Purpose and Scope
This Information Security Policy addresses the information security policy topics and requirements which maintain the security, confidentiality, integrity, and availability of Proctor360 applications, systems, infrastructure, and data. The topics and requirements called out in this policy should be continuously improved upon to maintain a secure information security posture. From time to time, Proctor360 may update this policy and implement different levels of security controls for different information assets, based on risk and other considerations. This policy is guided by security requirements specific to Proctor360 including compliance with applicable laws and regulations.
This policy applies to all Proctor360 assets utilized by personnel acting on behalf of Proctor360 or accessing its applications, infrastructure, systems or data. All personnel are required to read, accept and follow all Proctor360 policies and plans upon starting and at least annually.
Information Security Communication
Please contact if you have any questions about the Proctor360 information security program.
People Security
Background Check
All Proctor360 personnel are required to complete a background check. An authorized member of Proctor360 must review each background check in accordance with local laws.
Confidentiality
Prior to accessing sensitive information, personnel are required to sign an industry-standard confidentiality agreement protecting Proctor360 confidential information.
Security Awareness Training
Proctor360 has a security awareness training program in place to promote the understanding of security policies and procedures. All personnel are required to undergo training following initial employment and annually thereafter. Completion of the training program is logged by Proctor360.
Secure Coding
Proctor360 promotes the understanding of secure coding to its engineers in order to improve the security and robustness of Proctor360 products.
Physical Security
Clear Desk
Proctor360 personnel are required to ensure that all sensitive information in hardcopy or electronic form is secure in their work area when it is unattended. This requirement extends to both remote and in-office work.
Proctor360 personnel must remove hardcopies of sensitive information from desks and lock the information in a drawer when desks are unoccupied and at the end of the work day. Keys used to access sensitive information must not be left at an unattended desk.
Clear Screen
Proctor360 employees and contractors must be aware of their surroundings at all times and ensure that no unauthorized individuals have access to see or hear sensitive information. All mobile and desktop devices must be locked when unoccupied. Session time-outs and lockouts are enforced through technical controls for all systems containing covered information.
All devices containing sensitive information, including mobile devices, shall be configured to automatically lock after a period of inactivity (e.g. screen saver).
Remote Work
Any Proctor360 issued devices used to access company applications, systems, infrastructure, or data must be used only by the authorized employee or contractor of such device.
Employees or contractors accessing the Proctor360 network or other cloud-based networks or tools are required to use HTTPS/TLS 1.2+ at a minimum to protect data-in-transit.
If you are in a public space, ensure your sight lines are blocked and do not have customer conversations or other confidential conversations. If someone is close to you, assume they can see and hear everything. Connecting directly to a public wireless network that doesn't employ, at minimum, WPA-2 or an equivalent wireless protocol is prohibited
While working at home, employees and applicable contractors should be mindful when visitors (e.g. maintenance personnel) are at their residences, as visitors could become privy to sensitive information left up on computer screens.
System Access Security
Proctor360 adheres to the principle of least privilege, specifying that team members will be given access to only the information and resources necessary to perform their job functions as determined by management or a designee. Requests for escalation of privileges or changes to privileges and access permissions are documented and require approval by an authorized manager. System access is revoked immediately upon termination or resignation.
Account Audits
Audits of access and privileges to sensitive Proctor360 applications, infrastructure, systems, and data are performed regularly and reviewed by authorized personnel.
Password Security
Unique accounts and passwords are required for all users. Passwords must be kept confidential and not shared with anyone. Where possible, all user and system accounts must invoke password complexity requirements specified in the Access Control and Termination Policy. All accounts must use unique passwords not shared with any other accounts.
Rotation Requirements
If a password is suspected to be compromised, the password should be rotated immediately and the security team should be immediately notified.
Storing Passwords
Passwords must only be stored using a Proctor360 approved password manager. Proctor360 does not hard code passwords or embed credentials in static code.
Asset Security
Proctor360 maintains a Configuration and Asset Management Policy designed to track and set configuration standards to protect Proctor360 devices, networks, systems, and data. In compliance with such policy, Proctor360 may provide team members laptops or other devices to perform their job duties effectively.
Data Management
Proctor360 stores and disposes of sensitive data, in a manner that; reasonably safeguards the confidentiality of the data; protects against the unauthorized use or disclosure of the data; and renders the data secure or appropriately destroyed. Data entered into Proctor360 applications must be validated where possible to ensure quality of information processed and to mitigate the impacts of web-based attacks on the systems.
Data Classification
Proctor360 defines the handling and classification of data in the Data Classification Policy.
Data Retention and Disposal Policy
The time periods for which Proctor360 must retain customer data depends on the purpose for which it is used. Proctor360 retains customer data as long as an account is active, as needed to provide services to the customer, or in accordance with the agreement(s) between Proctor360 and the customer. An exemption to this policy would include if Proctor360 is required by law to dispose of data earlier or keep data longer. Proctor360 may retain and use customer data to comply with its legal obligations, resolve disputes, and enforce agreements.
