1. Introduction

Elephants Can’t Jump is a brand building agency, based in London offering brand strategy and innovation services to its clients.

This document has been developed to detail the Elephants Can’t Jump information security policy. The nature of our work means that the agency is in control of sensitive business data, confidential information that needs to be protected for the good of our clients and the agency’s reputation.

This security policy is a key component of Elephants Can’t Jump overall information security management framework and should be considered alongside more detailed information security guidance, protocols or procedures.

2. Objectives, Aim and Scope
2.1 Objectives

The objectives of Elephants Can’t Jump Information Security Policy are to preserve:

  • Confidentiality – Access to Data shall be confined to those with appropriate authority. 
  • Integrity – Information shall be complete and accurate.  All systems, assets and networks shall operate correctly, according to specification.
  • Availability – Information shall be available and delivered to the right person, at the time when it is needed.
2.2 Policy aim

The aim of this policy is to establish and maintain the security and confidentiality of information, information systems, applications and networks owned or held by Elephants Can’t Jump by:

  • Ensuring that all members of staff are aware of and fully comply with the relevant legislation as described in this and other policies.
  • Describing the principals of security and explaining how they shall be implemented in the organisation.
  • Introducing a consistent approach to security, ensuring that all members of staff fully understand their own responsibilities.
  • Creating and maintaining within the organisation a level of awareness of the need for Information Security as an integral part of the day to day business.
  • Protecting information assets under the control of the organisation.
2.3 Scope

This policy applies to all information, information systems, networks, applications, locations and users of Elephants Can’t Jump or supplied under contract to it.

3. Responsibilities for Information Security

3.1 Ultimate responsibility for information security rests with the Managing Director.

3.2 Line Managers are responsible for ensuring that their permanent and temporary staff and contractors are aware of:-

  • The information security policies applicable in their work areas
  • Their personal responsibilities for information security
  • How to access advice on information security matters

3.3 All staff shall comply with information security procedures including the maintenance of data confidentiality and data integrity. Failure to do so may result in disciplinary action.

3.4 The Information Security Policy shall be maintained, reviewed and updated by the Managing Director. This review shall take place annually.

3.5 Line managers shall be individually responsible for the security of their physical environments where information is processed or stored.

3.6 Each member of staff shall be responsible for the operational security of the information systems they use.

3.7 Each system user shall comply with the security requirements that are currently in force, and shall also ensure that the confidentiality, integrity and availability of the information they use is maintained to the highest standard.

3.8 Contracts with external contractors that allow access to the organisation’s information systems shall be in operation before access is allowed. These contracts shall ensure that the staff or sub-contractors of the external organisation shall comply with all appropriate security policies.

4. Legislation

4.1 Elephants Can’t Jump is obliged to abide by all relevant UK and European Union legislation. The requirement to comply with this legislation shall be devolved to employees and agents of Elephants Can’t Jump, who may be held personally accountable for any breaches of information security for which they may be held responsible.  Elephants Can’t Jump shall comply with the following legislation and other legislation as appropriate:

  • The Data Protection Act (1998)
  • The Data Protection (Processing of Sensitive Personal Data) Order 2000.
  • The Copyright, Designs and Patents Act (1988)
  • The Computer Misuse Act (1990)
  • The Health and Safety at Work Act (1974)
  • Human Rights Act (1998)
  • Regulation of Investigatory Powers Act 2000
  • Freedom of Information Act 2000
  • Health & Social Care Act 2001
5. Policy Framework

5.1 Management of Security

  • At board level, responsibility for Information Security shall reside with the Managing Director.
  • The Managing Director shall be responsible for implementing, monitoring, documenting and communicating security requirements for the organisation.

5.2 Information Security Awareness Training

  • Information security awareness training shall be included in the staff induction process.
  • An ongoing awareness programme shall be established and maintained in order to ensure that staff awareness is refreshed and updated as necessary.

5.3 Contracts of Employment

  • Staff security requirements shall be addressed at the recruitment stage and all contracts of employment contain a confidentiality clause.
  • Information security expectations of staff shall be included within appropriate job definitions.

5.4 Security Control of Assets

Each IT asset, (hardware, software, application or data) has a named custodian who shall be responsible for the information security of that asset.

5.5. Access Controls

Only authorised personnel who have a justified and approved business need shall be given access to restricted areas containing information systems or stored data. Access is restricted through passwords which are changed on a regular basis.

5.6 User Access Controls

Access to information shall be restricted to authorised users who have a bona-fide business need to access the information.

5.7 Computer Access Control

Access to computer facilities shall be restricted to authorised users who have business need to use the facilities.

