|
Technical And Organisational Measures
|
|
KLDiscovery shall take all prudent and recognised steps to ensure the security of the Personal Data it receives, processes, transfers, transmits, stores, delivers, and/or otherwise accesses from Clients (“Information Security Program”).
|
|
Definitions
“Resource” means all KLDiscovery devices, including but not limited to laptops, PCs, routers, servers, and other computer systems that store, process, transfer, transmit, deliver or otherwise access the Personal Data.
|
|
Information Security Program
KLDiscovery will maintain a comprehensive Information Security Program that contains administrative, technical, and physical safeguards appropriate to the complexity, nature, and scope of its activities, and the sensitivity of its information assets. Such safeguards will include the elements set forth below and will be reasonably designed to: (1) Achieve the security and confidentiality of Personal Data; (2) Protect against any anticipated threats or hazards to the security or integrity of Personal Data; (3) Protect against unauthorised access to or use of Personal Data that could result in substantial harm or inconvenience to Client; and (4) Provide assurances to Client of the ongoing effectiveness of controls.
|
|
Security Requirements
Information Security Policies and Governance
KLDiscovery’s Information Security Program will be consistent with the practices described in ISO 27001 and this Security Requirements Document. As part of the management of its Information Security Program, KLDiscovery will use a senior management forum to review and approve all new policies and changes to existing policies. A formal process will be used by KLDiscovery to manage risk by identifying, approving and managing those situations where compliance with its Information Security Program is not obtained.
|
|
Information Stewardship
KLDiscovery will designate information owners who are responsible for information assets under their control, including Personal Data. Specific requirements for transmission, disclosure, storage, and destruction will address the entire lifecycle of Personal Data. KLDiscovery will assign a systems owner for each Resource. The systems owner has the overall responsibility to ensure compliance with security controls including the maintenance of the equipment and patch level to support the confidentiality, availability and integrity of Personal Data.
|
|
Confidentiality and Integrity
KLDiscovery will utilise a managed approach to security to ensure that Personal Data is protected through the entire life cycle, from creation, transformation and use, storage and destruction regardless of the storage media. Specific controls will be implemented according to the classification of the Personal Data to protect the confidentiality and integrity of the Personal Data. Control components will be used to specify access control requirements, encryption, labelling and disclosure for both internal and external parties, shipping and handling, and destruction.
|
|
Vulnerability Management
Firewalls, routers, servers, PC’s, and all other Resources will be kept as current as possible with appropriate security-specific system patches. KLDiscovery will perform regular penetration tests to be completed by independent third parties to further assess KLDiscovery’s security preparedness. KLDiscovery will perform regular tests of its Resources to detect any known vulnerabilities (patch management, port scanning, virus scanning, etc.). All major technologies will be configured to best practice standards to remove unnecessary services and other configuration options that can subject the Resources to unnecessary risk. KLDiscovery will maintain a schedule for remediation for all vulnerability criticalities and ensure that vulnerabilities that are high or critical in nature are addressed in a reasonable time frame.
|
|
Physical Security
A security function will exist to grant, adjust and revoke physical access to facilities where Personal Data resides or can be accessed.
|
|
Exterior Physical Controls
The exterior of each KLDiscovery facility will be physically secure to prevent the public from unauthorised entry. No signs outside the facility will show that Personal Data is processed or stored at the facility. Exterior doors will be alarmed to warn when unauthorised entry occurs. Exterior doors will close automatically. Where appropriate, perimeter fences/gates will be in place and secured.
|
|
Interior Physical Controls
Assigned KLDiscovery personnel will be identified with a uniquely assigned badge. All badging systems will have a logging mechanism that will identify the individual, timestamp and door or area accessed. Interior physical security controls also include visitor management, clean desk practices, fire detection and suppression systems, incident response procedures, controlled access, security lighting, and other measures designed to protect personnel and assets.
|
|
Destruction of Personal Data
All Personal Data will be destroyed from any media, whether hard copy, magnetic, optical or any other form, before disposing of such media: (a) on or about the premises by assigned staff using commercially available shredding devices, software, or other means; or (b) by a reputable third-party shredding service.
|
|
Logging and Monitoring
Audit logs will capture access to Personal Data, new user additions, attempts to change security configuration, system start up, back up, shut down, and invalid login attempts. Audit logs will be retained in a protected state and will be reviewed regularly in an automated or manual fashion and retained for at least 90 days.
|
|
Intrusion Detection and Prevention
KLDiscovery will use security measures to protect the KLDiscovery telecommunications system and any computer system or network device that KLDiscovery uses to provide services to Client to reduce the risk of infiltration, hacking, access penetration by or exposure to a third-party by: (a) protecting against intrusions; (b) securing the computer systems and network devices; and, (c) protecting against intrusions of operating systems or software. Processes and procedures will be established for responding to security violations and unusual or suspicious events and incidents to limit further damage to information assets and to permit identification and prosecution of violators. KLDiscovery will report actual security violations or incidents that impact Client to Client.
|
|
Malware Defense
KLDiscovery will use the following computer malware detection/scanning services and procedures: a) prior to sending any data, files or other material and/or accessing or submitting the same (singularly or collectively “Data Sending”), implement and maintain commercially available computer virus detection; b) upon detecting a computer virus or other malware that has affected or will affect client, notify Client and immediately cease Data Sending and do not resume the same until the computer virus or malware has been eliminated or contained to the satisfaction of Client; and, c) install and use such computer virus detection/scanning on all Data Sending mechanisms as well as at any other points directed by Client. KLDiscovery will keep all anti-virus software up-to-date by installing new definition files when made available by the anti-virus supplier.
