1.1. Governance and Evolution

This Policy was created in close collaboration with and approved by 4Safe executives. At least annually, it is reviewed and modified as needed to ensure clarity, sufficiency of scope, concern for customer and personnel interests, and general responsiveness to the evolving security landscape and industry best practices.

1.2. Security Team

The 4Safe security team oversees the implementation of this Policy, including

• procurement, provisioning, maintenance, retirement, and reclamation of corporate computing resources,
• all aspects of service development and operation related to security, privacy, access, reliability, and survivability,
• ongoing risk assessment, vulnerability management, incident response, and
• security-related human resources controls and personnel training.

1.3. Risk Management Framework

The security team maintains a Risk Management Framework derived from NIST SP 800-39 - “Managing Information Security Risk: Organization, Mission, and System View” and NIST SP 800-30 - “Guide for Conducting Risk Assessments”. Risk assessment exercises inform prioritization for ongoing improvements to 4Safe’s security posture, which may include changes to this Policy itself.

Our Risk Management Framework incorporates the following:

• Identification of relevant, potential threats.
• A scheme for assessing the strength of implemented controls.
• A scheme for assessing current risks and evaluating their severity.
• A scheme for responding to risks.

2.1. Work Behaviors

The first line of defense in data security is the informed behavior of personnel, who play a significant role in ensuring the security of all data, regardless of format. Such behaviors include those listed in this section as well as any additional requirements specified in the employee handbook, specific security processes, and other applicable codes of conduct.

Training
All employees and contractors must complete the 4Safe security awareness and data handling training programs at least annually.

Unrecognized Persons and Visitors
It is the responsibility of all personnel to take positive action to maintain physical security. Challenge any unrecognized person present in a restricted office location. Any challenged person who does not respond appropriately should be immediately reported to supervisory staff and the security team. All visitors to 4Safe offices must be registered as such or accompanied by a 4Safe employee.

Clean Desk
Personnel should maintain workspaces clear of sensitive or confidential material and take care to clear workspaces of such material at the end of each workday.

Unattended Devices
Unattended devices must be locked. All devices will have an automatic screen lock function set to automatically activate upon no more than fifteen minutes of inactivity.

Use of Corporate Assets
Systems are to be used for business purposes in serving the interests of the company, and of our clients and partners in the course of normal business operations. Personnel are responsible for exercising good judgment regarding the reasonableness of personal use of systems. Only 4Safe-managed hardware and software is permitted to be connected to or installed on corporate equipment or networks and used to access 4Safe data. 4Safe-managed hardware and software includes those either owned by 4Safe or owned by 4Safe personnel but enrolled in a 4Safe device management system. Only software that has been approved for corporate use by 4Safe may be installed on corporate equipment. All personnel must read and understand the list of prohibited activities outlined in this Policy. Modifications or configuration changes are not permitted without explicit written consent by the 4Safe security team.

Removable Storage, No Backups, Use of Cloud Storage
Use of removable media such as USB drives is prohibited. Personnel may not configure work devices to make backups or copies of data outside corporate policies. Instead, personnel are expected to operate primarily “in the cloud” and treat local storage on computing devices as ephemeral. 4Safe data must be saved to company-approved secure cloud storage (e.g. Google Docs) to ensure that even in the event of a corporate device being lost, stolen, or damaged, such artifacts will be immediately recoverable on a replacement device.

Prohibited Activities
The following activities are prohibited. Under certain conditions and with the explicit written consent of the security team, personnel may be exempted from certain of these restrictions during the course of their legitimate job responsibilities (e.g. planned penetration testing, systems administration staff may have a need to disable the network access of a host if that host is disrupting production services).

The list below is by no means exhaustive, but attempts to provide a framework for activities which fall into the category of unacceptable use.

