Information Sensitivity, Security and Privacy Policy (ISSP Policy)

1.0       Purpose

The Information Sensitivity, Security and Privacy Policy is intended to help our employees, as well as our contractors, vendors and other individuals or business associates ('Interested Parties') with whom we do business and where such business may require access to personal or confidential information determine what information can be disclosed to non-employees, as well as the relative sensitivity of information that should not be disclosed outside of Innovative Technologies ('Company') without proper authorization, and to outline the data security and privacy policies to be adhered to.

The information covered in these guidelines includes, but is not limited to, information that is either stored or shared via any means. This includes: electronic information, information on paper, and information shared orally or visually (such as telephone and video conferencing).

All Interested Parties should familiarize themselves with this policy. It should be noted that the sensitivity level definitions were created as guidelines and to emphasize common sense steps that you can take to protect Innovative Technologies' Confidential Information and client personal information (e.g., Innovative Technologies Confidential information should not be left unattended in conference rooms, client policies or claims should not be left in a fax machine in public areas, etc.).

Please Note: The impact of these guidelines on daily activity should be minimal.

Questions about the proper classification of a specific piece of information should be addressed to your manager. Questions about these guidelines should be addressed to the PPO.

2.0       Scope

All Innovative Technologies information is categorized into two main classifications:

  • Innovative Technologies Public
  • Innovative Technologies Confidential

Innovative Technologies Public information is information that has been declared public knowledge by someone with the authority to do so, and can freely be given to anyone without any possible damage to Innovative Technologies

Innovative Technologies Confidential contains all other information. It is a continuum, in that it is understood that some information is more sensitive than other information, and should be protected in a more secure manner. Included is information that should be protected very closely, such as individual client records, client account numbers and other personal identification information that, when taken together make known the individuals' identity by usual, customary and reasonable ('UCR') means,  Company's trade secrets, development programs, potential acquisition targets, and other information integral to the success of our company. Also included in Innovative Technologies Confidential is information that is less critical, such as telephone directories, general corporate information, personnel information, etc., which does not require as stringent a degree of protection.

A subset of Innovative Technologies Confidential information is "Innovative Technologies Third Party Confidential" information. This is confidential information belonging or pertaining to another corporation which has been entrusted to Innovative Technologies by that company under non-disclosure agreements and other contracts. Examples of this type of information include everything from joint development efforts to vendor lists, customer record or orders, and supplier information. Information in this category ranges from extremely sensitive to information about the fact that we've connected a supplier / vendor into Innovative Technologies’ network to support our operations.

Innovative Technologies personnel are encouraged to use common sense judgment in securing Innovative Technologies Confidential information to the proper extent. If an employee is uncertain of the sensitivity of a particular piece of information, he/she should contact their manager

3.0       Policy

The Sensitivity Guidelines below provides details on how to protect information at varying sensitivity levels. Use these guidelines as a reference only, as Innovative Technologies Confidential information in each column may necessitate more or less stringent measures of protection depending upon the circumstances and the nature of the Innovative Technologies Confidential information in question.

3.1       Minimal Sensitivity: General corporate information; some personnel and technical information

Marking guidelines for information in hardcopy or electronic form.

Note: any of these markings may be used with the additional annotation of "3rd Party Confidential".

Marking is at the discretion of the owner or custodian of the information. If marking is desired, the words "Innovative Technologies Confidential" may be written or designated in a conspicuous place on or in the information in question. Other labels that may be used include "Innovative Technologies Proprietary" or similar labels at the discretion of your individual business unit or department. Even if no marking is present, Innovative Technologies information is presumed to be "Innovative Technologies Confidential" unless expressly determined to be Innovative Technologies Public information by a Innovative Technologies employee with authority to do so.

Access:  Innovative Technologies employees, contractors, people with a business need to know.

Distribution within Innovative Technologies:  Standard interoffice mail, approved electronic mail and electronic file transmission methods.

Distribution outside of Innovative Technologies internal mail:  U.S. mail and other public or private carriers, approved electronic mail and electronic file transmission methods.

Electronic distribution:  No restrictions except that it be sent to only approved recipients.

Storage:  Keep from view of unauthorized people; erase whiteboards, do not leave in view on tabletop. Machines should be administered with security in mind. Protect from loss; electronic information should have individual access controls where possible and appropriate.

Disposal/Destruction:  Deposit outdated paper information in specially marked disposal bins on Innovative Technologies premises; electronic data should be expunged/cleared. Reliably erase or physically destroy media.

Penalty for deliberate or inadvertent disclosure:  Up to and including termination, possible civil and/or criminal prosecution to the full extent of the law.