|
|
Segregation of Duties
KLDiscovery maintains controls designed to provide adequate segregation of duties among KLDiscovery personnel, including access to systems and networks. Duties are assigned in such a manner that a person will not have the opportunity to conceal their errors or irregularities. Segregation of duties shall be maintained among and/or within the following functions: computer operations, network management, system administration, development, change management, security administration and family members.
|
|
Encryption and Public Key Infrastructure
All Personal Data will be encrypted when in storage, unless Client-approved compensating controls are implemented. Laptop computers will not store Personal Data unless Client agrees there is a business need for such storage. If agreement is reached, Personal Data on laptops will be encrypted. KLDiscovery’s Information Security Office will approve all cryptographic devices, algorithms, key lengths, and key management systems to ensure adherence to industry standards and interoperability. KLDiscovery will maintain commercially available encryption key management systems to protect encryption keys against unauthorised use or disclosure.
|
|
Network Security
KLDiscovery will provide the following data communication security services: (a) safeguard the confidentiality and integrity of all data being transmitted over any form of data network; and (b) implement and maintain strong industry standard encryption techniques for all cases in which data identified as Personal Data is transmitted over any public data network. A minimum of 256-bit key encryption is preferred. KLDiscovery’s Internet connections will be protected with dedicated, industry-recognised firewalls that are configured and managed to adhere to industry best practices. No internal or private Internet Protocol (IP) addresses will be publicly available or natively routed to the Internet. All administrative access to firewalls and servers will be through a secure internal network only.
|
|
Identification, Authentication and Authorisation
Each user of any Resource will have a uniquely assigned user ID to enable individual authentication and accountability. Each Resource will authenticate the user prior to granting each authorised access. The level of authentication required for access to any Resource is proportionate to the sensitivity of the data housed on the Resource. Access to privileged accounts will be restricted to only those people who administer the Resource; individual accountability will be maintained. All default passwords (such as those from hardware or software vendors) will be changed immediately upon receipt. KLDiscovery will use and comply with the following access control services and procedures: (a) implement measures to restrict electronic access to Resources to only authorised personnel; (b) ensure that all KLDiscovery personnel who access or submit material to Resources are uniquely identified to and authenticated by the Resource (KLDiscovery will not use any form of generic or shared user identifier to access Personal Data); (c) enforce the principle of “least privilege,” namely, that authorised personnel have only the level of access to Resources required to perform their job functions in relation to the Resource and have such rights and privileges for the shortest length of time necessary; (d) restrict access to all Personal Data stored on backup media, in hardcopy form or in any other format to only those employees who require such access to accomplish their job functions in performance of services for Client and store such data in a physically secure location; and (e) remove physical and logical access rights immediately upon termination or transfer of the individual. KLDiscovery’s Resources will store Personal Data in a segregated and controlled manner from KLDiscovery’s other customers’ information.
|
|
User Passwords and Accounts
User passwords will: (a) remain confidential and will not be shared, posted, or otherwise divulged in any manner; (b) consist of a minimum of eight (8) alpha and numeric characters for standard user accounts; (c) not contain the account name or account ID or other easily guessed values; (d) not allow the previous five passwords to be reused; and (e) be hashed in storage and transmission. User accounts will automatically lockout after five (5) consecutive incorrect attempts.
|
|
Third-party Relationships
KLDiscovery will conduct security risk assessments of any third-party service providers with access to Personal Data. The purpose of the security risk assessments will be to ensure that safeguards are sufficient to protect the Personal Data. Furthermore, KLDiscovery’s contracts with such third-party service providers will ensure that the service providers maintain controls to ensure that any individual with physical or logical access to Personal Data have safeguards similar to those set forth in this Security Requirement Document to ensure the protection of the Personal Data.
|
|
Remote Access Connection Authorization
All remote access connections to KLDiscovery internal networks and/or computer systems will require authorization and will provide an approved means of access control at the “point of entry” to the KLDiscovery computing or communication resources through multi-factor authentication. Such access will use secure access channels, such as a Virtual Private Network (VPN). KLDiscovery networks that have access to the Personal Data will be logically isolated from any other network segments that allow wireless access.
|
|
Secure System Development
Applications developed by KLDiscovery for Client will follow a methodology that allows for: (i) defining security requirements as part of the requirements definition phase; (ii) using a design model that incorporates best practices in security; (iii) developing code in ways that minimise security vulnerabilities (such as cross-site scripting, SQL injection, buffer overflows, etc.); (iv) testing the code through static and dynamic assessments; and (v) deploying the application is a secure production environment.
|
|
Personnel Security
All KLDiscovery personnel must pass a criminal background check and general background investigation. KLDiscovery shall not be required to screen any individual where it is prohibited by law.
|
|
Training and Awareness
KLDiscovery shall require all KLDiscovery personnel to participate in training and awareness sessions at least annually. The training system will track attendance and provide testing to ensure the materials are understood.
|
|
Continuity and Disaster Recovery
KLDiscovery requires that all applications hosted on behalf of clients to have a formal, documented, approved, and tested disaster recovery plan. All continuity plans must be communicated and approved by formal management and audited at least annually by an internal or third-party auditing body. All continuity plans are tested annually to verify their effectiveness and suitability with all aspects of the testing being documented including overall results and lessons learned. Results of tests are communicated to senior management.
|