Schedule C of the EFGI intra-group Data Sharing Framework Agreement (TOMs)
Schedule C
The technical and organisational measures are those described in the following General Directives:
- POL 500-001, Information Security Policy
- GD 11 01 001, Organization of Information Security
- GD 11 02 001, Acceptable Use of ICT Assets and Services
- GD 11 03 001, Information Access Control
- GD 11 04 001, Software and Application Security
- GD 11 05 001, Information System Implementation
and are at least the following:
Control of physical access to the premises and equipment used for data processing
Objective: prevent unauthorised access to the premises and equipment used for/in data processing
- Anti-intrusion system (locked rooms, security alarm)
- Backup power supply to guarantee security of physical devices
- Authentication mechanism when entering premises (badge, key, etc.)
- Badge with specific access authorisation
- Procedure on the handling of authentication mechanism when entering premises
- Additional measures restricting access to critical technical areas:
- locked rooms,
- access badge with specific authorisation justified by a legitimate professional need
- Backup devices stored in secured location
- Video surveillance
- Specific modalities for guest access (signing of a record, temporary badge, etc.)
- Logging of badge activity
Control of access to IT systems
Objective: prevent unauthorised access to IT systems on which data are processed
- Access logging for IT systems
- User authentication through registered, unique, and personal user accounts
- Limitation of failed login attempts (blocking of user account)
- Strong password policy (users/administrators)
- Auditable, binding procedure to reset forgotten passwords
- Access policy for IT systems with a periodically reviewed procedure for granting authorisations
- Secure remote access to IT systems (VPN, strong authentication, etc.)
- Server systems can only be administered with console password or via password-protected and encrypted connection
- IT administrators have an additional, privileged account for administration tasks
- Secure wireless network
- Mobile terminal devices encrypted
- Automatic password-protected screen and computer locking when temporarily not in use
Control of data access
Objective: prevent any access or illegal/unauthorised activity on the data
- Data access restricted to persons with an operational need
- Predefined access profile in function of business role.
- Logging of data access
- Policy describing access authorisation
Control of data transfer
Objective: ensure a secure transmission of data and prevent any unauthorised transmission
- Data transmitted through the internet is encrypted (email encryption, SSL encryption)
- Logging of data transfer and log retention
- Data transfer only to 3rd parties with whom a contractual relationship exists.
- Prevent/control the use of removable storage devices
- Block data upload to file sharing sites such as WeTransfer, DropBox, etc.
- Block access to webmail interfaces
- Inspect outflowing information and block if in violation of policy
Control of data integrity
Objective: protect data against any alteration and ensure tracking of any input, modification or deletion of data
- Logging of system administrators’ activity
- Formal change management procedures
Control of data availability
Objective: prevent any loss/destruction, even if momentary, of data, whether it is accidental or intentional
- Data backup on a regular basis with control over carrying out and verifying theses backups
- Emergency and restore procedures
- Storing backup devices externally
- Maintain redundant backup media
- Secure technical setups:
- UPS with inverters
- temperature control
- Redundant power supply
- Redundant layout of the network
- Redundant layout of computing resources (CPU, Storage)
- Business continuation plan with regular testing
- Disaster recovery plan with regular testing
- Proper, state of the art usage of system protection solutions
Organisational measures
- Security policy
- Defined and established Information Security Governance
- Procedure for testing, analysing and assessing the efficiency of technical and organisational measures (penetration tests, scans for internal and external vulnerabilities, etc.)
- Periodic patching cycle
- Install critical updates for operating systems without delay
- Install applications updates in case of critical breach
- Procedure for managing security incidents
- Raising user awareness in terms of security
- Training employees whose tasks consist in processing personal data
- Assessment of sub-processors
Assurance of System Integrity
- Anti-Virus on workstations
- EDR / NGAV on workstations
- Malware scan in user mailboxes
- Malware interception on Internet gateways
- Filtering of potentially dangerous filetypes on the intent gateways
- Ethical phishing campaign to raise security awareness
- Regular update of antiviruses
- Detection of anomalous system behaviour
Separation control
- Physical/logical separation of data in case of numerous clients
Control in case of IT development
- IT development tests carried out on fictitious or anonymised data
Procedures for regular testing, assessment and evaluation
- Data Protection Management
- Cyber Security Management
- Incident Response Management
- Data Protection by Design & by Default
- Order or Contract Control
- No third-party data processing without corresponding instructions from the Controller, e.g.
- Clear and unambiguous contractual arrangements
- Strict controls on the selection of the Service Provider
- Duty of pre-evaluation