Data Security Policy
Effective Date: January 1, 2018
The purpose of this Policy is to describe Genoo’s security policy regarding personal information collected and processed by Genoo’s online services (“Policy”).
Specifically, this Policy is intended to identify Genoo’s policies, procedures, and auditing and training practices utilized for data security, and our resulting responsibilities to protect personal information from loss, misuse, unauthorized access, disclosure, alteration and destruction.
APPROACH TO SECURITY
The following sections describe Genoo’s comprehensive approach to ensuring enterprise-wide compliance with its Policy. This consists of four (4) major areas: Security, Personnel, Education, Verification and Contracts.
Security of data is the cornerstone of verifying privacy of data. Genoo maintains a rigorous security posture through focused methodology. It is founded on the implementation of best practices and security policies in five (5) major areas providing enterprise wide coverage including:
Service Provider Controls
Standardized Process and Practices
Business Partner Control.
Key policies in place that contribute to the verification and compliance with the Policy are:
Awareness and Training
Administrative Roles and Responsibilities
Network and Telecommunications Security
Incident Detection and Reporting
Malicious Code Control (Antivirus)
Logical and System Access
Third Party Services
Software Licensing and Appropriate usage
Auditing and Monitoring
Data Classification, Confidentiality, Integrity and Availability
Operational procedures demonstrating compliance with the Policy are:
The above referenced policies and procedures are documented and available for review.
Our personnel consist of employees and contractors.
The Policy is displayed on Genoo’s website.
At least once per year, the Policy is presented and discussed at a company-wide meeting.
The Policy is self-verified periodically by Genoo’s Security Officer. The Security Officer is responsible for:
Ensuring that the policies, guidelines, internal procedures, personnel training, and other measures necessary to implement the Policy are developed and put into practice,
Working with Genoo’s legal counsel to ensure Genoo’s ongoing compliance with applicable privacy laws and agreements, as well as any of Genoo’s other related legal obligations, and
Overseeing annual assessments of Genoo’s internal and external practices to ensure that they conform to the Policy and related company obligations.
In addition, Genoo, through its internal audit processes, conducts an audit of its security controls a minimum of once per year. This independent review assesses the physical security, network security and operational policies and controls in place to protect customer data.
As a condition of employment, all Genoo personnel must sign a IP Confidentiality Agreement. This agreement includes a provision that addresses personnel responsibility regarding compliance with privacy-related matters.
IN WITNESS WHEREOF, the undersigned Security Officer hereby accepts this Data Security Policy and agrees to implement all terms and conditions thereof.
Kim Albee, Security Officer