Last Updated at 2024-Jan-10
This policy establishes an effective, accountable, and transparent framework for ensuring compliance with the requirements of the GDPR.
This policy applies to all BrainPayroll employees and all third parties responsible for the processing of personal data on behalf of BrainPayroll services/entities. The content of this policy also applies to our processors and sub processors globally.
BrainPayroll is committed to conducting its business in accordance with all applicable data protection laws and regulations and in line with the highest standards of ethical conduct.
This policy sets forth the expected behaviors of BrainPayroll employees and third parties in relation to the collection, use, retention, transfer, disclosure and destruction of any personal data belonging to BrainPayroll contact (i.e. the data subject).
Personal data is any information (including opinions and intentions) which relates to an identified or identifiable natural person. Personal data is subject to certain legal safeguards and other regulations, which impose restrictions on how organization may process personal data. Our client collect data from data controller or data subjects and give us for process so as an organization that process on personal data known as a Data Processor or Data Sub-Processor. BrainPayroll, as a Data Sub Processor, is responsible for ensuring compliance with the data protection requirements outlined in this policy. Non-compliance may expose BrainPayroll to complaints, regulatory action, fines and/or reputational damage. BrainPayroll, as a Data Sub-Processor is responsible for ensuring compliance with the requirements of the Data Controller and with the data protection requirements outlined in this policy. Non-compliance may expose BrainPayroll to complaints, regulatory action, fines and/or reputational damage.
BrainPayroll’s leadership is fully committed to ensuring continued and effective implementation of this policy and expects all BrainPayroll employees and third parties to share in this commitment. Any breach of this policy will be taken seriously and may result in disciplinary action or business sanction.
3.1.1 Data Protection Officer
To demonstrate our commitment to data protection, and to enhance the effectiveness of our compliance efforts, BrainPayroll has appointed a Data Protection Officer. The Data Protection Officer operates with independence and is supported by suitability skilled individuals granted all necessary authority. The Data Protection Officer works with and reports to Management Team. The Data Protection Officer’s duties include:
Ensuring establishment of procedures and standard contractual provisions for obtaining compliance with this Policy deficiencies any third party who:
3.1.2 Data Protection by Design
To ensure that all data protection requirements are identified and addressed when designing new systems or processes or services and/or when reviewing or expanding existing systems or processes or services, each of them must go through an approval process before continuing. Each BrainPayroll service/entity must ensure that a Data Protection Impact Assessment (DPIA) is conducted, in cooperation with the Data Protection Officer, for all new and/or revised systems or processes for which it has responsibility. The subsequent findings of the DPIA must then be submitted to the Data Privacy Team for review and approval. Where applicable, the any third-party Information Technology (IT) contractors, as part of BrainPayroll’s IT system and application design review process, will cooperate with the Data Protection Officer to assess the impact of any new technology uses on the security of personal data.
3.1.3 Compliance Monitoring
To confirm that an adequate level of compliance that is being achieved by all BrainPayroll services/entities in relation to this policy, the Data Protection Officer will carry out an annual data protection compliance audit for all such services/entities. Each audit will, as a minimum, assess:
Compliance with policy in relation to the protection of personal data, including:
BrainPayroll has adopted the following principles to govern its collection, use, retention, transfer, disclosure, and destruction of personal data:
Principle 1: Lawfulness, Fairness and Transparency. Personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject. This means, BrainPayroll must tell the data subject what processing will occur (transparency), the processing must match the description given to the data subject (fairness), and it must be for one of the purposes specified in the applicable data protection regulation (lawfulness).
Principle 2: Purpose Limitation. Personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. This means BrainPayroll must specify exactly what the personal data collected will be used for and limit the processing of that personal data to only what is necessary to meet the specified purpose.
Principle 3: Data Minimisation.Personal data shall be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed. This means BrainPayroll must not store any personal data beyond what is strictly required.
Principle 4: Accuracy. Personal data shall be accurate and, kept up to date. This means BrainPayroll must have in place processes for identifying and addressing out-of-date, incorrect, and redundant personal data.
Principle 5: Storage Limitation.Personal data shall be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. This means BrainPayroll must, wherever possible, store personal data in a way that limits or prevents identification of the data subject.
Principle 6: Integrity & Confidentiality.Personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing, and against accidental loss, destruction or damage. BrainPayroll must use appropriate technical and organisational measures to ensure the integrity and confidentiality of personal data is maintained at all times.
Principle 7: Accountability. The Data Processor shall be responsible for and be able to demonstrate compliance. This means BrainPayroll must demonstrate that the six data protection principles (outlined above) are met for all personal data for which it is responsible
3.3.1 Data Sources
Personal data should be collected only from the data collector or data processor unless one of the following apply:
If personal data is collected from someone other than the data subject, the data subject must be informed of the collection unless one of the following apply:
Where it has been determined that notification to a data subject is required, notification should occur promptly, but in no case later than:
3.3.2 Data Subject Consent
Each BrainPayroll service/entity will obtain personal data only by lawful and fair means and, where appropriate with the knowledge and consent of the individual concerned. Where a need exists to request and receive the consent of an individual prior to the collection, use or disclosure of their personal data, BrainPayroll is committed to seeking such consent. The Data Protection Officer, in cooperation with other relevant business representatives, shall establish a system for obtaining and documenting data subject consent for the collection, processing, and/or transfer of their personal data.
3.3.3 Data Subject Notification
Each BrainPayroll service/entity will, when required by applicable law or contract, or where it considers that it is reasonably appropriate to do so, provide data subjects with information as to the purpose of the processing of their personal data. When the data subject is asked to give consent to the processing of personal data and when any personal data is collected from the data subject, all appropriate disclosures will be made, in a manner that draws attention to them, unless one of the following apply:
3.3.4 External Privacy Notices
Each external website provided by BrainPayroll will include an online ‘Privacy Notice’ and an online ‘Cookie Notice’ fulfilling the requirements of applicable law.
