Technical And Operational Security Measures

Owned by Andy Brook [Plugin People]
Oct 05, 2023

Overview

This documents purpose is to comply with design and default principles (Article 25, GDPR).

Privacy by default requires that protection of personal data be a default for all an organisation's systems and services. The essence of this concept is that only personal data which are necessary for each specific purpose of the processing are processed and data controllers must structure their systems and processes to meet the concept of data minimisation (Article 25(2), GDPR).

Ensure a level of security appropriate to the risk to the rights and freedoms of individuals, taking account of:

  • the state of the art;

  • the cost of implementing the measures; and

  • the nature, scope, context and purposes of processing.

Technical Measures

JEMHC

  • Best practice deployment architecture followed to isolate processing nodes at a network level

  • JEMH App is deployed in a highly available configuration to minimise downtime, is ‘fault tolerant’ and can automatically recover from failed nodes via health check monitoring

  • JEMHC nodes and databases are not publicly available (firewall enforce IP access to limited nodes)

  • JEMHC app is only available over SSL/TLS.

  • JEMHC communication (inbound/outbound) must be over a secure transport (SSL/TLS)

  • All customer data stored by JEMHC is encrypted at rest (database, other storage) to prevent any data leak from underlying storage system replacement

  • JEMHC will further encrypt specific Sensitive information like passwords

  • JEMHC deployment environment uses role based permissions applied to limited named users. A principle of least privilege is applied.

  • Queues are used to break up processing to ensure that high volume of events/data do not swap the system.

  • JEMHC Auditing whilst useful for customers to avoid data loss can be disabled, requires support involvement to reactivate

  • 2FA is required when accessing JEMHC ‘flagged' support messages or accessing the JEMHC deployment environment at all

  • A combination of (restricted access) Client Certificates and IP level firewalls govern network access to the JEMHC app nodes.

Organisation

  • All customer data provided through support (or flagged through JEMHC) is available over a secure transport (SSL/TLS)

  • Only permanent employees have access to support systems and supplied customer data

  • Our company employs multiple layers of network security to prevent ingress.

  • All employee desktop/laptop environments are fully encrypted at rest

  • All employees primary authenticating accounts are 2FA secured

  • All passwords are stored in personal encrypted password storage apps

Operational Measures

JEMHC

  • Access to the JEMHC app environment is named user only

  • Permissions in the JEMHC app environment are role based, and follow the principle of least privilege

  • Access to customer ‘audit’ data is strictly limited to the CTO only.

  • Limited term backups are kept within the deployment environment infrastructure

Organisational

  • There is no outsourcing and are no subcontractors that could access customer data

  • Premises door access secured by key fobs as well as cameras.

  • Company offices are not left unoccupied, are locked securely at other times

  • Access to office by company employees and limited building staff

  • Any visitors are escorted at all times