Information Security Policy

Virginia Water Medical Practice handles sensitive cardholder information daily. Sensitive Information must have adequate safeguards in place to protect the cardholder data, cardholder privacy, and to ensure compliance with various regulations, along with guarding the future of the organisation. Virginia Water Medical Practice commits to respecting the privacy of all its customers and to protecting any customer data from outside parties. To this end management are committed to maintaining a secure environment in which to process cardholder information so that we can meet these promises.

Employees handling sensitive cardholder data should ensure:

Handle Company and cardholder information in a manner that fits with their sensitivity and classification;
Limit personal use of Virginia Water Medical Practice information and telecommunication systems and ensure it doesn’t interfere with your job performance;
Virginia Water Medical Practice reserves the right to monitor, access, review, audit, copy, store, or delete any electronic communications, equipment, systems and network traffic for any purpose;
Do not use e-mail, internet and other Company resources to engage in any action that is offensive, threatening, discriminatory, defamatory, slanderous, pornographic, obscene, harassing or illegal;
Do not disclose personnel information unless authorised;
Protect sensitive cardholder information;
Keep passwords and accounts secure;
Request approval from management prior to establishing any new software or hardware, third party connections, etc.;
Do not install unauthorised software or hardware, including modems and wireless access unless you have explicit management approval;
Always leave desks clear of sensitive cardholder data and lock computer screens when unattended;
Information security incidents must be reported, without delay, to the individual responsible for incident response locally – Please find out who this is.

We each have a responsibility for ensuring our company’s systems and data are protected from unauthorised access and improper use. If you are unclear about any of the policies detailed herein you should seek advice and guidance from your line manager.

1. Network Security

A high-level network diagram of the network is maintained and reviewed on a yearly basis. The network diagram provides a high level overview of the cardholder data environment (CDE), which at a minimum shows the connections in and out of the CDE. Critical system components within the CDE, such as POS devices, databases, web servers, etc., and any other necessary payment components, as applicable should also be illustrated.

In addition, ASV should be performed and completed by a PCI SSC Approved Scanning Vendor, where applicable. Evidence of these scans should be maintained for a period of 18 months.

2. Acceptable Use Policy

Management’s intentions for publishing an Acceptable Use Policy are not to impose restrictions that are contrary to Virginia Water Medical Practice’s established culture of openness, trust and integrity. Management is committed to protecting the employees, partners and the Company from illegal or damaging actions, either knowingly or unknowingly by individuals. Virginia Water Medical Practice will maintain an approved list of technologies and devices and personnel with access to such devices as detailed in Appendix B.

Employees are responsible for exercising good judgment regarding the reasonableness of personal use
Employees should take all necessary steps to prevent unauthorized access to confidential data which includes card holder data
Keep passwords secure and do not share accounts. Authorized users are responsible for the security of their passwords and accounts
All PCs, laptops and workstations should be secured with a password-protected screensaver with the automatic activation feature.
All POS and PIN entry devices should be appropriately protected and secured so they cannot be tampered or altered.
The List of Devices in Appendix B will be regularly updated when devices are modified, added or decommissioned. A stocktake of devices will be regularly performed and devices inspected to identify any potential tampering or substitution of devices.
Users should be trained in the ability to identify any suspicious behaviour where any tampering or substitution may be performed. Any suspicious behaviour will be reported accordingly.
Information contained on portable computers is especially vulnerable, special care should be exercised.
Postings by employees from a Company email address to newsgroups should contain a disclaimer stating that the opinions expressed are strictly their own and not necessarily those of Virginia Water Medical Practice, unless posting is in the course of business duties.
Employees must use extreme caution when opening e-mail attachments received from unknown senders, which may contain viruses, e-mail bombs, or Trojan horse code.

3. Protect stored data

All sensitive cardholder data stored and handled by Virginia Water Medical Practice and its employees must be securely protected against unauthorised use at all times. Any sensitive card data that is no longer required by Virginia Water Medical Practice for business reasons must be discarded in a secure and irrecoverable manner.
If there is no specific need to see the full PAN (Permanent Account Number), it has to be masked when displayed.
PAN'S which are not protected as stated above should not be sent to the outside network via end user messaging technologies like chats, ICQ messenger etc.,

It is strictly prohibited to store:

1. The contents of the payment card magnetic stripe (track data) on any media whatsoever.

2. The CVV/CVC (the 3 or 4 digit number on the signature panel on the reverse of the payment card) on any media whatsoever.

3. The PIN or the encrypted PIN Block under any circumstance.

4. Information Classification

Data and media containing data must always be labelled to indicate sensitivity level.

Confidential data might include information assets for which there are legal requirements for preventing disclosure or financial penalties for disclosure, or data that would cause severe damage to Virginia Water Medical Practice if disclosed or modified. Confidential data includes cardholder data.
Internal Use data might include information that the data owner feels should be protected to prevent unauthorized disclosure.
Public data is information that may be freely disseminated

5. Access to the Sensitive Cardholder Data

All Access to sensitive cardholder should be controlled and authorised. Any job functions that require access to cardholder data should be clearly defined.

