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This Vanta policy template represents a complete, compliance-ready policy with placeholders for company specific text. Each policy section represents a policy-specific topic that you should consider and/or modify to match your company’s practices.
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A good rule-of-thumb is to keep your language high enough level such that it stays representative for at least a year. If you have more questions about how to use this template, please reach out to support@vanta.com or your auditor for additional guidance.<import the original text>
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Information Security Roles and Responsibilities Policy
Policy Owner: <Policy owner>Principal Engineer
Effective Date: <Effective date>2023-05-01
Statement of Policy
<Company Name> CloudCard is committed to conducting business in compliance with all applicable laws, regulations, and company policies. <Company Name> CloudCard has adopted this policy to outline the security measures required to protect electronic information systems and related equipment from unauthorized use.
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This policy and associated guidance establish the roles and responsibilities within <Company Name>CloudCard, 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.
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This policy is applicable to all <Company Name> CloudCard infrastructure, network segments, systems, and employees and contractors who provide security and IT functions.
Audience
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The audience for this policy includes all <Company Name> CloudCard employees and contractors who are involved with the Information Security Program. Awareness of this policy applies for all other agents of <Company Name> CloudCard with access to <Company Name> CloudCard 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 “<Company Name> “CloudCard community”.
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Roles and Responsibilities
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Roles | Responsibilities |
Board of Directors | Oversightof Cyber-Risk and internal control for information security, privacy and compliance Consults with Executive Leadership to understand |
CloudCard 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 |
CloudCard Board of Directors Aligns Information Security and Privacy Policy and Posture based on |
CloudCard’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 |
CloudCard’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 Counsel 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 Manager3 | 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 |
CloudCard policies on information security and privacy Approval of technical access and change requests for non-standard access to systems under their control |
CloudCard 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 |
CloudCard’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 |
CFO | Responsible for oversight over third-party risk management process Responsible for review of vendor service contracts |
(legacy) Employees | Participation in the Annual review of the Information Security Policy Participation in the Annual review of the Business Continuity Plan Participation in the Annual review of the Disaster Recovery Plan Participation in the Annual review of the Data Breach Response Plan Reporting all information vulnerabilities or threats to Managing Director |
(legacy) Managing Director |
Policy Compliance
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Responsible for implementation of the Information Security Policy Annual review of the Information Security Policy Annual review of the Business Continuity Plan Annual review of the Disaster Recovery Plan Annual review of the Data Breach Response Plan Employee correction and review when the policy is not followed. | |
(legacy) Product Owner | Oversee maintenance of the Information Security Policy - direct reposnibility for providing guidance and advice on its implementation. Systems are adequately protected from unauthorised access. Systems are secured against theft and damage to a level that is cost-effective. Adequate steps are taken to ensure the availability of the information system, commensurate with its importance (Business Continuity). Electronic data can be recovered in the event of loss of the primary source. I.e. failure or loss of a computer system. It is incumbent on all system owners to backup data and to be able to restore data to a level commensurate with its importance (see Disaster Recovery Plan). Data is maintained with a high degree of accuracy. Systems are used for their intended purpose and that procedures are in place to rectify discovered or notified misuse. Any electronic access logs are only retained for a justifiable period to ensure compliance with the data protection, investigatory powers and freedom of information acts. Any third parties entrusted with CloudCard data understand their responsibilities with respect to maintaining its security. Perform and document risk assessments on an annual basis. Web server access and error logs are reviewed for anomalies that could indicate a compromise. |
Policy Compliance
The Principal Engineer 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> Principal Engineer 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.
Version | Date | Description | Author | Approved by |
1. |
0 |
2023- |
03- |
<First Version>
<OWNER>
<APPROVER>
1 All fields in this document marked by angled brackets < > and highlighted must be filled in.
2 Customize for your organization. Roles and responsibilities can be assigned however it makes sense for your company.
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16 | First Version (incorporating roles and responsibilities from legacy Information Security Policy into SOC 2 Template) | Ryan Heathcote | Luke Rettstatt |