Last Updated at 2022-Jan-03
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: dataofficer@brainpayroll.co.uk
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 dataofficer@brainpayroll.co.uk.
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 2022-Jan-05
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 2022-Jan-07
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 |
Databas | 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 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 2022-Jan-10
BrainPayroll Security Policy Document encompasses all aspects of security, especially surrounding confidential payroll information. All company employees and contractors must understand this document in its entirety and sign the form confirming they have read and understood this policy fully. This document will be reviewed and updated by management on an annual basis 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.
The main purpose is to inform company’s all stakeholders about their obligatory requirements for protecting the technology and information assets of the company.
1.1 Security goals
BrainPayroll is committed to safeguarding the confidentiality, integrity, availability, and resilience of all physical and electronic information assets of the payroll data to ensure that regulatory, operational, and contractual requirements are fulfilled. The overall goals for the BrainPayroll security requirements are below:
1.2 Security Strategy
The 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, defense against damaging code and malicious activities, system and information access control, incident management and reporting.
The term security policy is related to the following concepts:
Most critical aspects supporting activities are availability and reliability for 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 actions to ensure software security. Development of code has been checked and validated with the most current versions of the Coding Standards for Secure Application Development. All developers verified that their code is in compliance with the most recent and approved coding standards and guidelines.
2.1 Protected Stored Data
All sensitive payroll data stored and handled protected against unauthorized use at all times. Any sensitive payroll data that is no longer required for business reasons will be discarded with an anonymized technique.
2.2 Protected Data in Transit
2.3 Disposal of Stored Data
2.4 Password Policy
2.5 Security Features
To protect the servers against network analysis attacks, the servers are secured as follows.
3.1 Antivirus
3.2 Patch Management Policy
Our components are updated automatically with the latest security fixes in the standard Microsoft patch cycle. Security patches have to be installed every second week of the month when it release from Microsoft.
All server components etc. have up-to-date system security patches installed to protect the asset from known vulnerabilities.
Firewall, NAS, switches, and other network components update with the latest firmware. Normally use the n-1 policy for firmware updates and prefer to use the most recent and stable version of the firmware.
3.3 Password Policy
Strong passwords on any accounts with access to Remote Desktop should be considered a required step before enabling Remote Desktop. Where possible passwords are generated using a password generation tool, which ensures that the password is difficult to remember and is stored at a secure file.
All users, including contractors and vendors with access to the systems, are responsible for taking the appropriate steps to select and secure their passwords.
2FA use to access critical devices, servers, and services access.
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 and external network vulnerability scans after any significant change in the network.
Vulnerability scans are performed by external staff periodically and the scan process has to include that rescans will be done until passing results are obtained.
3.5 Physical Security
3.6 Remote Access Policy
3.7 Network Policy
All our cloud servers are within the UK region. The data center is totally secure, highly resilient and designed to cope with all computing demands.
3.8 Firewall Policy
We maintain best resilience practices to minimize productivity hampering and data loss. We can recover from any damage to computer equipment or files within a reasonable period of time. 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 the cloud server or FTP and/or tape to ensure data recoverability in the event of accidental data deletion, corrupted information or some kind of a system outage. Backup data is stored in an off-site location and protected from physical damage.
Backup policies typically consist of capturing an initial full backup of data onto a disk and/or tape, followed by a series of intervening incremental or differential daily backups.
The backups are protected through 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 loss of data in the event of a fire, natural disaster, or system 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 the process to establish an SLA and continues throughout the life of the arrangement. The clients involved come together in order to understand each other’s needs, priorities and concerns, and to gain an insight into the problems which may be faced by each party through the failure of each party to fulfill their obligations.
The policies and procedures defined below should be incorporated into company practice to maintain a high level of security awareness. The protection of sensitive data needs regular training of 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 the Email / SMS alert for any potentially suspicious activity. Email / SMS 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 maintained for a minimum of 3 months. 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 different 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 is to ensure that changes proposed 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 risk calculator. The risk calculator defines the overall risk of classified changes.
The change roles are as follow:
Change Requester
Change Manager
Change Approver (CAB)
Change Implementer
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, environment modeling and workflow-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 allow for an increase in visibility for the whole team. It combines workload automation and release-management tools as they relate to release packages, as well as 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 that the code written by the development team 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
Build release
User acceptance testing
Prepare release
Deploy release
6.4 Emergency Release Process
In the case of emergency changes that 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, therefore it forces 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 follow:
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. Scope of information security includes the protection of the confidentiality, integrity, and availability of the information.
7.1 Roles and Responsibility
Access Control systems are in place to protect the interest of the company computer systems by providing a safe, secure, and readily accessible environment in which to work.
Access control systems perform identification authentication and authorization of users required login credentials which can include 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 authorization provided by the IT Services and system owner.
Access to The Company IT resources and services is a unique Active directory account and complex password.
Password issuing, strength requirements, and control are managed through the formal process. Password length, complexity and expiration times are controlled through Windows Active Directory Group Policy.
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
8.2 Data Scrambling
Data scrambling is the process to remove sensitive data. It is irreversible so that 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 performing within the SQL database.
Updated at 2022-Jan-12
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 dataofficer@brainpayroll.co.uk
In addition, the Policy requires maintenance of a process to help identify and act on security incidents quickly and effectively, including:
Last Updated at 2022-Jan-17
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.