3.4.1 Data Processing
BrainPayroll uses the personal data of its contacts for the following broad purposes:
The use of a contact’s information should always be considered from their perspective and whether the use will be within their expectations or if they are likely to object. For example, it would clearly be within a contact’s expectations that their details will be used by BrainPayroll to respond to a contact request for information about the products and services on offer. However, it will not be within their reasonable expectations that BrainPayroll would then provide their details to third parties for marketing purposes.
3.4.2 Special Categories of Data
BrainPayroll will only process special categories of data (also known as sensitive data) where the data subject expressly consents to such processing or where one of the following conditions apply:
In any situation where, special categories of data are to be processed, prior approval must be obtained from the Data Protection Officer, and the basis for the processing clearly recorded with the personal data in question. Where special categories of data are being processed, BrainPayroll will adopt additional protection measures.
3.4.3 Children’s Data
Children under the age of 16 are unable to consent to the processing of personal data for information society services (any service normally provided for payment, by electronic means and at the individual request of a recipient of services). Consent must be sought from the person who holds parental responsibility over the child. However, it should be noted that where processing is lawful under other grounds, consent need not be obtained from the child or the holder of parental responsibility.
3.4.4 Data Quality
Each BrainPayroll service/entity will adopt all necessary measures to ensure that the personal data it collects, and processes is complete and accurate in the first instance and is updated to reflect the current situation of the data subject. The measures adopted by BrainPayroll to ensure data quality include:
3.4.5 Digital Marketing
As a rule, BrainPayroll will not send promotional or direct marketing material to BrainPayroll contact through digital channels such as mobile phones, email, and the Internet, without first obtaining their consent. Any BrainPayroll service/entity wishing to carry out a digital marketing campaign without obtaining prior Consent from the data subject must first have it approved by the Data Protection Officer. Where personal data (e.g. case studies or photographs) processing is approved for digital marketing purposes, the data subject must be informed at the point of first contact that they have the right to object, at any stage, to having their data processed for such purposes. If the data subject puts forward an objection, digital marketing related processing of their personal data must cease immediately, and their details should be kept on a suppression list with a record of their opt-out decision, rather than being completely deleted. It should be noted that where digital marketing is carried out in a ‘business to business’ context, there is no legal requirement to obtain an indication of Consent to carry out digital marketing to individuals provided that they are given the opportunity to opt-out.
To ensure fair processing, personal data will not be retained by BrainPayroll for longer than necessary in relation to the purposes for which it was originally collected, or for which it was further processed. The length of time for which BrainPayroll services/entities need to retain personal data is set out in BrainPayroll’s ‘Data Retention Policy’. This considers the legal and contractual requirements, both minimum and maximum, that influence the retention periods set forth in the schedule. All personal data should be deleted or destroyed as soon as possible where it has been confirmed that there is no longer a need to retain it.
Each BrainPayroll service/entity will adopt physical, technical, and organisational measures to ensure the security of personal data. This includes the prevention of loss or damage, unauthorised alteration, access or processing, and other risks to which it may be exposed by virtue of human action or the physical or natural environment. A summary of the personal data related security measures is provided below:
The Data Protection Officer will establish a system to enable and facilitate the exercise of data subject rights related to:
BrainPayroll will consider each such request in accordance with all applicable data protection laws and regulations. No administration fee will be charged for considering and/or complying with such a request unless the request is deemed to be unnecessary or excessive in nature. data subjects are entitled to obtain, based upon a request made in writing/email to: [email protected]
It should be noted that situations may arise where providing the information requested by a data subject would disclose personal data about another individual. In such cases, information must be redacted or withheld as may be necessary or appropriate to protect that person’s rights. Detailed guidance for dealing with requests from data subjects can be found in BrainPayroll’s ‘Data Subject Access Rights Policy and Procedure’ document.
In certain circumstances, it is permitted that personal data be shared without the knowledge or consent of a data subject. This is the case where the disclosure of the personal data is necessary for any of the
following purposes:
If BrainPayroll service/entity processes personal data for one of these purposes, then it may apply an exception to the processing rules outlined in this policy but only to the extent that not doing so would be likely to prejudice the case in question. If any BrainPayroll service/entity receives a request from a court or any regulatory or law enforcement authority for information relating to BrainPayroll contact, you must immediately notify the Data Protection Officer who will provide comprehensive guidance and assistance.
All BrainPayroll employees that have access to personal data will have their responsibilities under this policy outlined to them as part of their staff induction training. In addition, each BrainPayroll service/entity will receive regular Data Protection training and procedural guidance.
BrainPayroll services/Entities processing to be carried out on behalf of controller or another data processor. the controller shall use only processors providing sufficient guarantees to implement appropriate technical and organisational measures in such a manner that processing will meet the requirements of this Regulation and ensure the protection of the rights of the data subject.
BrainPayroll shall not engage another processor without prior specific or general written authorisation of the controller. In the case of general written authorisation, BrainPayroll shall inform the controller of any intended changes concerning the addition or replacement of other processors, thereby giving the controller the opportunity to object to such changes.
Processing by BrainPayroll shall be governed by contract or other legal act under union or member state law, that is binding on the BrainPayroll with regards to the controller and that sets out the subject-matter duration of processing, the nature and purpose of the processing, the type of personal data and categories of data subjects and obligations and right of the controller.
BrainPayroll and any person acting under the authority of the BrainPayroll, who has access to personal data, shall not process those data except on instructions from the controller, unless required to do so by Union or Member State law.
