Information Security Policy

Version Control

Date: 26/01/2024

Version: 1.0

Author & Approver: Fatou Senghore

Changes: Document Update

Purpose

Information that is collected, analysed, stored, communicated and reported upon may be subject to theft, misuse, loss and corruption. Information may be put at risk by poor education and training, and the breach of security controls.

Information security incidents can give rise to financial loss, non-compliance with standards and legislation, as well as damage to the reputation of the company.

This high-level Information Security Policy sits alongside the ‘Information Risk Management Policy and ‘Data Protection Policy. This is to provide the high-level outline of, and justification for Travel Places risk-based information security controls.

Objectives

Travel Places security objectives are that:

  • our information risks are identified, managed and treated according to an agreed risk tolerance
  • our authorised users can securely access and share information in order to perform their roles
  • our physical, procedural and technical controls balance user experience and security
  • our contractual and legal obligations relating to information security are met
  • our administrative activity considers information security
  • individuals accessing our information are aware of their information security responsibilities
  • incidents affecting our information assets are resolved and learnt from to improve our controls

 

Scope

The Information Security Policy and its supporting controls, processes and procedures apply to all information used at Travel Places in all formats. This includes information processed by staff, contractors, clients and suppliers dealing with Travel Places.

The Information Security Policy and its supporting controls, processes and procedures apply to all individuals who have access to Travel Places information and technologies. This includes external parties that provide information processing services to Travel Places.

Policy Statement

It is Travel Places policy to ensure that information is protected from a loss of:

  • confidentiality – information will be accessible only to authorised individuals
  • integrity – the accuracy and completeness of information will be maintained
  • availability – information will be accessible to authorised users and processes when required

Travel Places will implement an Information Security Management System based on certified standards, such as ISO27001, PCI DSS and GDPR as required.

Travel Places will be mindful of the approaches adopted by its stakeholders, including partners.

Travel Places will adopt a risk-based approach to the application of the following controls:

Information security policies

A set of lower-level controls, processes and procedures for information security will be defined in support of the high-level Information Security Policy and its stated objectives. This suite of supporting documentation will be approved by the Managing Director, published and communicated to Travel Places users and relevant external parties.

Travel Places of information security

Travel Places will define and implement suitable governance arrangements for the management of information security. This will include identification and allocation of security responsibilities, to initiate and control the implementation and operation of information security within Travel Places.

Human resources security

Travel Places security policies and expectations for acceptable use will be communicated to all users to ensure that they understand their responsibilities. Information security awareness training will be made available to all staff. Poor or inappropriate behaviour will be addressed through the company’s disciplinary procedures.

Where practical, security responsibilities will be included in role descriptions, person specifications and personal development plans.

Asset management

All assets will be documented and accounted for. This includes:

  • information
  • software
  • electronic information processing equipment
  • service utilities
  • people

Owners will be identified for all assets and they will be responsible for the maintenance and protection of their assets.

All information assets will be classified according to their legal requirements, business value, criticality and sensitivity. Classification will indicate appropriate handling requirements. All information assets will have a defined retention and disposal schedule.

Access control

Access to all information will be controlled and will be driven by business requirements. Access will be granted or arrangements made for users according to their role and the classification of information, only to a level that will allow them to carry out their duties.

A formal user registration and de-registration procedure will be maintained for access to all information systems and services. This will include mandatory authentication methods based on the sensitivity of the information being accessed, and will include consideration of multiple factors as appropriate.

Specific controls will be implemented for users with elevated privileges, to reduce the risk of negligent or deliberate system misuse. The separation of duties will be implemented, where practical.

Cryptography

Travel Places will provide guidance and tools to ensure proper and effective use of cryptography to protect the confidentiality, authenticity and integrity of information and systems as required.

Physical and environmental security

Information processing facilities are housed in secure areas, physically protected from unauthorised access, damage and interference by defined security perimeters. Layered internal and external security controls will be in place to deter or prevent unauthorised access and protect assets. This includes those that are critical or sensitive, against forcible or hidden attacks.

Operations security

Travel Places will ensure the correct and secure operations of information processing systems. This will include:

  • documented operating procedures
  • the use of formal change and capacity management
  • controls against malware
  • defined use of logging
  • vulnerability management

Communications security

Travel Places will maintain network security controls to ensure the protection of information within its networks. Travel Places will also provide the tools and guidance to ensure the secure transfer of information both within its networks and with external entities. This is in line with the classification and handling requirements associated with that information.

System acquisition, development and maintenance

Information security requirements will be defined during the development of business requirements for new information systems or changes to existing information systems.

Controls to reduce any risks identified will be implemented where appropriate.

Systems development will be subject to change control and separation of test, development and operational environments.

Supplier relationships

Travel Places information security requirements will be considered when establishing relationships with suppliers, to ensure that assets accessible to suppliers are protected.

Supplier activity will be monitored and audited according to the value of the assets and the associated risks.

Information security incident management

Guidance will be available on what constitutes an information security incident and how this should be reported. Actual or suspected breaches of information security must be reported and will be investigated. The appropriate action to correct the breach will be taken, and any learning built into controls.

Information security aspects of business continuity management

Travel Places will have in place arrangements to protect critical business processes from the effects of major failures of information systems or disasters. This is to ensure their timely recovery in line with documented business needs. This will include appropriate backup routines and built-in resilience.

Business continuity plans must be maintained and tested in support of this policy. Business impact analysis will be undertaken, detailing the consequences of:

  • disasters
  • security failures
  • loss of service
  • lack of service availability

Compliance

The design, operation, use and management of information systems must comply with all statutory, regulatory and contractual security requirements.

Currently this includes:

  • data protection legislation (GDPR)
  • the payment card industry standard (PCI-DSS)
  • the ISO27001
  • Travel Places contractual commitments

Travel Places will use a combination of internal and external audits to demonstrate compliance against chosen standards and best practice, including against internal policies and procedures. This will include:

  • IT health checks
  • gap analyses against documented standards
  • internal checks on staff compliance
  • returns from Information Asset Owners

Compliance monitoring

Compliance with the controls in this policy will be monitored by the Information Security Team, and reported to the Head of HR.

Review

A review of this policy will be undertaken by the Information Security Analyst. This will be annually or as required, and will be approved by the Head of HR