note that completing this proposal
More informationNAPBS BACKGROUND SCREENING AGENCY ACCREDITATION PROGRAM ACCREDITATION STANDARD AND AUDIT CRITERIA Version 2.0. Potential Verification for Onsite Audit
Page 1 of 24 NAPBS BACKGROUND SCREENING AGENCY ACCREDITATION PROGRAM ACCREDITATION STANDARD AND AUDIT CRITERIA Version 2.0 (Glossary provided at end of document.) Information Security 1.1 Information Security
More informationPAI Secure Program Guide
PAI Secure Program Guide A complete guide to understanding the Payment Card Industry Data Security Requirements (PCI DSS) and utilizing the PAI Secure Program Welcome to PAI Secure, a unique 4-step PCI-DSS
More informationFOR COMMENT PERIOD NOT YET APPROVED AS NEW STANDARD
UPDATED STANDARD FOR COMMENT OCT 2017 Page 1 of 23 NAPBS BACKGROUND SCREENING AGENCY ACCREDITATION PROGRAM ACCREDITATION STANDARD AND AUDIT CRITERIA (Glossary provided at end of document.) Information
More informationHIPAA COMPLIANCE. for Small & Mid-Size Practices
HIPAA COMPLIANCE for Small & Mid-Size Practices Golden State Web Solutions 619.825.GSWS (4797) INTRODUCTION Most individuals reading this are interested in HIPAA, GSWS, or some combination of the two;
More informationLIABILITY INTERRUPTION OF ACTIVITIES CYBER CRIMINALITY OWN DAMAGE AND COSTS OPTION: LEGAL ASSISTANCE
I N S U R A N C E a g a i n s t c y b e r r i s k s After "prevention", risk covering is always the next step. Good insurance policies have the substantial merit allowing people to progress, even choosing
More informationTitle CIHI Submission: 2014 Prescribed Entity Review
Title CIHI Submission: 2014 Prescribed Entity Review Our Vision Better data. Better decisions. Healthier Canadians. Our Mandate To lead the development and maintenance of comprehensive and integrated health
More informationBluesphere Advisors LLC. Form ADV Part 2A Disclosure Brochure
Form ADV Part 2A Disclosure Brochure Effective: April 27, 2017 This Form ADV 2A ( Disclosure Brochure ) provides information about the qualifications and business practices of ( Bluesphere or the Advisor
More informationANTI-FRAUD CODE CONTENTS INTRODUCTION GOAL CORPORATE REFERENCE FRAMEWORK CONCEPTUAL FRAMEWORK ACTION FRAMEWORK GOVERNANCE STRUCTURE
ANTI-FRAUD CODE CONTENTS INTRODUCTION GOAL CORPORATE REFERENCE FRAMEWORK CONCEPTUAL FRAMEWORK ACTION FRAMEWORK GOVERNANCE STRUCTURE PREVENTION, DETECTION, INVESTIGATION AND RESPONSE MECHANISMS APPLICATION
More informationALTA Best Practices Framework: Assessment Procedures
Mr. John Baumgart Chief Executive Officer 733 Crown Industrial Court, Suite A Chesterfield, MO 63005 Dear Mr. Baumgart: PYA, P.C. (PYA) has completed the assessment procedures as defined by the American
More informationOMERS Administration Corporation Privacy Statement
OMERS Administration Corporation Privacy Statement Noam Sela privacy@omers.com Effective November 1, 2017 L E G A L OUR COMMITMENT TO YOUR PRIVACY At OMERS Administration Corporation, we are committed
More informationPRIVACY IMPACT ASSESSMENT
The Guide to Completing a PRIVACY IMPACT ASSESSMENT Under the Access to Information and Protection of Privacy Act, 2015 June 2016 Table of Contents Part A Introduction to Privacy Impact Assessments...
More informationUnited Security Bank Online Banking Agreement
United Security Bank Online Banking Agreement APPLICATION FOR ONLINE ACCESS AGREEMENT By clicking on "I Agree", you are agreeing to the "Terms and Conditions" that govern your use of the online banking
More informationPrepared by Office of Procurement and Real Property Management. This replaces Administrative Procedure No. A8.266 dated September 2014 A8.
