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Security Policies and Procedures <br />C. Maintaining this document <br />This document must be reviewed at least once a year or anytime there are significant <br />changes in software or security. Updates must be made to keep it in accord with Virtru's <br />overall business goals and risk position. The document will be reviewed by the ISO or <br />AISO. Any updates, improvements or suggestions should be sent to the ISO. <br />V. Roles and Responsibilities <br />A. Rules for ownership of information <br />The information and systems provided by Virtru to workforce members, contractors and <br />representatives are owned by Virtru, which also determines appropriate usage and access <br />rules. All data on Virtru's systems and networks is owned by Virtru, with the exception of <br />software that the ISO has approved to be open sourced or otherwise transferred to another <br />entity through code escrow or code exchange and/or trade. <br />In this document, the words 'information owner' refer to the person who owns the <br />responsibility for the information. The information itself remains the property of Virtru. <br />B. Information users <br />Every user of Virtru's information must protect that information and ensure that it is used <br />for Virtru's business purposes only. Any incidents or questionable issues in the security of <br />our information must be reported to the ISO or AISO. <br />Information users may not assign access rights, authorize destruction or copying of <br />information, or change the protections given to information assets. Information users must <br />comply with all laws, regulations and Virtru's policies and procedures. <br />C. Information Security Officer <br />Virtru's ISO and AISO will: <br />1. Manage awareness programs relating to security and privacy topics <br />2. Maintain a central record of exceptions to this Standards document <br />3. Manage changes to this Standards document <br />4. Provide leadership relating to new security risks, controls and technologies <br />5. Oversee and approve the sharing and reuse of Personal Identifiable <br />Information (PII) collected by or processed by the company <br />See Appendices for further information and Information Security Committee for a current <br />listing of members. <br />Rev.2015.8.6 <br />15 <br />