BrainPayroll services/entities may transfer personal data to internal or third-party recipients located in another country where that country is recognised as having an adequate level of legal protection for the rights and freedoms of the relevant data subjects. Where transfers need to be made to countries lacking an adequate level of legal protection (i.e. third countries), they must be made in compliance with an approved transfer mechanism. BrainPayroll services/entities may only transfer personal data where one of the transfer scenarios list below applies:
Data subjects with a complaint about the processing of their personal data, should put forward the matter in writing to the Data Protection Officer. An investigation of the complaint will be carried out to the extent that is appropriate based on the merits of the specific case. The Data Protection Officer will inform the data subject of the progress and the outcome of the complaint within a reasonable period. If the issue cannot be resolved through consultation between the data subject and the Data Protection Officer, then the data subject may, at their option, seek redress through mediation, binding arbitration, litigation, or via complaint to the Data Protection Authority within the applicable jurisdiction.
Any individual who suspects that a personal data breach has occurred due to the theft or exposure of personal data must immediately notify the Data Protection Officer providing a description of what occurred. Notification of the incident can be made via e-mail, by calling, or by using the independent Information Commissioner Office (ICO) Data Concern line. The Data Protection Officer will investigate all reported incidents to confirm whether or not a personal data breach has occurred. If a personal data breach is confirmed, the Data Protection Officer will follow the relevant BrainPayroll ‘Data Breach Notification Policy and Procedure’ based on the criticality and quantity of the personal data involved. For severe personal data breaches, BrainPayroll’s Data Privacy Team will initiate and chair an emergency response time to coordinate and manage the personal data breach response.
The management team and senior staff of each BrainPayroll service/entity must ensure that all BrainPayroll employees responsible for the processing of personal data are aware of and comply with the contents of this policy. In addition, each BrainPayroll’s service/entity will make sure all third parties engaged to process personal data on their behalf are aware of and comply with the contents of this policy. Assurance of such compliance must be obtained from all third parties, whether companies or individuals, prior to granting them access to personal data controlled by BrainPayroll.
4.2 Support, Advice and Communication
For advice and support in relation to this policy, please contact to [email protected].
This policy will be reviewed by the Data Protection Officer every year, unless there are any changes to regulations or legislation that would enable a review earlier.
Last Updated at 2024-Jan-12
The purpose of this policy to ensure that customer data should not disclose to any government/public authority and third party until unless it’s necessary according to GDPR.
This policy applies to all BrainPayroll employees and all third parties responsible for the processing of personal data on behalf of BrainPayroll services/entities. The content of this policy also applies to our processors and sub processors globally.
BrainPayroll receives requests from government agencies, users and other third parties to disclose data other than in the ordinary operation and provision of the Services. This Data Request Policy outlines BrainPayroll’s policies and procedures for responding to such requests for Customer Data. Any capitalised terms used in this Data Request Policy that are not defined will have the meaning set out in the Customer Terms of Service. In the event of any inconsistency between the provisions of this Data Request Policy and the Customer Terms of Service or written agreement with the Customer, as the case may be, the Customer Terms of Service or written agreement will prevail.
Third parties seeking Customer Data should contact the Customer regarding such requests. The Customer controls the Customer Data and generally has the right to decide what to do with all Customer Data.
BrainPayroll is committed to the importance of trust and transparency for the benefit of our customers. Except as expressly permitted by the Contract or as described in this policy, BrainPayroll will only disclose Customer Data in response to valid legal process. BrainPayroll requires a search warrant issued by a court of competent jurisdiction or the equivalent legal process in the applicable jurisdiction to disclose the contents of Customer Data. BrainPayroll does not voluntarily disclose any data to government entities unless: (a) there is an emergency involving imminent danger of death or serious physical injury to any person, or (b) to prevent harm to the Services or Customers. BrainPayroll also does not voluntarily provide governments with access to any data about users for surveillance purposes.
If a request concerns personal information for which a customer is the controller, BrainPayroll will ordinarily ask the Requesting Authority to make the Data Disclosure Request directly to the relevant Customer. If the Requesting Authority agrees, BrainPayroll will support the Customer in accordance with the terms of its contract to respond to the Data Disclosure Request.
Unless BrainPayroll is prohibited from doing so or there is a clear indication of illegal conduct or risk of harm, BrainPayroll will notify the Customer of the request before disclosing any of the Customer’s Data so that the Customer may seek legal remedies.
If BrainPayroll is legally prohibited from notifying the Customer prior to disclosure, BrainPayroll will take reasonable steps to notify the Customer of the demand after the non-disclosure requirement expires. In addition, if BrainPayroll receives legal process subject to an indefinite non-disclosure requirement, BrainPayroll will challenge that non-disclosure requirement in court.
BrainPayroll requires that any individual or entity issuing legal process or legal information requests (e.g. discovery requests, warrants or subpoenas) ensure that the process or request is properly domesticated. For data stored in the United Kingdom, BrainPayroll does not accept legal process or requests directly from law enforcement entities outside the UK or EEA. Foreign law enforcement agencies seeking data stored within the UK should proceed through a mutual legal assistance treaty or other diplomatic or legal means to obtain data through a court where BrainPayroll is located.
Last Updated at 2024-Jan-18
This Policy sets out the type(s) of personal data held by the Company, the period(s) for which that personal data is to be retained, the criteria for establishing and reviewing such period(s), and when and how it is to be deleted or otherwise disposed of.
This policy applies to all persons within the Company (meaning permanent, fixed term, temporary staff and sub-contractors engaged with the Company). Adherence to this policy is mandatory and non-compliance could lead to disciplinary or contractual action.
This policy sets out the obligations of “Brain Payroll UK Limited” (hereinafter referred to as the "Company") regarding retention of personal data collected, held, and processed by the Company in accordance with General Data Protection Regulation ("GDPR").
The GDPR defines "personal data" as any information relating to an identified or identifiable natural person (a "data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. The Company only ever retains records and information for legitimate or legal business reasons and always complies fully with EU data protection laws, guidance and best practice.