• Under no circumstances are personnel of 4Safe authorized to engage in any activity that is illegal under local, state, federal or international law while utilizing 4Safe-owned resources.
• Violations of the rights of any person or company protected by copyright, trade secret, patent or other intellectual property, or similar laws or regulations including, but not limited to, the installation or distribution of "pirated" or other software products that are not appropriately licensed for use by 4Safe.
• Violating or attempting to violate the terms of use or license agreement of any software product used by 4Safe is strictly prohibited.
• Unauthorized copying of copyrighted material including, but not limited to, digitization and distribution of photographs from magazines, books or other copyrighted sources, copyrighted music, and the installation of any copyrighted software for which 4Safe or the end user does not have an active license is strictly prohibited.
• Exporting software, technical information, encryption software or technology may result in a violation of international or regional export control laws. The appropriate management should be consulted prior to export of any material that is in question.
• Revealing your account password to others or allowing use of your account by others. This includes colleagues, as well as family and other household members when work is being done at home.
• Making fraudulent offers of products, items, or services originating from any 4Safe account.
• Making statements about warranty, expressly or implied, unless it is a part of normal job duties and then only to the extent the warranties are consistent with 4Safe’s authorized warranties.
• Introduction of malicious programs into the network or server (e.g., viruses, worms, Trojan horses, e-mail bombs, etc.).
• Effecting security breaches or disruptions of network communication. Security breaches include, but are not limited to, accessing data of which the employee is not an intended recipient or logging into a server or account that the employee is not expressly authorized to access. For purposes of this section, "disruption" includes, but is not limited to, network sniffing, ping floods, packet spoofing, denial of service, and forged routing information for malicious or unlawful purposes.
• Except by or under the direct supervision of the security team, port scanning or security scanning, or other such software designed to exploit or find computer, software, or network vulnerabilities.
• Executing any form of network monitoring which will intercept data not intended for the employee’s host, unless this activity is a part of the employee’s normal job/duty.
• Circumventing user authentication or security of any host, network or account or attempting to break into an information resource or to bypass a security feature. This includes running password-cracking programs or sniffer programs, and attempting to circumvent file or other resource permissions.
• Attempting to interfere with or deny service to any other user.
• Providing information about, or lists of, 4Safe personnel to parties outside 4Safe.
• Installation of software which installs or includes any form of malware, spyware, or adware as defined by the security team.
• Crashing an information system. Deliberately crashing an information system is strictly prohibited. Users may not realize that they caused a system crash, but if it is shown that the crash occurred as a result of user action, a repetition of the action by that user may be viewed as a deliberate act.
• Attempts to subvert technologies used to effect system configuration of company-managed devices (e.g. MDM) or personal devices voluntarily used for company purposes (e.g. mobile Work Profiles).

2.2. Personnel Systems Configuration, Ownership, and Privacy

Centralized System Configuration
Personnel devices and their software configuration are managed remotely by members of the security team via configuration-enforcement technology, also known as MDM software. Such technology may be used for purposes including auditing/installing/removing software applications or system services, managing network configuration, enforcing password policy, encrypting disks, remote wipe & recovery, copying data files to/from employee devices, and any other allowed interaction to ensure that employee devices comply with this Policy.

Data and Device Encryption
All devices must use modern full disk encryption to protect data in the event of a lost device. An example of valid full disk encryption is Apple FileVault 2 using XTS-AES-128 encryption with a 256-bit key. This is enforced using MDM software.

Device Heartbeat and Remote Wipe
Devices must support the ability to report their status and be remotely wiped. This is enforced using MDM software.

Prevent Removable Storage
Devices must prevent usage of removable storage. This is enforced using MDM software.

Devices must automatically install and configure the 4Safe provided antivirus software for endpoint protection. Configured software will report status and potential threats, allowing for remote administration and reporting by the security team. This is enforced using MDM software.

Retention of Ownership
All software programs, data, and documentation generated or provided by personnel while providing services to 4Safe or for the benefit of 4Safe are the property of 4Safe unless otherwise covered by a contractual agreement.

Personnel Privacy
While 4Safe’s network administration desires to provide a reasonable level of privacy, users should be aware that the data they create on the corporate systems remains the property of 4Safe. Due to the need to protect 4Safe’s network, management does not intend to guarantee the privacy of personnel’s personal information stored on any network device belonging to 4Safe. Personnel are responsible for exercising good judgment regarding the reasonableness of personal use such as general web browsing or personal email. If there is any uncertainty, personnel should consult the security team or their manager.

Personnel should structure all electronic communication with recognition of the fact that the content could be monitored and that any electronic communication could be forwarded, intercepted, printed, or stored by others.

