Information Security Roles and Responsibilities Policy

Policy Owner: Principal Engineer

Effective Date: 2023-05-01

Statement of Policy

CloudCard is committed to conducting business in compliance with all applicable laws, regulations, and company policies. CloudCard has adopted this policy to outline the security measures required to protect electronic information systems and related equipment from unauthorized use.

Objective

This policy and associated guidance establish the roles and responsibilities within 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.

Applicability

This policy is applicable to all CloudCard infrastructure, network segments, systems, and employees and contractors who provide security and IT functions.

Audience

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”.

Roles and Responsibilities

Roles	Responsibilities
Board of Directors	Oversight of 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	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 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