5.8 Application Access Control

Access to data, system utilities and program source libraries shall be controlled and restricted to those authorised users who have a legitimate business need e.g. systems or database administrators. Authorisation to use an application shall depend on the availability of a licence from the supplier.

5.9 Equipment Security

In order to minimise loss of, or damage to, all assets, equipment shall be physically protected from threats and environmental hazards.

5.10 Clear desks, storage and filing

Steps should be taken for any confidential information to be protected at all times. Elephants Can’t Jump operate a strict clear desk policy at the end of the day to ensure not physical materials are left accessible. Printing and filing of confidential information is also not permitted without the permission of a Director. All printed material is disposed of via a secure disposal service.  All USB Memory Sticks will be stored empty and all content will be removed immediately after use.

5.11 Computer and Network Procedures

Management of computers and networks shall be controlled through standard documented procedures that have been authorised by the Board of Directors.

5.12 Information Risk Assessment

The core principle of risk assessment and management requires the identification and quantification of information security risks in terms of their perceived value of asset, severity of impact and the likelihood of occurrence.

Once identified, information security risks shall be managed on a formal basis. They shall be recorded within a baseline risk register and action plans shall be put in place to effectively manage those risks. The risk register and all associated actions shall be reviewed at regular intervals. Any implemented information security arrangements shall also be a regularly reviewed feature of an Elephants Can’t Jump risk management programme. These reviews shall help identify areas of continuing best practice and possible weakness, as well as potential risks that may have arisen since the last review was completed.

5.13 Information security events and weaknesses

All information security events and suspected weaknesses are to be reported to the Managing Director – bob@elephantscantjump.com . All information security events shall be investigated to establish their cause and impacts with a view to avoiding similar events.

5.14 Classification of Sensitive Information.

A consistent system for the classification of information within Elephants Can’t Jump enables common assurances in information partnerships, consistency in handling and retention practice when information is shared with clients and partners.

Elephants Can’t Jump shall implement appropriate information classifications controls, based upon the results of formal risk assessment and guidance contained within the Information Security Policy to secure their data.

The classification Confidential – shall be used for all documentation and data sent to us by our clients.  Documents so marked shall be held securely on our server, which is physically locked away, to which only authorised persons have access. 

The classification Restricted – shall be used to mark all other sensitive information such as financial and contractual records.  It shall cover information that the disclosure of which is likely to:

  • adversely affect the reputation of the organisation or its officers or cause substantial distress to individuals;
  • make it more difficult to maintain the operational effectiveness of the organisation;
  • cause financial loss or loss of earning potential, or facilitate improper gain or disadvantage for individuals or organisations;
  • breach proper undertakings to maintain the confidence of information provided by third parties or impede the effective development or operation of policies;
  • breach statutory restrictions on disclosure of information;
  • disadvantage the organisation in commercial or policy negotiations with others or undermine the proper management of the organisation and its operations.

Restricted documents should also be stored in the same way as confidential.

5.15 Protection from Malicious Software

The organisation use software countermeasures and management procedures to protect itself against the treat of malicious software. The network is protected by a WatchGuard firewall/router with IDS capabilities. In addition, all workstations run windows Firewall in a standard configuration and are protected by our managed anti-malware and anti-virus installation of BitDefender which includes GravityZone remote management.

All staff shall be expected to co-operate fully with this policy.  Users shall not install software on the organisation’s property without permission from the Board Directors.  Users breaching this requirement may be subject to disciplinary action.

5.16 User media

Removable media of all types that contain software or data from external sources, or that have been used on external equipment, require the approval of the Managing Director before they may be used on Elephants Can’t Jump systems. Such media must also be fully virus checked before being used on the organisation’s equipment.  Users breaching this requirement may be subject to disciplinary action.

5.17 System Change Control

Changes to information systems, applications or networks shall be reviewed and approved by the Managing Director.

5.18 Intellectual Property Rights

The organisation shall ensure that all information products are properly licensed and approved by the Managing Director.  Users shall not install software on the organisation’s property without permission from the Managing Director.  Users breaching this requirement may be subject to disciplinary action.

5.19 Business Continuity and Disaster Recovery Plans

The organisation shall ensure that business impact assessment, business continuity and disaster recovery plans are produced for all mission critical information, applications, systems and networks.

5.20 Reporting

The Managing Director shall keep the Board informed of the information security status of the organisation by means of regular reports and presentations.

5.21 Policy Audit

This policy shall be subject to audit by the Board.

5.22 Further Information

Further information and advice on this policy can be obtained from James Crabb, 0207 291 8000, james@elephantscantjump.com

6. Policy approved by:                  

Bob Bayman, Director of Elephants Can’t Jump.