The GDPR impose obligations on the Company, as a Data Processor, to process personal data in a fair manner which notifies data subjects of the purposes of data processing and to retain the data for no longer than is necessary to achieve those purposes.
Summary of the Company's objectives and principles in relation to Data Retention are as follows:
Heads of departments and information asset owners have overall responsibility for the management of records and data generated by their departments' activities, namely to ensure Records Retention Policy that the records created, received and controlled within the purview of their department, and the systems (electronic or otherwise) and procedures they adopt, are managed in a way which meets the aims of this policy.
Where a DPO has been designated, they must be involved in any data retention processes and records or all archiving and destructions must be retained. Individual employees must ensure that the records for which they are responsible are complete and accurate records of their activities, and that they are maintained and disposed of in accordance with the Company's protocols.
Data Type | Retention Period | Why is it collected | Who can access | Security | Final Disposition |
---|---|---|---|---|---|
PII (Excel, word, pdf files) | One month | Payroll Process | Data Processing Team | Stored on encrypted location and Password protected | Secure deletion |
Database | NA | Debugging purpose | Development Team | Access though SQL Management studio | Remove the access immediately after purpose completion |
Masked Database for production issue. | According to debugging time | Debugging purpose | Development Team | Data mask and download only after client’s approval. Download only on secure location by IT team, Access allows to developer team on password protected system. | Secure deletion |
Data Type | Retention Period | Why is it collected | Who can access | Security | Final Disposition |
---|---|---|---|---|---|
Payroll application audit logs | 3 years | For investigation of incidents with third external application. | Production support team | Stored in database at UK server. | Secure deletion |
Data Type | Retention Period | Why is it collected | Who can access | Security | Final Disposition |
---|---|---|---|---|---|
Incident Records and Evidence | 3 years | Minimize the impact on business operations | Compliance officer and management | Stored in lockable filing cabinet – CS own access to files If stored as e-copy; access will be password protected |
Confidential shredding OR Safe/secure deletion |
Last Updated at 2024-Jan-04
BrainPayroll Security Policy Document encompasses all security aspects, especially confidential payroll information. All company employees and contractors must understand this document and sign the form confirming they have read and understood this policy thoroughly. This document will be reviewed and updated by management annually or, when relevant, to include newly developed security standards into the policy and distribute it to all employees and contracts as applicable.
This Security Policy is a formal set of rules by which
all stakeholders who are given access to the Company's technology
and
information assets must abide by.
The primary purpose is to inform Company's all stakeholders about their obligatory requirements for protecting its technology and information assets.
1.1 Security goals
BrainPayroll is committed to safeguarding the confidentiality, integrity, availability, and resilience of all payroll data's physical and electronic information assets to ensure that regulatory, operational, and contractual requirements are fulfilled. The overall goals for the BrainPayroll security requirements are below:
1.2 Security Strategy
Current business strategy and framework for risk management are the guidelines for identifying, assessing, evaluating, and controlling information-related risks through establishing and maintaining the security policy (this document).
It has been decided that information security is to be ensured by the policy for information security and a set of underlying and supplemental documents. In order to secure operations at BrainPayroll even after serious incidents, we ensure the availability of continuity plans, backup procedures, defence against harmful code and malicious activities, system and information access control, incident management and reporting.
The term security policy is related to the following concepts:
Confidentiality:
Information is
not made available or disclosed to unauthorized individuals, entities, or processes.
Integrity:
It is
safeguarding the accuracy and completeness of the information and IT assets.
Availability:
It is
accessible and usable upon demand by an authorized entity.
The most critical aspects supporting activities are the availability and reliability of network, infrastructure, and services. We practice openness and principles of public disclosure, but in certain situations, we prioritize confidentiality over availability and integrity.
The Secure Application development policy is a plan of action to guide developers' decisions and measures to ensure software security. Code development has been checked and validated with the most current versions of the coding Standards for Secure Application Development. All developers verified that their code complied with the most recent and approved coding standards and guidelines.
We ensure code security by doing a vulnerability scan before the production release. Any bug or vulnerability must fix before release, and the green VAPT report is part of change management.
Third-party open libraries with the application are reviewed and scanned for vulnerability; the green scan report is part of change management.
Public-facing application is protected with Web application firewall (WAF) configured according to OWASP's top ten security controls to protect application from Broken authentication, SQL injection, Cross-site scripting, etc. Additionally, it protects the application from DDOS and bot attacks.
2.1 Protected Stored Data
All sensitive payroll data stored and handled is protected against unauthorized use. Any sensitive payroll data that is no longer required for business reasons will be discarded with an anonymized technique.
Data in rest is protected with required security controls.
2.2 Protected Data in Transit
a) All sensitive payroll data is protected if it is to
be transported physically or electronically. Payroll data never be sent over the
internet via email (except when initiated by customers/end users for support of live
issues), instant chat or any other end-user technologies.
b) Suppose there is a
business justification for payroll data via email, the internet, or other modes. In
that case, it will be done after authorization and by using the best possible
security and encryption mechanism (i.e., SSL, TLS, etc.).
c) The transportation
of media containing sensitive payroll data to another location needs to be
authorized by management, logged, and inventoried.
d) We separated internal
network communications within departments by network VLAN security.
e)
Identified the BrainPayroll data, services and servers and allowed access of it by
VDI solution only.
f) Screen share, data download to the local machine and
local to VDI copy past are blocked.
g) Email security is maintained using a
white-listing domain. Users can send emails only to authorized domains.
h)
Teams' communication is maintained using the white-listing domain.
i) Remote
user access was assigned through SSL Secure VPN.