Prepared by Office of Procurement and Real Property Management. This replaces Administrative Procedure No. A8.266 dated September 2014 A8.266 A8.266 Purchasing Cards 1. Purpose A8.200 Procurement July
More informationUNDERSTANDING HIPAA & THE HITECH ACT. Heather Deixler, Esq. Associate, Morgan, Lewis & Bockius LLP
UNDERSTANDING HIPAA & THE HITECH ACT Heather Deixler, Esq. Associate, Morgan, Lewis & Bockius LLP 1 Objectives of Presentation Learn what HIPAA is Learn the purpose of HIPAA Understand who HIPAA regulates
More informationTracking and Targeting Customers and Prospects Online, on Mobile Devices, and in Social Media 2013
INTELLECTUAL PROPERTY Course Handbook Series Number G-1156 Tracking and Targeting Customers and Prospects Online, on Mobile Devices, and in Social Media 2013 Chair D. Reed Freeman, Jr. To order this book,
More informationALTA Best Practices Framework: Assessment Procedures
ALTA Best Practices Framework: Page 1 of 19 ALTA Best Practices Framework The ALTA Best Practices Framework has been developed to assist lenders in satisfying their responsibility to manage third party
More informationProprietary Information Protection
C O R P O R A T E P O L I C Y M A N U A L Section Proprietary Information Protection 14 A. SUMMARY B. APPLICABILITY C. POLICY D. PROCEDURES E. REFERENCES Code of Ethics United Technologies Corporation
More informationDetermining Whether You Are a Business Associate
The HIPAApotamus in the Room: When Lawyers and Law Firms are Subject to HIPAA Enforcement, And How to Comply with the Law by Leslie R. Isaacman, J.D., M.B.A. The Omnibus Final Rule 1 of the Health Information
More informationDATA PROCESSING AGREEMENT (GDPR, Privacy Shield, and Standard Contractual Clauses)
DATA PROCESSING AGREEMENT (GDPR, Privacy Shield, and Standard Contractual Clauses) This Data Processing Agreement ("DPA") forms part of the Master Services and Subscription Agreement between Customer and
More informationA guide to the fiduciary role in a retirement plan
Retirement Plan Solutions Content provided by: Compliments of TD Ameritrade Institutional A guide to the fiduciary role in a retirement plan Understanding your status, supporting plan sponsors as fiduciaries,
More informationAPPLICATION FOR DATA BREACH AND PRIVACY LIABILITY, DATA BREACH LOSS TO INSURED AND ELECTRONIC MEDIA LIABILITY INSURANCE
Deerfield Insurance Company Evanston Insurance Company Essex Insurance Company Markel American Insurance Company Markel Insurance Company Associated International Insurance Company DataBreach SM APPLICATION
More informationCredit Card Handling Security Standards
Credit Card Handling Security Standards Overview This document is intended to provide guidance regarding the processing of charges and credits on credit and/or debit cards. These standards are intended
More informationCybersecurity Threats: What Retirement Plan Sponsors and Fiduciaries Need to Know and Do
ARTICLE Cybersecurity Threats: What Retirement Plan Sponsors and Fiduciaries Need to Know and Do By Gene Griggs and Saad Gul This article analyzes cybersecurity issues for retirement plans. Introduction
More informationDICKINSON COLLEGE PURCHASING CARD PROGRAM POLICIES AND PROCEDURES MANUAL
DICKINSON COLLEGE PURCHASING CARD PROGRAM POLICIES AND PROCEDURES MANUAL Introduction Dickinson College has established a Purchasing Card Program to provide expanded convenience and controls for low dollar
More informationDELHAIZE AMERICA PHARMACIES AND WELFARE BENEFIT PLAN HIPAA SECURITY POLICY (9/1/2016 VERSION)
DELHAIZE AMERICA PHARMACIES AND WELFARE BENEFIT PLAN HIPAA SECURITY POLICY (9/1/2016 VERSION) Delhaize America, LLC Pharmacies and Welfare Benefit Plan 2013 Health Information Security and Procedures (As
More informationProtection of Personal Information (POPI) Policy. Sigma SA (Pty) Ltd FSP: 45643
Protection of Personal Information (POPI) Policy Sigma SA (Pty) Ltd FSP: 45643 1 Table of Contents 1. Protection of Personal Information Policy... 3 2 1. Protection of Personal Information Policy Objective:
More informationBPU Investment Management, Inc. Form ADV Wrap Fee Brochure March 29, 2018
BPU Investment Management, Inc. Form ADV Wrap Fee Brochure March 29, 2018 Principal Office One Oxford Centre 301 Grant Street, Suite 3300, PA 15219 (800) 822-6585 www.bpuinvestments.com This brochure provides
More informationLICENSE AGREEMENT. Security Software Solutions
LICENSE AGREEMENT Security Software Solutions VERIS ACTIVE ID SERVICES AGREEMENT between Timothy J. Rollins DBA Security Software Solutions, having an office at 5215 Sabino Canyon Road and 4340 N Camino
More information* Unless otherwise indicated, this policy will still apply beyond the review date.