4Safe reserves the right, at its discretion, to review personnel’s files or electronic communications to the extent necessary to ensure all electronic media and services are used in compliance with all applicable laws and regulations as well as corporate policies.

4Safe reserves the right to audit networks and systems on a periodic basis to ensure compliance with this policy. For security and network maintenance purposes, authorized individuals within 4Safe may monitor equipment, systems and network traffic at any time.

2.3. Human Resources Practices

Background Checks
Background checks are conducted for personnel with access to production infrastructure prior to their start date. The consequences of problematic background check results may range from a limitation of security privileges, to revocation of employment offer, to termination.

Training
The security team maintains a company-wide security awareness program delivered to all personnel at least annually. The program covers security awareness, policies, processes, and training to ensure that personnel are sufficiently informed to meet their obligations. Those most responsible for maintaining security at 4Safe, including the security team itself as well as key engineering/operations staff, undergo more technical continuing education.

Separation
In the case of personnel termination or resignation, the security team coordinates with human resources to implement a standardized separation process to ensure that all accounts, credentials, and access of outgoing employees are reliably disabled.

2.4. Physical Office Environment

Access to 4Safe offices is mediated by a staffed front office and programmable door control access. All doors shall remain locked or staffed under normal business conditions. The security team may provide approval to unlock doors for short periods of time in order to accommodate extenuating physical access needs.
Internet-based security cameras are positioned to record time-stamped video of ingress/egress, which are stored off-site.

2.5. Office Network

Internet access shall be provided to devices via wired ethernet and WPA2 wifi. A network firewall that blocks all WAN-sourced traffic shall be put in place. WAN-accessible network services shall not be hosted within the office environment.

3.1. User Accounts and Authentication

Each individual having access to any 4Safe-controlled system does so via a user account denoting their system identity. Such user accounts are required to have a unique username, a unique strong password of at least 8 characters.

Logging into 4Safe Systems
Logins by personnel may originate only from 4Safe-managed devices. . Repeated failed attempts to authenticate may result in the offending user account being locked or revoked.

Revocation and Auditing of User Accounts
User accounts are revoked (that is, disabled but not deleted) immediately upon personnel separation. As a further precaution, all user accounts are audited at least quarterly, and any inactive user accounts are revoked.

3.2. Access Management

4Safe adheres to the principle of least privilege, and every action attempted by a user account is subject to access control checks.

Role-based Access Control
4Safe employs a role-based access control (RBAC) model utilizing Google-supplied facilities such as organizational units, user accounts, user groups, and sharing controls.

Web Browsers and Extensions
4Safe may require use of a specified web browser(s) for normal business use and for access to corporate data such as email. For certain specified roles such as software development and web design, job activities beyond those mentioned above necessitate the use of a variety of browsers, and these roles may do so as needed for those activities.

Any browser that is allowed to access corporate data such as email is subject to a whitelist-based restriction on which browser extensions can be installed.

Administrative Access
Access to administrative operations is strictly limited to security team members and further restricted still as a function of tenure and the principle of least privilege.

Regular Review
Access control policies are reviewed regularly with the goal of reducing or refining access whenever possible. Changes in job function by personnel trigger an access review as well.

3.3. Termination

Upon termination of personnel, whether voluntary or involuntary, the security team will follow 4Safe’s personnel exit procedure, which includes revocation of the associated user account and reclamation of company-owned devices, office keys or access cards, and all other corporate equipment and property prior to the final day of employment.

4.1. Software Development

4Safe stores source code and configuration files in private GitHub repositories. The security and development teams conduct code reviews and execute a static code analysis tool on every code commit. Reviewers shall check for compliance with 4Safe’s conventions and style, potential bugs, potential performance issues, and that the commit is bound to only its intended purpose.

Security reviews shall be conducted on every code commit to security-sensitive modules. Such modules include those that pertain directly to authentication, authorization, access control, auditing, and encryption.

All major pieces of incorporated open source software libraries and tools shall be reviewed for robustness, stability, performance, security, and maintainability.

The security and development teams shall establish and adhere to a formal software release process.

Sensitive data which does not need to be decrypted (e.g. passwords) is salted and hashed using approved functions such as Bcrypt.