2.3 Disposal of Stored Data
a) All data will be securely disposed of when no longer
required by the Company, regardless of the media or application type on which it is
stored.
b) All hard copies of payroll data must be manually destroyed as when
no longer required for valid and justified business reasons. A quarterly process is
in place to confirm that all non-electronic payroll data has been appropriately
disposed of in a timely manner.
c) The application allows the user to delete
their own data. This operation is known as hard delete, which removes data from the
database.
d) We can delete or archive data from the system if we receive a
request from the subject.
e) All payroll data on electronic media will be
rendered unrecoverable when deleted.
f) All payroll data awaiting destruction
will be held in lockable storage containers.
g) Any data user processing by
downloading in the local environment is wiped within 24 hours.
2.4 Password Policy
a) All users with access to payroll data have a unique
ID.
b) All users use a username and password to access the payroll data or
other electronic resources.
c) A unique password must be set up for new users,
who are prompted to change the password on the first login.
d) The password
expiry feature is available within the system. The default password expiration
policy is 90 days.
e) The process of selecting a password is complex. A strong
password will be:
2.5 Security Features
a) Data is transferred using web API, which is highly
secured with TLS V1.2 communication protocol with token-based authentication.
Whenever any data request comes from outside, it first checks the token, and if it
is valid, only the request will be processed. The token is generated when the user
logs in.
b) Our applications run on SSL certificates, the most secure way to
communicate between the server and the client. SSL Certificate initiates a secure
session with browsers. Once a secure connection is established, all web traffic
between the web server and the web browser will be secure.
c) Token uses the
JWT concept, the most secure way to generate the token. (https://jwt.io/)
d)
For an external user like an employee user, we are using a dedicated API for
external users, which returns employee-related data. This will eliminate the risk of
getting access to data exposed by other APIs.
e) We are using "Token Based
Authentication", so data cannot be accessed without authentication.
f) If the
token has been tampered with, the login will expire, and the user must log in
again.
g) We are using an entity framework for database activity, which is
highly protected against SQL Injection.
h) The string used to connect the
database is encrypted, which cannot be exposed.
i) We use stored procedures to
fetch data, so SQL queries are not exposed when client-server communication
happens.
j) Archive data will keep data in the system, but it will not be
visible or accessible to any other users.
The servers are secured; To protect the servers
against network analysis attacks following controls are in place.
3.1 Antivirus
a) We are using market-leading Antivirus Security which
is being updated automatically.
b) Protects enterprises against the full
spectrum of sophisticated cyber threats with speed and accuracy. It is a layered
next-gen architecture that delivers prevention, detection, remediation, and
visibility in a single modular platform.
c) To effectively protect from highly
sophisticated cyber-attacks that evade conventional endpoint security tools, a
layered defence approach with multi-stage signature-less technologies, including
advanced machine learning, behavioural analysis, anti-exploit, and integrated
sandbox.
d) Antivirus software detects all known types of malicious software
(Viruses, Trojans, adware, spyware, worms and rootkits). All removable media (for
example, USB) should be scanned for viruses before use. End users cannot modify any
settings or alter the antivirus software.
3.2 Patch Management Policy
Our components are updated automatically with the latest security fixes in the standard Microsoft patch cycle. Security patches must be installed every second week of the month when it is released from Microsoft.
All server components have up-to-date system security patches installed to protect the asset from known vulnerabilities.
The latest firmware updates the firewall, NAS, switches, and other network components. Usually use the n-1 policy for firmware updates and prefer to use the most recent and stable version.
3.3 Password Policy
Strong passwords on any accounts with access to Remote Desktop should be considered a required step before enabling remote desktops. Where possible, passwords are generated using a password generation tool, which ensures that the password is difficult to remember and is stored in a secure file.
All users, including contractors and vendors with access to the systems, are responsible for selecting and securing their passwords.
2FA is used to access critical devices, servers, and services like production servers, Application support access, Office365 global admins, AWS accounts, etc.
3.4 Vulnerability Management Policy
All the vulnerabilities would be assigned a risk ranking such as High, Medium, and Low based on industry best practices.
We run internal infra VAPT quarterly and at the time of major changes in IT infrastructure.
Brain Application VAPT testing is done by an external
Third-party yearly and during major code changes.
We do the code scanning
before every production release and fix the bug and vulnerabilities before release.
Code VAPT green report is part of the change and release management.
Third-party open library use in an application is scanned before every production release, and fix the bug and vulnerabilities before release. Third-party open library VAPT green report is part of the change and release management.
VAPT result of any scan is shared with responsible stakeholders who review the report and mitigate the vulnerability.
We use JIRA as a vulnerability management tool to create JIRA for each vulnerability and assign it to a responsible team member.
3.5 Physical Security
a) We have restricted servers from any other storage
media. So, no external devices can be attached to the system until we allow
it.
b) Configured servers to not auto-run content from removable media such as
USB tokens, drives and DVDs, etc
c) Server-room access is prohibited for
non-authorize users. The finger base access system is configured on the server-room
entrance.
d) UPS and DG systems are available to run all servers and desktops
for a couple of hours in case of power failure.
e) Required cooling environment
maintained in server-room for 24*7 by using multiple air conditions.
f) The
cloud server is hosted with market-leading service providers.
g) We have
required SLA and agreements with the hosting provider for uptime and troubleshooting
issues.
h) We ensure that the hosting provider complies with the required
certificates for the security of servers and follows proper ITSM.
i) Server
hardening is in place according to the hardening server policy.
j) Our data
processing team is seated in a separate cabin protected with a finger-based access
control system, Metal detector and security guard.
k) No one can enter with a
mobile phone or any other digital equipment in the data processing room.
3.6 Remote Access Policy
a) Secure remote access (RDP) is strictly controlled.