Except as otherwise set forth in the Proctor360 policies, Proctor360 also disposes of customer data when requested by customers.
Proctor360 maintains a sanitization process that is designed to prevent sensitive data from being exposed to unauthorized individuals. Proctor360 hosting and service providers are responsible for ensuring the removal of data from disks allocated to Proctor360 use before they are repurposed or destroyed.
Change and Development Management
To protect against unauthorized changes and the introduction of malicious code, Proctor360 maintains a Change Management Policy with change management procedures that address the types of changes, required documentation, required review and/or approvals, and emergency changes. Changes to Proctor360 production infrastructure, systems, and applications must be documented, tested, and approved before deployment.
Vulnerability and Patch Management
Proctor360 uses a proactive vulnerability and patch management process that prioritizes and implements patches based on classification. Such classification may include whether the severity is security-related or based on other additional factors. Proctor360 schedules third party penetration tests and/or performs internal assessments at least annually.
If you believe you have discovered a vulnerability, please email and Proctor360 will aim to address the vulnerability, if confirmed, as soon as possible.
Environment Separation
As necessary, Proctor360 maintains requirements and controls for the separation of development and production environments.
Source Code
Proctor360 controlled directories or repositories containing source code are secured from unauthorized access.
Logging and Monitoring
Proctor360 collects & monitors audit logs and alerts on key events stemming from production systems, applications, databases, servers, message queues, load balancers, and critical services, as well as IAM user and admin activities. Proctor360 manages logging solution(s) and/or SIEM tool(s) to collect event information of the aforementioned systems and activities. Proctor360 implements filters, parameters, and alarms to trigger alerts on logging events that deviate from established system and activity baselines. Logs are securely stored and archived for a minimum of 1 year to assist with potential forensic efforts.
Logs are made available to relevant team members for troubleshooting, auditing, and capacity planning activities. System and user activity logs may be utilized to assess the causes of incidents and problems. Proctor360 utilizes access control to prevent unauthorized access, deletion, or tampering of logging facilities and log information.
When events and alerts are generated from monitoring solutions and mechanisms, Proctor360 correlates those events and alerts across all sources to identify root causes and formally declare incidents, as necessary, in accordance with the Security Incident Response Policy and Change Management Policy.
Additionally, Proctor360 utilizes threat detection solution(s) to actively monitor and alert on network and application-based threats.
Business Continuity and Disaster Recovery
Proctor360 maintains a plan for continuous business operations if facilities, infrastructure or systems fail. The plan is tested, reviewed and updated at least annually.
Backup Policy
Backups are performed according to appropriate backup schedules to ensure critical systems, records, and configurations can be recovered in the event of a disaster or media failure.
Security Incident Response
Proctor360 maintains a plan that defines responsibilities, detection, and corrective actions during a security incident. The plan will be executed following the discovery of an incident such as system compromise, or unintended/unauthorized acquisition, access, use or release of non-public information. The plan is tested, reviewed and updated at least annually.
Proctor360 utilizes various monitoring and surveillance tools to detect security threats and incidents. Early detection and response can mitigate damages and minimize further risk to Proctor360.
A message should be sent to if you believe there may be a security incident or threat.
Risk Management
Proctor360 requires a risk assessment to be performed at least annually. For risks identified during the process, Proctor360 must classify the risks and develop action plans to mitigate discovered risks.
Vendor Management
Proctor360 requires a vendor security assessment before third party products or services are used confirming the provider can maintain appropriate security and privacy controls. The review may include gathering applicable compliance audits (SOC 1, SOC 2, PCI DSS, HITRUST, ISO 27001, etc.) or other security compliance evidence. Agreements will be updated and amended as necessary when business, laws, and regulatory requirements change.
Privacy
Personal Data
Proctor360 personnel must treat personal data with appropriate security and handling and accommodate data subject requests, as required by applicable laws and regulations. No unauthorized personnel should have access to personal data.
Exceptions
Proctor360 business needs, local situations, laws and regulations may occasionally call for an exception to this policy or any other Proctor360 policy. If an exception is needed, Proctor360 management will determine an acceptable alternative approach.
Enforcement
Any violation of this policy or any other Proctor360 policy or procedure may result in disciplinary action, up to and including termination of employment. Proctor360 reserves the right to notify the appropriate law enforcement authorities of any unlawful activity and to cooperate in any investigation of such activity. Proctor360 does not consider conduct in violation of this policy to be within an employee’s or contractor’s course and scope of work.
Any employee or contractor who is requested to undertake an activity that he or she believes is in violation of this policy must provide a written or verbal complaint to his or her manager or any other manager of Proctor360 as soon as possible.
The disciplinary process should also be used as a deterrent to prevent employees and contractors from violating organizational security policies and procedures, and any other security breaches.
Responsibility, Review, and Audit
Proctor360 reviews and updates its security policies and plans to maintain organizational security objectives and meet regulatory requirements at least annually. The results are shared with appropriate parties internally and findings are tracked to resolution. Any changes are communicated across the organization.
This document is maintained by Proctor360 Inc..
This document was last updated on 4/18/2023.