Sensitive data which must be decrypted (e.g. tokens) must use an approved encryption provider for HSM functions, such as KMS.

4.2. Configuration and Change Management

The 4Safe security and development teams shall document the configuration of all adopted systems and services, whether hosted by 4Safe or are third party hosted. Industry best practices and vendor-specific guidance shall be identified and incorporated into system configurations. All configurations shall be reviewed on at least an annual basis. Any changes to configurations must be approved by appointed individuals and documented in a timely fashion.

System configurations must address the following controls in a risk-based fashion and in accordance with the remainder of this policy:

• data-at-rest protection encryption
• data-in-transit protection of confidentiality, authenticity, and integrity for incoming and outgoing data
• data and file integrity
• malware detection and resolution
• capturing event logs
• authentication of administrative users
• access control enforcement
• removal or disabling of unnecessary software and configurations
• allocation of sufficient hardware resources to support loads that are expected at least twelve months into the future.
• production data is not used in development or test systems.

4.3. Third Party Services

For every third-party service or sub-processor that 4Safe adopts, the compliance team shall review the service and vendor, on an annual basis, to gain assurance that their security posture is consistent with 4Safe’s for the type and sensitivity of data the service will store or access.

5.1. Data Classification

4Safe maintains the following Data Confidentiality Levels:

• Confidential - Information only available to specific roles within the organization. Data must be encrypted at rest and in transit. Access to data requires 2FA/MFA.
• Restricted - Access restricted to specific roles within the organization and authorized third parties. Data must be encrypted at rest and in transit. Access to data requires 2FA/MFA.
• Internal - Information is available to all employees and authorized third parties. Data must be encrypted at rest and in transit.
• Public - Information is available to the public.

Data Confidentiality is determined by:

• The value of the information, based on impacts identified during the risk assessment process.
• Sensitivity and criticality of the information, based on the highest risk calculated for each data item during the risk assessment.
• Policy, legal, regulatory, and contractual obligations.

Additionally, data may be separated into data type classifications to enforce processing rules for customer data. For each data class, the 4Safe security and development teams may provision and dedicate specific information systems to store and process data of that class, and only data of that class, unless otherwise explicitly stated. For all classes of customer data, data must be encrypted at rest and in transit. Corresponding systems may store and process data items needed to keep each customer’s data properly segmented, such as 4Safe customer identifiers.

Customer User Account Data - This is data pertaining to login accounts for the www.4Safe.online customer web interface, used by 4Safe customer agents. User account credentials shall be hashed in such a manner that the plaintext passwords cannot be recovered.

Customer Contact Data - This is contact data about 4Safe customers and customer agents.

Customer Preferences Data - This is data pertaining to the customer-specific preferences and configurations of the 4Safe service made by customer agents.

Customer Recorded Data - This is data that the 4Safe service collects during session recording.

Customer Event Transaction Metadata - This is metadata about transactions conducted on all other classes of customer data. This includes customer organization and user identifiers, standard syslog data pertaining to customer users, and instances of Customer Contact Data and Customer Preferences Data. This class does not include Customer Recorded Data.

Customer Contact Data, Customer Preferences Data, and Customer Event Transaction Metadata may be stored and processed in systems hosted in different environments, as approved by the security team.

Resources must maintain accurate data classification tagging policies for their entire lifecycle, including during decommissioning or when removed from service temporarily.

5.2. 4Safe Employee Access to Customer Data

4Safe employees may access Customer Data only under the following conditions.

• From managed devices.
• For the purpose of incident response, or customer support.
• For no longer than is needed to fulfill the purpose of access.
• In an auditable manner.
• Customer Data is not used in development or test systems.
• Product usage metadata may be utilized for analytics, performance monitoring, and service/feature improvement.

5.3. Customer Access

4Safe provides web user interfaces (UIs), application programming interfaces (APIs), and data export facilities to provide customers access to their data.

5.4. Exceptional Cases

The security team in conjunction with executive management may approve emergency exceptions to any of the above rules, in response to security incidents, service outages, or significant changes to the 4Safe operating environment, when it is deemed that such exceptions will benefit and protect the security and mission of 4Safe, 4Safe customers, and visitors of 4Safe customers’ websites.