Control is enforced by two-factor authentication. Only authenticated users can
access the system with permission via 2FA.
b) The servers can only be accessed
through SSL VPN.
c) The server only runs network services, protocols and ports
necessary to achieve its business requirements.
d) Client/Vendor accounts with
access to the server will only be enabled when the access is required and will be
disabled or removed once access is no longer necessary.
e) Assign only require
permission from the VPN user. Users can access only their system or assigned
services. All other device access is prohibited.
3.7 Network Policy
All our cloud servers are within the UK region. The data centre is secure, highly resilient and designed to handle all computing demands.
a) Arbor DDoS protection is applied across the data
centre network. When potential threats are detected, traffic is redirected through
the Arbor solution, stripping out harmful attack traffic and allowing only
legitimate traffic through.
b) Our cloud provider's UK data centres are ISO
9001, ISO 27001, ISO 22301 and PCI DSS compliant. In fact, with an impressive number
of global certifications, we're proud to say we are using a server from the UK's
most accredited cloud company.
c) All unnecessary services, protocols, ports,
etc., have been disabled.
d) Interconnectivity
3.8 Firewall Policy
a. No direct connections from the internet to the
payroll data environment will be permitted. All traffic must traverse through a
firewall.
b. The firewall rules will be reviewed periodically to ensure
validity, and the firewall will have a clean-up rule at the bottom of the rule
base.
c. The web-based restriction is configured to access any websites, only
allowed websites or categories are accessible.
d. Email notifications of
receiving security reports, unauthorised access or malicious activity logs
daily.
e. SSL VPN is configured to give resources access out of the office in
special conditions.
f. DDOS attacks are monitored and prevented from the
firewall.
We maintain best resilience practices to minimize
productivity hampers and data loss. We can recover from any damage to computer
equipment or files within a reasonable period. Each entity is required to develop
and maintain a plan for responding to a system emergency or other occurrence (for
example, fire, system failure and natural disaster) that damages systems. This will
include developing policies and procedures to address the following.
4.1 Data Backup Plan
A backup policy is a pre-defined, set schedule whereby information from business applications. Backup for user files is uploaded to NAS, cloud server or FTP to ensure data recoverability in the event of accidental data deletion, corrupted information or some system outage. Backup data is stored in an off-site location and protected from physical damage.
Backup policies typically capture an initial full data backup onto a disk and cloud, followed by a series of intervening incremental or differential daily backups.
The backups are protected through encryption, and strong passwords and backups are uploaded securely to the cloud server.
4.2 Disaster Recovery Plan
A disaster recovery plan has been developed, which contains a process enabling the entity to restore any data loss in the event of a fire, natural disaster, cyber security incident or system failure.
We have pre-defined RTO & RPO with the customer in case of any application component failure.
4.3 SLA (Service Level Agreement)
The SLA is a contract between parties that defines the services provided, the indicators associated with these services, acceptable and unacceptable service levels, liabilities on the part of the service provider and the customer, and actions to be taken in specific circumstances.
There are certain objectives for SLA:
We facilitate
two-way communication between clients. This communication starts at the beginning of
establishing an SLA and continues throughout the life of the arrangement. The
clients involved come together to understand each other's needs, priorities and
concerns and to gain an insight into the problems each party may face through the
failure of each party to fulfil their obligations.
The policies and procedures defined below should
be incorporated into company practice to maintain high-security awareness. The
protection of sensitive data needs regular training for all employees and
contractors.
Review handling procedures for sensitive data and hold
periodic security awareness meetings to incorporate these procedures into day-to-day
practice. Distribute this security policy document to all employees/clients to
read.
Maintaining a formal security awareness program for all employees that
provide multiple methods of communicating awareness and educating employees
(training, meetings, documentation, etc.)
The awareness training includes
Security Awareness Training, GDPR information, Secure coding guideline etc.
5.1 Audit and Log review:
The audit and Log review procedure cover all logs generated for systems within the payroll data environment, including the following components:
The IT team has configured an email alert for any potentially suspicious activity. An email will be sent for the alerts to the related team's mailbox with a summary of the incident. The related team also receives details of email alerts for informational purposes.
Audit Logs were maintained for six months on hot storage and three years on cold storage. The authorized person can only be permitted to access log files.
Release management is the process of managing,
planning, scheduling, and controlling a software build through different
environments and life cycles, including testing and deploying software releases.
6.1 Change Roles
Changes to the application are managed and executed according to a formal change control process. The control process ensures that proposed changes are reviewed, authorized, implemented, and released in a controlled manner; and that the status of each proposed change is monitored.
The change control process is formally defined and documented. This documented process includes change management responsibilities and a change request form. The change request form contains change-related details and a risk calculator. The risk calculator defines the overall risk of classified changes.
The change roles are as follows:
6.2 Release Automation
Deploying a software package to the production environment is fully automated. Release Automation refers to the process of packaging and deploying an application or update of an application from development across various environments, and ultimately to production.
Having the ability to deliver a high-quality application rapidly and safely is its most important competitive differentiator. By exploring and implementing deployment automation options, DevOps and continuous delivery teams are better able to build, test, and deliver reliable applications more quickly.
Automation tool helps cultivate DevOps best practices by providing a combination of automation, and environment.
modeling and work-flow-management capabilities. These
practices help teams deliver software rapidly, reliably, and responsibly. Automated
tools achieve a key DevOps goal of implementing continuous delivery with a large
number
of releases quickly.
Automated tools deploy applications using structured release-automation techniques that increase visibility for the whole team. It combines workload automation and release-management tools related to release packages and movement through different environments within the DevOps pipeline.
Automated tools help regulate deployments, how environments are created and deployed, and how and when releases are deployed.
6.3 Standard Release Process
The release process ensures the code the development team writes is built on a build server using the build tool. Once the testing of the built package is completed and passed, it can be deployed in environments for testing or live usage. The Release process is a critical bridge between Development and Testing/Production.