Name of Policy Description of Policy Privacy Policy This policy sets out how ACU manages privacy obligations and reflects the 13 Australian Privacy Principles (APPs) from Schedule 1 of the Privacy Amendment
More informationThe following legal provisions apply to the provision of the Technolutions services and are binding on any subscriber to such service:
Terms and Conditions No-one really likes digging through the small print, but it s essential to have these terms and conditions in place so that everyone is protected. However we'll try and keep them as
More informationNegotiating Business Associate Agreements
Negotiating Business Associate Agreements February 19, 2015 William J. Roberts, Esq. Shipman & Goodwin LLP 2015. All rights reserved. HARTFORD STAMFORD GREENWICH WASHINGTON, DC About HIPAA HIPAA is a federal
More informationCyber Risk Proposal Form
Cyber Risk Proposal Form Company or trading name Address Postcode Country Telephone Email Website Date business established Number of employees Do you have a Chief Privacy Officer (or Chief Information
More information"HIPAA RULES AND COMPLIANCE"
PRESENTER'S GUIDE "HIPAA RULES AND COMPLIANCE" Training for HIPAA REGULATIONS Quality Safety and Health Products, for Today...and Tomorrow OUTLINE OF MAJOR PROGRAM POINTS OUTLINE OF MAJOR PROGRAM POINTS
More information13.1 Quantitative vs. Qualitative Analysis
436 The Security Risk Assessment Handbook risk assessment approach taken. For example, the document review methodology, physical security walk-throughs, or specific checklists are not typically described
More informationEMPLOYEE PRIVACY STATEMENT
EMPLOYEE PRIVACY STATEMENT 1 INTRODUCTION This is SBM Offshore s Privacy Statement for employee data. This Privacy Statement provides information on the processing of personal data of the employees of
More informationSureRent 2020 Private Landlord Tenant Screening Application Package
Page 1 of 9 SureRent 2020 Private Landlord Tenant Screening Application Package Welcome to Alliance 2020. Your membership packet includes several forms that you must complete before service can be started,
More informationHEALTHCARE BREACH TRIAGE
IAPP Privacy Academy September 30 October 2, 2013 HEALTHCARE BREACH TRIAGE Theodore P. Augustinos EDWARDS WILDMAN PALMER LLP Kenneth P. Mortensen CVS/CAREMARK 2013 Edwards Wildman Palmer LLP & Edwards
More informationData Privacy Alert: California Consumer Privacy Act of 2018 Just Enacted
2018 Data Privacy Alert: California Consumer Privacy Act of 2018 Just Enacted After only a few days of legislative debate, Governor Jerry Brown of California signed a bill enacting the California Consumer
More informationMay 2, 2018 Page 1 of 8
ALBERTA BLUE CROSS ONLINE SERVICES BILLING AGREEMENT Terms of Use ABC Benefits Corporation ( Alberta Blue Cross ) makes the Alberta Blue Cross Provider Online Services Web Site available solely for the
More informationSentry Wealth Advisors. Form ADV Part 2A Disclosure Brochure
Form ADV Part 2A Disclosure Brochure Effective: June 28, 2011 This Disclosure Brochure provides information about the qualifications and business practices of Sentry Wealth Advisors, P. Richard Perryman
More informationTerms and Conditions of Use for the Credit Suisse TWINT App