Any display of the card holder should be restricted at a minimum to the first 6 and the last 4 digits of the cardholder data.
Access to sensitive cardholder information such as PAN’s, personal information and business data is restricted to employees that have a legitimate need to view such information.
No other employees should have access to this confidential data unless they have a genuine business need.
If cardholder data is shared with a Service Provider (3rd party) then a list of such Service Providers will be maintained as detailed in Appendix C.
Virginia Water Medical Practice will ensure a written agreement that includes an acknowledgement is in place that the Service Provider will be responsible for the for the cardholder data that the Service Provider possess.
Virginia Water Medical Practice will ensure that a there is an established process, including proper due diligence is in place, before engaging with a Service provider.
The Company will have a process in place to monitor the PCI DSS compliance status of the Service provider.

6. Physical Security

Access to sensitive information in both hard and soft media format must be physically restricted to prevent unauthorised individuals from obtaining sensitive data.

Media is defined as any printed or handwritten paper, received faxes, floppy disks, back-up tapes, computer hard drive, etc.
Media containing sensitive cardholder information must be handled and distributed in a secure manner by trusted individuals.
Visitors must always be escorted by a trusted employee when in areas that hold sensitive cardholder information.
Procedures must be in place to help all personnel easily distinguish between employees and visitors, especially in areas where cardholder data is accessible. “Employee” refers to full-time and part-time employees, temporary employees and personnel, and consultants who are “resident” on Virginia Water Medical Practice sites. A “visitor” is defined as a vendor, guest of an employee, service personnel, or anyone who needs to physically enter the premises for a short duration, usually not more than one day.
A list of devices that accept payment card data should be maintained.
The list should include make, model and location of the device.
The list should have the serial number or a unique identifier of the device
The list should be updated when devices are added, removed or relocated
POS devices surfaces are periodically inspected to detect tampering or substitution.
Personnel using the devices should be trained and aware of handling the POS devices
Personnel using the devices should verify the identity of and=y third party personnel claiming to repair or run maintenance tasks on the devices, install new devices or replace devices.
Personnel using the devices should be trained to report suspicious behaviour and indications of tampering of the devices to the appropriate personnel. Virginia Water Medical Practice sites. A “visitor” is defined as a vendor, guest of an employee, service personnel, or anyone who needs to enter the premises for a short duration, usually not more than one day.
Strict control is maintained over the external or internal distribution of any media containing card holder data and has to be approved by management
Strict control is maintained over the storage and accessibility of media
All computer that store sensitive cardholder data must have a password protected screensaver enabled to prevent unauthorised use.

7. Protect Data in Transit

All sensitive cardholder data must be protected securely if it is to be transported physically or electronically.

Card holder data (PAN, track data, etc.) must never be sent over the internet via email, instant chat or any other end user technologies.
If there is a business justification to send cardholder data via email or by any other mode then it should be done after authorization and by using a strong encryption mechanism (i.e. – AES encryption, PGP encryption, IPSEC, etc.).
The transportation of media containing sensitive cardholder data to another location must be authorised by management, logged and inventoried before leaving the premises. Only secure courier services may be used for the transportation of such media. The status of the shipment should be monitored until it has been delivered to its new location.

8. Disposal of Stored Data

All data must be securely disposed of when no longer required by Virginia Water Medical Practice, regardless of the media or application type on which it is stored.
An automatic process must exist to permanently delete on-line data, when no longer required.
All hard copies of cardholder data must be manually destroyed when no longer required for valid and justified business reasons. A quarterly process must be in place to confirm that all non-electronic cardholder data has been appropriately disposed of in a timely manner.
Virginia Water Medical Practice will have procedures for the destruction of hardcopy (paper) materials. These will require that all hardcopy materials are crosscut shredded, incinerated or pulped so they cannot be reconstructed.
Virginia Water Medical Practice will have documented procedures for the destruction of electronic media. These will require:

All cardholder data on electronic media must be rendered unrecoverable when deleted e.g. through degaussing or electronically wiped using military grade secure deletion processes or the physical destruction of the media;
If secure wipe programs are used, the process must define the industry accepted standards followed for secure deletion.

All cardholder information awaiting destruction must be held in lockable storage containers clearly marked “To Be Shredded” - access to these containers must be restricted.

9. Security Awareness and Procedures

The policies and procedures outlined below must be incorporated into company practice to maintain a high level of security awareness. The protection of sensitive data demands regular training of all employees and contractors.

Review handling procedures for sensitive information and hold periodic security awareness meetings to incorporate these procedures into day to day company practice.
Distribute this security policy document to all company employees to read. It is required that all employees confirm that they understand the content of this security policy document by signing an acknowledgement form (see Appendix A).
All employees that handle sensitive information will undergo background checks (such as criminal and credit record checks, within the limits of the local law) before they commence their employment with the Company.
All third parties with access to credit card account numbers are contractually obligated to comply with card association security standards (PCI/DSS).
Company security policies must be reviewed annually and updated as needed.