<consolidate roles between those imported and those in the original template>
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Policy
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Policy Owner: Principal Engineer
Effective Date: 2023-05-01
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This policy and associated guidance establish the roles and responsibilities within CloudCard, which is critical for the 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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The audience for this policy includes all CloudCard employees and contractors who are involved with the Information Security Program. Awareness of this policy applies for all other agents of CloudCard with access to 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 “CloudCard community”.
Future Expansion
Currently, CloudCard is a very small company, and its executive team is very small. Therefore many roles and responsibilities are currently aligned to a single job title. In the table below, multiple rows refer to a single job title, but define a specific sub-role in which that job title is acting. The table is structured in this way so that in future we can more easily realign roles that apply to a given function to a new executive job title when such title is established.
Roles and Responsibilities
Roles | Responsibilities |
Investors | 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 |
Chief Executive |
Officer | 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 |
Investors Aligns Information Security and Privacy Policy and Posture based on CloudCard’s mission, strategic objectives and risk appetite | |
Chief Executive Officer (Financial Oversight Role) | Responsible for oversight over third-party risk management process Responsible for review of vendor service contracts |
Chief Executive Officer (Human Resources Role) | 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 to the CoC is periodically evaluated Ensuring that employees receive appropriate security training Employee correction and review when the policy is not followed. |
Chief Executive Officer (Compliance Management Role) | 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 information security and data privacy standards and frameworks, including SOC 2. Responsible for the implementation of the Information Security Policy Responsible for annual review of all policies |
Principal Engineer | Provide guidance and advice on Information Security Policy design and implementation. Oversight of 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 |
Principal Engineer (IT |
Management Role) | 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 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 |
Investors, Law Enforcement, Internal Audit and General Counsel Oversight over Identity Management and Access Control processes |
VP of Engineering
Oversight |
, |
implementation, operation |
and monitoring of |
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 adoptedinformation security |
VP of Global Customer Support
tools and processes in |
production environments Execution of customer data retention and deletion processes in |
accordance with company policy and customer requirements |
Systems Owners
Principal Engineer (System Ownership Role) | Approval of technical access and change requests for non-standard access to |
all systems used and managed by CloudCard | |
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 |
persons 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
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.
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Participate in Annual review of relevant policies |
Policy Compliance
The Principal Engineer will measure the compliance to with this policy through various methods, including, but not limited to—reportsto, reports, internal/external audits, and feedback to the policy owner. Exceptions to the policy must be approved by the 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 | 2023-03-16 | First Version (incorporating roles and responsibilities from legacy Information Security Policy into SOC 2 Template) | Ryan Heathcote | Luke Rettstatt |
1.1 | 2024-07-16 | Policy renewal Spelling and grammar updates | Luke Rettstatt | Ryan Heathcote |