Terms and Conditions of Use for the Credit Suisse TWINT App 1. General Provisions 1.1 Scope/Overview of Services Credit Suisse (Switzerland) Ltd. (hereinafter referred to as the Bank ) offers people (hereinafter
More informationPolicy 42 Anti-Fraud, Anti-Theft & Anti-Corruption
Policy 42 Anti-Fraud, Anti-Theft & Anti-Corruption Table of Contents Introduction...1 Our written rules...2 Expected Behaviour...2 Preventing fraud, theft and corruption...3 Detecting and investigating
More informationApplication of Self-Regulatory Principles to the Mobile Environment
Application of Self-Regulatory Principles to the Mobile Environment Digital Advertising Alliance www.aboutads.info July 2013 developed by: American Association of Advertising Agencies American Advertising
More informationDesigning Privacy Policies and Identifying Privacy Risks for Financial Institutions. June 2016
Designing Privacy Policies and Identifying Privacy Risks for Financial Institutions June 2016 Program Overview Regulatory Environment Who Needs a Privacy Program and Common Questions Components of a Comprehensive
More informationAdvia Credit Union 24 Hour Online, Text and Mobile Banking Access Agreement
Advia Credit Union 24 Hour Online, Text and Mobile Banking Access Agreement This Internet Access Agreement is the contract that covers your and our rights and responsibilities concerning the Internet Banking
More informationAnti-Facilitation of Tax Evasion Policy
Foreword A good reputation is a hard-won asset which we must protect. Our ability to tender for new business and our relationship with the full range of our stakeholders depends a great deal upon the good
More informationConsumer Internet Banking Agreement
Consumer Internet Banking Agreement 1. AGREEMENT. This agreement contains the terms and conditions that govern accessing or using the Consumer Internet Banking, Bill Payment Services, E-bill Service and
More informationARE YOU HIP WITH HIPAA?
ARE YOU HIP WITH HIPAA? Scott C. Thompson 214.651.5075 scott.thompson@haynesboone.com February 11, 2016 HIPAA SECURITY WHY SHOULD I CARE? Health plan fined $1.2 million for HIPAA breach. Health plan fined
More informationHIPAA / HITECH. Ed Massey Affiliated Marketing Group
HIPAA / HITECH Agent Understanding And Compliance Presented By: Ed Massey Affiliated Marketing Group It s The Law On February 17, 2010 the Health Information Technology for Economic and Clinical Health
More informationCompute Managed Services Schedule to the Products and Services Agreement
Compute Managed Services Schedule to the Products and Services Agreement Contents Words defined in the General Terms and conditions... 2 Part A Compute Managed Services... 2 1 Service Summary... 2 2 Service
More informationDear Colleague, In the steadfast pursuit of excellence, I remain, Sincerely yours,
Dear Colleague, Every employee, manager and physician plays a vital role in realizing Lifespan s mission: Delivering health with care. Essential to achieving this mission is Lifespan s continuous commitment
More informationCompute Managed Services Schedule to the General Terms
Compute Managed Services Schedule to the General Terms Contents A note on you... 2 Words defined in the General Terms... 2 Part A Compute Managed Services... 2 1 Service Summary... 2 2 Service Components...
