The Company has implemented seven key company policies addressing information security and data privacy. AllCompany employees/contractors should read, understand and follow these policies. Violations of these policies may result in disciplinary action up to and including termination.

Key Company Policy #1
Global Information Security  Policy Summary  

The  Company is committed to ensuring the confidentiality, integrity and  availability of the information assets developed by or entrusted to it. Information  assets may include electronic and written information that is stored,  transmitted or maintained in any form. The Company has established an InformationSecurity policy and program to ensure the protection of the Company’s information assets.

Key Company Policy #2
    Acceptable Use  Summary

    Employees should never use company supplied technologies such as Internet access, email or telephone access in a way that would be construed as inappropriate, unlawful or unprofessional.   Users of company-supplied technologies should have no expectations of privacy. Users are responsible for the security of their user IDs, passwords and other security measures  and/or devices and all actions taken under their user IDs. Detailed Acceptable Use Policy should be reviewed.

Key Company Policy #3
Access Management Overview  

Protecting the  confidentiality, integrity and availability of information about employees,  guests and clients is critical to the Company’s mission. Access privilege to  information is limited to the minimum information that employees need to know  in order to perform their specific job functions.  

Key Company Policy #4
Data Classification Overview

    There are four classification levels for data (listed in least sensitive to most sensitive order):  Public (Level 1) - Company  Private (Level  2) – Company Restricted (Level 3) -  Vital Trust  (Level 4) Vital Trust data (Level 4) is the  most sensitive information.   This information includes: Credit card Security numbers  Passport numbers  Driver’s license  numbers Bank Account  numbers Vital Trust  data must never be transmitted electronically  via email or stored in a  computer system without  being encrypted. Vital Trust  data must be securely stored under  lock and  key and shredded when in paper  form.

Key Company Policy #5
Software Licensing and Duplication Restrictions Policy Overview    

All software installed or used on Company Information Systems, including all desktop and laptop computers, must be lawfully acquired through license, internal or contractor development, or other lawful means.

Key Company Policy #6
Technical Information Security Overview

     The Company has a technical security program which ensures the confidentiality, integrity, and availability of the Company’s data on information systems and other technologies. The Company has established and continues to maintain an incident response process. This process includes the timely reporting of security incidents and weaknesses, vulnerabilities, and procedures to maintain the Company’s ability to promptly respond to threats to technologies that store, transmit,  or protect Company information assets.

Key Company Policy #7
Physical IT Environment Security Overview  

The Company strives to maintain a security  environment that appropriately safeguards  Company information assets and technology systems from  unauthorized access and use. This security environment includes physical and operational controls over information technology assets at all Company offices and where applicable on hosted services.