There are five primary steps to the release process as follow:
Release planning
1.
The planning stage may be the most time-intensive as this is where the entire
release is structured from start to finish.
2. A robust release plan helps to
stay on track and ensures standards and requirements are properly met.
3. The
release plan includes timelines, delivery dates, requirements and the project's
overall scope.
We have created a release process checklist to map out a plan
and clarify the process. The checklist outlines the process functions and
responsibilities in roughly chronological order.
4. When the team looks at the
checklist, they quickly establish what step they are on and what their role and
responsibility are.
5. Once the plan is approved and finalized, it can be
implemented by respected leaders.
Build
release
1. With the release plan finalized, developers start
designing and building for release. It is the actual "development" of the
application based on the requirements outlined in the release plan.
2. Once all
the issues that may have come up are addressed, subject the build to real-world
scenario testing.
3. This takes several iterations. As the team builds out the
product, it is sent (usually automatically) to a testing environment for user
acceptance. This allows the team to identify any bugs or issues in a live
environment.
4. The build is sent back for development at stage two as issues
are identified. In other words, within the iterative release management process, the
work may flow from stage two to stage three and back again until the release is
approved.
User acceptance testing
1. User
acceptance testing, also known as UAT, is when the end-users or clients start
testing and give valuable feedback. This is often done as a free beta trial online
or shared with a larger group of employees.
2. User acceptance testing is the
most crucial step to release management because of the data collected and fixes
required to get the build to where it needs to be for the official launch.
3.
The build must pass through the UAT stage to be considered for final implementation
and release.
Prepare release
1. This step is
to put the finishing touches on the product. Release preparation also includes a
final quality review
2. During the review, the QA team will conduct final
checks to ensure the build meets the minimum acceptable standards and business
requirements outlined in the release plan.
3. Although UAT and quality
assurance can't always replicate every scenario that might occur once the product by
the QA team is launched, these steps hopefully fleshed out the most common bugs so
that team can better anticipate and prevent any problems at launch.
4. Once the
review is completed, the functional team will validate the findings and finalize the
release for deployment. Before the build can deploy into a live environment, it must
be approved by the respected leader.
Deploy
release
1. This step is to release the application into the
production environment.
2. For instance, users get notified of changes with the
release and how to operate within the new features.
3. Finally, during the
deployment stage, the development team meet to assess the release's performance
and
discuss how the deployment went.
4. If there are any lingering issues,
those should be identified and documented for the team to address in the next
iteration.
6.4 Emergency Release Process
In the case of emergency changes which have to be dealt with by Release Planning, this general rule should never be violated: "No matter how urgent a release is, it has to pass through Release Management". It is usually done for a quick fix for a problem or known error.
Compared to Standard Release, the main difference of an Emergency Release is that it is not planned before and needs to be implemented urgently. Therefore, it requires reduced testing efforts. Often the necessary testing, documentation and monitoring agents cannot be assigned. Finally, an emergency release is not planned within overall Release Planning, forcing a change in the overall planning. An Emergency Release is managed in line with the Emergency Change activities.
The main activities in the Emergency release are as
follows:
1. Description of the content of the emergency release.
2. At
least basic testing of the release (including component and integration
testing).
3. Documentation of the emergency release.
6.5 Source Control
Source control is the practice of tracking and managing changes to the code. Source control management (SCM) systems provide a running history of code development and help to resolve conflicts when merging contributions from multiple sources.
SCM tool allows and encourages to have multiple local branches that can be entirely independent of each other.
Given one or more existing commits, revert the changes that the related patches introduce, and record some new commits that record them. This requires your working tree to be clean (no modifications from the HEAD commit).
The scope defines part of the project planning and
lists the project goals, tasks, costs, deliverables, and project deadlines. It
requires input from the project stakeholders, who, together with project managers,
establish the key elements and budget. The scope of information security includes
the protection of the confidentiality, integrity, and availability of the
information.
7.1 Roles and Responsibility
a) Chief Information Security Officer (CISO) is the high-level executive directly responsible for an organization's security function. CISOs are responsible for their organization's physical security needs and their digital or electronic security requirements, including computer networks.
Maintaining a formal security awareness program for all employees that provide multiple methods of communicating awareness and educating employees (for example, posters, letters, and meetings).
b) System Administrator manages user accounts and authentication, maintains a service provider list, monitors system performance, and manages backup and recovery policy.
Administrator maintaining a clean and enjoyable working environment, handling external or internal communication. The administrator manages the office activities and operations to secure efficiency and compliance with company policies.
c) The service provider provides a solution and service within our scope of work. The service provider makes suggestions and opportunities or changes needed within the organization.
d) Quality Assurance (QA) is responsible for enhancing the application quality by guaranteeing the system's integrity, confidentiality, and availability.
e) Employees are responsible for keeping a complete privacy application or program that guarantees compliance with privacy needs, developing and analysing privacy policies and handling privacy risks.
f) Change Manager is responsible for the proper execution of the change management process, whose mission is to change the request status, lead the review board, coordinate changes and make an activity report. The change Manager is also responsible for authorizing and approving Major/Minor changes in the application or program.
g) CAB (Change Advisory Board) is a group that supports the assessment, prioritization, authorization and scheduling of changes.
h) End User is anyone authorized to read, create, and update information from the application and program.
i) Contractor is a business owner themselves or belongs to a vendor organization. Typically, you pay them for the completed tasks once the work is completed. Their business is to provide certain skills for another business that doesn't have the expertise or time to do those skills themselves.
Access Control systems are in place to protect the
interest of the company's computer systems by providing a safe, secure, and readily
accessible environment in which to work.
Access control systems authenticate and authorise users' required login credentials, including passwords, personal identification numbers, security tokens or other authentication factors.
Multifactor authentication requires two or more authentication factors to protect access control systems.