5.5. Data Encryption

4Safe protects all data in transit with TLS 1.2 and all data at rest with AES-256 encryption. Cryptographic keys are assigned to specific roles based on least privilege access and keys are automatically rotated yearly. Usage of keys is monitored and logged.

Resources must maintain data encryption at rest and in transit for their entire lifecycle, including during decommissioning or when removed from service temporarily.

5.6. Data Retention

Each customer is responsible for the information they create, use, store, process and destroy.

On expiration of services, customers may instruct 4Safe to delete all customer data from 4Safe’s systems in accordance with applicable law as soon as reasonably practicable, unless applicable law or regulations require otherwise.

5.7. Data Sanitization and Secure Disposal

4Safe uses Amazon Web Services for all infrastructure. AWS provides the following guidance regarding their data lifecycle policies:

Media storage devices used to store customer data are classified by AWS as Critical and treated accordingly, as high impact, throughout their life-cycles. AWS has exacting standards on how to install, service, and eventually destroy the devices when they are no longer useful. When a storage device has reached the end of its useful life, AWS decommissions media using techniques detailed in NIST 800-88. Media that stored customer data is not removed from AWS control until it has been securely decommissioned.

6.1. Vulnerability Detection and Response

The 4Safe security and development teams shall use all of the following measures to detect vulnerabilities that may arise in 4Safe’s information systems.

• Cross-checking vulnerability databases with all systems and software packages that support critical 4Safe services.
• Automated source code scanners on every code commit.
• Code reviews on every security-sensitive code commit.
• Vulnerability scanning on 4Safe services.
• Maintain a bug bounty program.
• Annual penetration testing.

The 4Safe security team shall evaluate the severity of every detected vulnerability in terms of the likelihood and potential impact of an exploit, and shall develop mitigation strategies and schedules accordingly. Suitable mitigations include complete remediation or implementing compensating controls.

6.2. Incident Detection and Response

The 4Safe security team maintains an internal Incident Response Policy which contains steps for preparation, identification, containment, investigation, eradication, recovery, and follow-up/postmortem.

The 4Safe security team shall use all of the following measures to detect security incidents.

• Continuous monitoring of AWS network traffic and workloads for malicious or unauthorized activities.
• Continuous monitoring of logs to detect potentially malicious or unauthorized activity.
• Conduct reviews on the causes of any service outages.
• Respond to notices of potential incidents from employees, contractors, or external parties.

The 4Safe security team shall make a determination of whether every indicator is representative of an actual security incident. The severity, scope, and root cause of every incident shall be evaluated, and every incident shall be resolved in a manner and timeframe commensurate with the severity and scope.

In the event that a data breach affecting a customer has been detected, 4Safe will maintain communication with the customer about the severity, scope, root cause, and resolution of the breach.

7.1 Availability and Resiliency

4Safe services shall be configured in such a manner so as to withstand long-term outages to individual servers, availability zones, and geographic regions. 4Safe infrastructure and data is replicated in multiple geographic regions to ensure this level of availability. 4Safe availability and status information can be found at status.4Safe.online.

7.2 Disaster Recovery

4Safe targets a Data Recovery Point Objective (RPO) of 24 hours.

Due to the distributed nature of 4Safe services, Recovery Time Objectives (RTO) are near-zero for geographic disasters. RTO for systemic disasters involving data recovery is targeted at 48 hours.

4Safe tests backup and recovery processes on at least a monthly basis.

7.3 Business Continuity

Business Risk Assessment and Business Impact Analysis
4Safe's risk assessment committee will include business risk assessment and business impact analysis for each Key Business System that is used by the organization. The outcome of ongoing risk assessments will update or create recovery plans for Key Business Systems and update prioritization of systems compared to other key systems.

Distribution, Relocation, and Remote Work
4Safe prioritizes policies, tools, and equipment which enables independent, distributed remote work for all staff if emergencies or disasters strike. If the organization’s primary work site is unavailable, staff can work from home or an alternate work site shall be designated by management.

Notification and Communication
4Safe has established internal communications using secure, distributed providers using industry standard security protocols. Staff and management will be notified via existing channels during any emergency event, or when any data recovery plan is initiated or deactivated.