More informationHealth & Safety Policy HSP25 CCTV
Health & Safety Policy HSP25 CCTV Version Status Date Title of Reviewer Purpose/Outcome 1.0 Draft 07.03.2016 David Maine 1 st Draft for consultation/review 1.1 Approved 10.01.2017 David Maine 1 st Issue
More informationCODE OF BUSINESS CONDUCT AND ETHICS
CODE OF BUSINESS CONDUCT AND ETHICS 1. Introduction Shutterstock, Inc. and its subsidiaries ( Shutterstock, the Company or we ) are committed to maintaining the highest standards of ethical conduct. This
More informationColorado All Payer Claims Database Privacy, Security and Data Release Fact Guide
Colorado All Payer Claims Database Privacy, Security and Data Release Fact Guide Colorado All Payer Claims Database: Background The Colorado All Payer Claims Database (APCD) collects health insurance claims
More informationCBOE GLOBAL MARKETS, INC. AND SUBSIDIARIES CODE OF BUSINESS CONDUCT AND ETHICS. Adopted October 27, 2017
CBOE GLOBAL MARKETS, INC. AND SUBSIDIARIES CODE OF BUSINESS CONDUCT AND ETHICS Adopted October 27, 2017 Purpose This Code of Business Conduct and Ethics (the Code ) has been adopted by the Board of Directors
More informationOfficial Rules AMAZON ECHO SWEEPSTAKES SPONSORED BY AT&T, INC.
Official Rules AMAZON ECHO SWEEPSTAKES SPONSORED BY AT&T, INC. NO PURCHASE NECESSARY TO ENTER OR WIN A PRIZE. A PURCHASE WILL NOT INCREASE YOUR CHANCES OF WINNING. VOID OUTSIDE OF THE FIFTY UNITED STATES
More informationFor the purpose of these General Terms and Conditions, the below-specified terms shall have the following meaning:
GENERAL TERMS AND CONDITIONS OF HRVATSKI TELEKOM D.D. FOR PROVISION OF SERVICES IN THE PUBLIC FIXED COMMUNICATIONS NETWORK (HRVATSKI TELEKOM FIXED SERVICES) (hereinafter: General Terms and Conditions)
More informationHIPAA AND YOU 2017 G E R A L D E MELTZER, MD MSHA
HIPAA AND YOU 2017 G E R A L D E MELTZER, MD MSHA ALLISON SHUREN, J D, MSN Financial Disclosure Gerald Meltzer is a consultant for imedicware Allison Shuren co-chairs the Life Sciences and Healthcare Regulatory
More informationTTCU FEDERAL CREDIT UNION
TTCU FEDERAL CREDIT UNION ONLINE BANKING AGREEMENT & DISCLOSURES 1. Introduction. This Agreement is the contract which covers your and our rights and responsibilities concerning Online Banking ("Online
More informationPLEASE READ THESE TERMS AND CONDITIONS CAREFULLY BEFORE PARTICIPATING IN THE EVENT/ USING ANY EVENT PLATFORM.
TERMS AND CONDITIONS FOR THE NIKE BATTLE FORCE EVENT NIKE Philipinnes Inc. ( Nike ) in media partnership with Creative Programs, Inc. ( CPI ) is sponsoring a competition-based event designed to support
More informationNasdaq Nordic / Baltic Business Continuity Plan Description
Nasdaq Nordic / Baltic Business Continuity Plan Description This document is valid for the legal entities: Nasdaq Stockholm AB Nasdaq Copenhagen A/S Nasdaq Helsinki Ltd Nasdaq Iceland h.f. Nasdaq Tallinn
More informationAnti-Money Laundering and Counter Terrorism
1 Anti-Money Laundering and Counter Terrorism 1. INTRODUCTION SimpleFX Ltd. ( The Company ) aims to prevent, detect and not knowingly facilitate money laundering and terrorism financing activities. The
More informationHIPAA in the Digital Age. Anisa Kelley and Rachel Procopio Maryan Rawls Law Group Fairfax, Virginia
HIPAA in the Digital Age Anisa Kelley and Rachel Procopio Maryan Rawls Law Group Fairfax, Virginia Virginia MGMA reminds attendees that the program is not intended to provide legal advice and advises participants
More informationCamargo Investment Management, Ltd Fox Cub Lane Cincinnati, OH (513)
Firm Brochure (Part 2A of Form ADV) Item 1 Cover Page Camargo Investment Management, Ltd. 8497 Fox Cub Lane Cincinnati, OH 45243 (513) 936-5050 This brochure provides information about the qualifications
More informationCode of Ethics for Directors
Code of Ethics for Directors 2 Table of Contents 1. Introduction... 3 1.1. Application... 3 1.2. Following these principles... 3 1.3. Other requirements... 3 1.4. Waivers... 3 1.5. Revisions... 3 1.6.