3.2       More Sensitive: Business, financial, technical, and most personnel information

Marking guidelines for information in hardcopy or electronic form.

Note: any of these markings may be used with the additional annotation of "3rd Party Confidential". As the sensitivity level of the information increases, you may, in addition or instead of marking the information "Innovative Technologies Confidential" or "Innovative Technologies Proprietary", wish to label the information "Innovative Technologies Internal Use Only" or other similar labels at the discretion of your individual business unit or department to denote a more sensitive level of information. However, marking is discretionary at all times.

Access:  Innovative Technologies employees and non-employees with signed non-disclosure agreements who have a business need to know.

Distribution within Innovative Technologies:  Standard interoffice mail, approved electronic mail and electronic file transmission methods.

Distribution outside of Innovative Technologies internal mail:  Sent via U.S. mail or approved private carriers.

Electronic distribution:  No restrictions to approved recipients within Innovative Technologies, but should be encrypted or sent via a private link to approved recipients outside of Innovative Technologies premises.

Storage: Individual access controls are highly recommended for electronic information.

Disposal/Destruction:  In specially marked disposal bins on Innovative Technologies premises; electronic data should be expunged/cleared. Reliably erase or physically destroy media.

Penalty for deliberate or inadvertent disclosure:  Up to and including termination, possible civil and/or criminal prosecution to the full extent of the law.

3.3       Most Sensitive: Medical records, Social Security numbers, Customer account numbers, Data groupings where identity can be determined through UCR measures, trade secrets & marketing, operational, personnel, financial, source code, & technical information integral to the success of our company

Marking guidelines for information in hardcopy or electronic form.

Note: any of these markings may be used with the additional annotation of "3rd Party Confidential". To indicate that Innovative Technologies Confidential information is very sensitive, you may should label the information "Innovative Technologies Internal: Registered and Restricted", "Innovative Technologies Eyes Only", "Innovative Technologies Confidential" or similar labels at the discretion of your individual business unit or department. Once again, this type of Innovative Technologies Confidential information need not be marked, but users should be aware that this information is very sensitive and be protected as such.

Access:  Only those individuals (Innovative Technologies employees and non-employees) designated with approved access and signed non-disclosure agreements.

Distribution within Innovative Technologies:  Due to overlapping responsibilities requiring companywide access, internal distribution controls are not applicable.

Distribution outside of Innovative Technologies internal mail:  Delivered direct; signature required; approved private carriers.

Electronic distribution:  No restrictions to approved recipients within Innovative Technologies, but it is highly recommended that all information be strongly encrypted.

Storage:  Individual access controls are very highly recommended for electronic information. Physical security is generally used, and information should be stored in a physically secured computer.

Disposal/Destruction:  Strongly Encouraged: In specially marked disposal bins on Innovative Technologies premises; electronic data should be expunged/cleared. Reliably erase or physically destroy media.

Penalty for deliberate or inadvertent disclosure:  Up to and including termination, possible civil and/or criminal prosecution to the full extent of the law.

4.0       Enforcement

Any employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment.

5.0       Training, Review and Preparation

Innovative Technologies understands that all privacy and security are, ultimately subjected to human error.  To maximize privacy and security controls and compliance, Innovative Technologies will conduct workforce privacy awareness for all employees and Interested Parties. This includes training of all new workforce members including management, volunteers and Interest Parties in privacy and security procedures and requirements, as well as the enforcement policies that envelope them.

Any amendments or changes to the policies and procedures herein will be distributed to all employees and Interested Parties as appropriate and training provided where needed.  Such distribution will be acknowledged by the receiving party.

Semi-annually, Innovative Technologies will distribute some or all of these policies as a reminder of our commitment to privacy and security.  The receiving parties will acknowledge receipt and acceptance of such distribution as a demonstration of their similar commitment.

Annually, Innovative Technologies will perform a Vulnerability Assessment to identify any privacy or security risks and vulnerabilities, and take appropriate action to mitigate.  When mitigation demands policy or procedural amendments, such will be made and disseminated.

At least every  year, Innovative Technologies will perform a Risk to identify any vulnerabilities, and take appropriate action to mitigate.  When mitigation demands policy or procedural amendments, such will be made and disseminated.

Any changes to the company structure or infrastructure will also initiate Risk and Vulnerability Assessments.

Innovative Technologies believes that transparency, ultimately is the greatest measure of adherence to privacy and security policies and procedures.  Therefore, any and all actions pertaining hereto will be documented and made available to appropriate, authorized parties.

7.0       Revision History