The privilege rights (e.g. domain and local administrator, super-user and root access) are restricted, and the IT Services and system owner provide authorization.
Access to The Company IT resources and services is a unique Active directory account and a complex password.
Password issuing, strength requirements, and control are managed through the formal process. Windows Active Directory Group Policy controls password length, complexity, and expiration times.
Access to confidential, Restricted and Protected information is limited to authorized persons whose job responsibilities require it. Request for access permission to be granted, changed, or revoked must be made in writing.
Access control methods include login access rights, Windows share and NFTS permission, user account privileges, server and workstation access rights, firewall permission, IIS server rights and SQL database rights as necessary.
8.1 Access Server for Support
1. Access to the application servers is granted to the
corporate network.
2. The application server is accessible only on-premises
networks through a dedicated server.
3. The application server automatically
disconnected after five minutes of inactivity.
4. We are using 2FA (Two-factor
authentication) via one-time password authentication or public/private keys with
strong passphrases for the Live server.
5. Users cannot copy and paste any data
from the Local machine to the Live server.
8.2 Data Scrambling
Data scrambling is the process of removing sensitive data. It is irreversible, so data cannot be derived from the scrambled data.
The configuration process begins with the DBA defining the attributes and mapping them to database columns. Then they collect attributes together to define policies and policy sets. All these steps are part of the data scrambling configuration and are performed within the SQL database.
Last Updated at 2024-Jan-20
The IT Security Information Breach Notification Policy defines the minimum requirements and responsibilities for reporting security incidents to minimize the negative impact on the confidentiality, integrity, and availability of BrainPayroll Information and systems.
This policy applies to all BrainPayroll employees and all third parties responsible for the processing of personal data on behalf of BrainPayroll services/entities. The content of this policy also applies to our processors and sub processors globally.
This Policy requires all individuals with access to BrainPayroll Resources and Information to immediately report any suspected or actual security incidents to [email protected]
In addition, the Policy requires maintenance of a process to help identify and act on security incidents quickly and effectively, including:
Last Updated at 2024-Feb-02
This Acceptable Usage Policy covers the security and use of all Brain Payroll information and IT equipment. It also includes the use of email, internet, voice and mobile IT equipment. This policy applies to all Brain Payroll’s employees, contractors and agents (hereafter referred to as ‘individuals’).
This policy applies to all information, in whatever form, relating to Brain Payroll business activities, and to all information handled by Brain Payroll relating to other organizations with whom it deals. It also covers all IT and information communications facilities operated by Brain Payroll or on its behalf.
Computer Access Control – Individual’s Responsibility
Access to the IT systems is controlled using User IDs, passwords and/or tokens. All User IDs and passwords are to be uniquely assigned to named individuals and consequently, individuals are accountable for all actions on the Brain Payroll IT systems.
Individuals must not:
Respective managers must ensure that individuals are given clear direction on the extent and limits of their authority regarding IT systems and data.
Internet and Email Conditions of Use
Use of Brain Payroll internet and email is intended for business use. Personal use is permitted where such use does not affect the individual’s business performance, is not detrimental to Brain Payroll in any way, not in breach of any term and condition of employment and does not place the individual or Brain Payroll in breach of statutory or other legal obligations.
All individuals are accountable for their actions on the internet and email systems.
Individuals must not:
Social media applications must be accessed only for business use and as per project requirements. The afore-mentioned internet usage best practices guidelines apply for social media access as well.
Clear Desk and Clear Screen Policy
To reduce the risk of unauthorized access or loss of information, Brain Payroll enforces a clear desk and screen policy as follows:
Working Off-Site
It is accepted that laptops and mobile devices will be taken off-site. The following controls must be applied:
Mobile Storage Devices
Mobile devices such as memory sticks, CDs, DVDs and removable hard drives must be used only in situations when network connectivity is unavailable or there is no other secure method of transferring data. Only Brain Payroll authorized mobile storage devices with encryption enabled must be used, when transferring sensitive or confidential data.
Software
Employees must use only software that is authorized by Brain Payroll on Brain Payroll computers. Authorized software must be used in accordance with the software supplier's licensing agreements. All software on Brain Payroll computers must be approved and installed by the Brain Payroll IT department.
Individuals must not:
Viruses
The IT department has implemented automated virus detection and virus software updates within the limits. All PCs have antivirus software installed to detect and remove any virus automatically.
Individuals must not:
Telephony (Voice) Equipment Conditions of Use
Use of Brain Payroll invoice equipment is intended for business use. Individuals must not use voice facilities for sending or receiving private communications on personal matters, except in exceptional circumstances. All non-urgent personal communications should be made at an individual’s own expense using alternative means of communications.
Individuals must not:
Actions upon Termination of Contract
All Brain Payroll equipment and data, for example laptops and mobile devices including telephones, smartphones, USB memory devices and CDs/DVDs, must be returned to Brain Payroll. All Brain Payroll data or intellectual property developed or gained during the period of employment remains the property of Brain Payroll and must not be retained beyond termination or reused for any other purpose.
Monitoring and Filtering
All data that is created and stored on Brain Payroll computers is the property of Brain Payroll and there is no official provision for individual data privacy, however wherever possible Brain Payroll will avoid opening personal emails.
IT system logging will take place where appropriate, and investigations will be commenced where reasonable suspicion exists of a breach of this or any other policy. Brain Payroll has the right (under certain conditions) to monitor activity on its systems, including internet and email use, to ensure systems security and effective operation, and to protect against misuse.
Any monitoring will be carried out in accordance with audited, controlled internal processes.
It is user’s responsibility to report suspected breaches of security policy without delay to their line management, the IT department, the information security department or the IT helpdesk. All breaches of information security policies will be investigated. Where investigations reveal misconduct, disciplinary action may follow in line with Brain Payroll disciplinary procedures.