More informationCyber Security Insurance Proposal Form
Cyber Security Insurance Proposal Form This proposal must be completed and signed by a Principal, Partner or Director of the Proposer. The person completing and signing the form should be authorised by
More informationHOSTED TELEPHONY SERVICE AGREEMENT
HOSTED TELEPHONY SERVICE AGREEMENT The Company is a supplier of hosted telephony services and the Client wishes that the Company provide those services to it. This Hosted Telephony Service Agreement ("Agreement")
More informationCyber ERM Proposal Form
Cyber ERM Proposal Form This document allows Chubb to gather the needed information to assess the risks related to the information systems of the prospective insured. Please note that completing this proposal
More informationHIPAA Privacy: PHI Disclosure Accounting (Changes) and Access Report (New)
Issue 2 2011 HIPAA Privacy: PHI Disclosure Accounting (Changes) and Access Report (New) The Office of Civil Rights (OCR) of the Department of Health and Human Services (HHS) issued new proposed privacy
More informationData Protection Agreement
Data Protection Agreement This Data Protection Agreement (the DPA ) becomes effective on May 25, 2018. The Customer shall make available to GURTAM and the Customer authorizes GURTAM to process information
More informationMacLean-Fogg Company Anti-Corruption Policy
MacLean-Fogg Company Anti-Corruption Policy EFFECTIVE DATE: October 1, 2017 OWNER: General Counsel POLICY NAME: MF-LC1.01-P-20171001-ANTICORRUPTION OUR STANDARD: Our position is clear: MacLean-Fogg is
More informationData Processing Appendix
Company Name* Execution Date *Company name indicated must conform to the name on customer s Master Subscription Agreement executed with SugarCRM. This Data Processing Appendix on the processing of personal
More informationD E B R A S C H U C H E R T, C O M P L I A N C E O F F I C E R
D E B R A S C H U C H E R T, C O M P L I A N C E O F F I C E R INTEGRATED CARE ALLIANCE, LLC CORPORATE COMPLIANCE PROGRAM It is the policy of Integrated Care Alliance to comply with all laws governing
More informationGuide to compliance with the Australian Privacy Principles. APP 1 Open and transparent management of personal information
Guide to compliance with the Australian Privacy Principles This guide provides a summary of each of the Australian Privacy Principles (APPs) prescribed under the Privacy Act 1988 (Cth), together with some
More informationCompliance with Laws (HR-685)
1.0 PURPOSE: All directors, officers, employees, agents, suppliers, and contractors of Microchip Technology Incorporated and its subsidiaries (Microchip Technology Incorporated and its subsidiaries together,
More informationTerms, Conditions and Limitations of Your Relationship with the Credit Union.
HERITAGE TRUST FEDERAL CREDIT UNION ONLINE SERVICES ON LINE BANKING AND BILL PAYMENT AGREEEMENT AND DISCLOSURE This Agreement is the contract which covers your and our rights and responsibilities concerning
More informationget cash withdrawals from savings account(s) with an ATM card get cash withdrawals from savings account(s) with a debit card
ELECTRONIC FUND TRANSFERS YOUR RIGHTS AND RESPONSIBILITIES Indicated below are types of Electronic Fund Transfers we are capable of handling, some of which may not apply to your account. Please read this
More informationWATTS WATER TECHNOLOGIES, INC.
WATTS WATER TECHNOLOGIES, INC. Code of Business Conduct and Ethics Introduction Purpose and Scope The Board of Directors of Watts Water Technologies, Inc. (the Company ) established this Code of Business
More informationIt is the policy of Citizens Deposit Bank & Trust to adhere to the following Privacy Policy.
It is the policy of Citizens Deposit Bank & Trust to adhere to the following Privacy Policy. Purpose and Objectives This policy reaffirms and formalizes our bank's realization of and respect for the privacy
More informationIT Data Destruction Risks vs. Rewards. Corey Dehmey Director of Sustainability AERC Recycling Solutions
IT Data Destruction Risks vs. Rewards Corey Dehmey Director of Sustainability AERC Recycling Solutions Overview What is IT Data Destruction Risks vs. Rewards Review of Data Destruction Methods Process
More informationEldorado Resorts, Inc. Code of Ethics and Business Conduct. The Code includes standards that are designed to deter wrongdoing and to promote:
Eldorado Resorts, Inc. Code of Ethics and Business Conduct This Code of Ethics and Business Conduct, which includes our Conflicts of Interest Policy attached as Exhibit A hereto (collectively, the Code
More informationWILLIAMS SCOTSMAN INTERNATIONAL, INC. CODE OF CONDUCT AND ETHICS
WILLIAMS SCOTSMAN INTERNATIONAL, INC. CODE OF CONDUCT AND ETHICS September 11, 2005 I. Introduction This Code of Conduct and Ethics ( Code ) provides a general statement of the expectations of Williams
More informationAWS GDPR DATA PROCESSING ADDENDUM
AWS GDPR DATA PROCESSING ADDENDUM This Data Processing Addendum ( DPA ) is an agreement between Amazon Web Services, Inc. ( AWS, we, us, or our ) and you or the entity you represent ( Customer, you or
More informationPrivacy and Data Breach Protection Modular application form
Instructions The Hiscox Technology, Privacy and Cyber Portfolio Policy may be purchased on an a-la-carte basis. Some organizations may require coverage for their technology errors and omissions, while
More informationEvanston Insurance Company Markel American Insurance Company Markel Insurance Company
Evanston Insurance Company Markel American Insurance Company Markel Insurance Company InfoPro SM APPLICATION FOR INFORMATION TECHNOLOGY PROFESSIONAL LIABILITY AND DATA BREACH AND PRIVACY LIABILITY, DATA
More informationAsset Manager Code of Professional Conduct. second edition
Asset Manager Code of Professional Conduct second edition 2009 2009 CFA Institute The mission of the CFA Institute Centre for Financial Market Integrity is to be a leading voice on issues of fairness,
More informationHIPAA Compliance Guide
This document provides an overview of the Health Insurance Portability and Accountability Act (HIPAA) compliance requirements. It covers the relevant legislation, required procedures, and ways that your
More informationYour Guide to Business Asset Protection
Your Guide to Business Asset Protection Imagine finding yourself on the wrong end of a costly judgment in a lawsuit. Or re-building your business after a destructive natural disaster. Potentially worse,
More informationUniversity Data Policies
BACKGROUND Data are valuable institutional assets of Washington State University. Data policies are needed to ensure that these resources are carefully managed, maintained, protected, and used appropriately.
More informationH 7789 S T A T E O F R H O D E I S L A N D
======== LC001 ======== 01 -- H S T A T E O F R H O D E I S L A N D IN GENERAL ASSEMBLY JANUARY SESSION, A.D. 01 A N A C T RELATING TO INSURANCE - INSURANCE DATA SECURITY ACT Introduced By: Representatives
More informationCRISP Portal Guide for Practices. CRISP Maryland s Health Information Exchange
CRISP Portal Guide for Practices CRISP Maryland s Health Information Exchange 1 Contents Introduction... 3 Particpitation Agreement FAQ... 4 Notice of Privacy Practice Sample... 12 Patient Education...
More informationFOUNDATIONS IN UNIVERSITY FINANCE FINANCIAL POLICIES
FOUNDATIONS IN UNIVERSITY FINANCE FINANCIAL POLICIES Financial Policies Anna Jensen University Chief Accountant Participant Outcomes Develop a general awareness of university policies and how to locate
More informationMastering the PCAOB's New Extensive Reporting Mandate on Firm Activities Preparing Now to Meet Annual and Special Disclosure Requirements
presents Mastering the PCAOB's New Extensive Reporting Mandate on Firm Activities Preparing Now to Meet Annual and Special Disclosure Requirements A Live 110-Minute Teleconference/Webinar with Interactive
More information