Switchboard Visual Technologies, Inc. (the “Company”) implements policies to safely, privately, and securely manage the data of our customers.
For the purposes of this policy, the terms below have the following meanings:
Summary: A data subject may contact us to request that the Company delete personal data about the data subject. In certain circumstances, the Company is required to promptly erase personal data concerning a data subject, such as if one of the following circumstances applies:
To request deletion of personal data, please send an email to firstname.lastname@example.org.
Excerpted from Switchboard’s internal document “Data Management Policy v1”. More details available upon request to email@example.com.
Switchboard is a fully-remote company with no physical locations; neither offices that house Switchboard personnel, nor data centers that house Switchboard equipment.
Switchboard classifies data and information systems in accordance with legal requirements, sensitivity, and business criticality in order to ensure that information is given the appropriate level of protection. Data owners are responsible for identifying any additional requirements for specific data or exceptions to standard handling requirements.
Information systems and applications shall be classified according to the highest classification of data that they store or process.
To help Switchboard and its employees easily understand requirements associated with different kinds of information, the company has created three classes of data.
Highly sensitive data requiring the highest levels of protection; access is restricted to specific employees or departments, and these records can only be passed to others with approval from the data owner or a company executive. Examples include:
Switchboard proprietary information requiring thorough protection; access is restricted to employees with a “need-to-know” based on business requirements. This data can only be distributed outside the company with approval. This is default for all company information unless stated otherwise. Examples include:
Documents intended for public consumption which can be freely distributed outside Switchboard when they’re made publicly accessible, e.g. by publication to a public website that allows unauthenticated or anonymous access. Examples include:
Confidential data should be labeled “confidential” whenever paper copies are produced for distribution.
Confidential data is subject to the following protection and handling requirements:
Restricted data is subject to the following protection and handling requirements:
No special protection or handling controls are required for public data. Public data may be freely distributed.
Switchboard shall retain data as long as the company has a need for its use, or to meet regulatory or contractual requirements. Once data is no longer needed, it shall be securely disposed of or archived. Data owners, in consultation with legal counsel, may determine retention periods for their data. Retention periods shall be documented in the Data Retention Matrix in Appendix B to this policy.
Data classified as restricted or confidential shall be securely deleted when no longer needed. Switchboard shall assess the data and disposal practices of third-party vendors in accordance with the Third-Party Management Policy. Only third-parties who meet Switchboard requirements for secure data disposal shall be used to store and process restricted or confidential data.
Switchboard shall ensure that all restricted and confidential data is securely deleted from company devices prior to, or at the time of, disposal.
Management shall review data retention requirements during the annual review of this policy. Data shall be disposed of in accordance with this policy.
Under certain circumstances, Switchboard may become subject to legal proceedings requiring retention of data associated with legal holds, lawsuits, or other matters as stipulated by Switchboard legal counsel. Such records and information are exempt from any other requirements specified within this Data Management Policy and are to be retained in accordance with requirements identified by the Legal department. All such holds and special retention requirements are subject to annual review with Switchboard’s legal counsel to evaluate continuing requirements and scope.
Switchboard will measure and verify compliance to this policy through various methods, including but not limited to, business tool reports, and both internal and external audits.
In cases where a device is damaged in a way that Switchboard cannot access the Recovery Partition to erase the drive, Switchboard may optionally decide to use an E-Waste service that includes data destruction with a certificate. Switchboard will keep certificates of destruction on record for one year. Physical destruction can be optional if it is verified that the device is encrypted with Full Disk Encryption, which would negate the risk of data recovery.
Management will review this procedure at least annually.
Excerpted from Switchboard’s internal document “Operations Security Policy v1”. More details available upon request to firstname.lastname@example.org.
The need for backups of systems, databases, information and data shall be considered and appropriate backup processes shall be designed, planned and implemented. Security measures to protect backups shall be designed and applied in accordance with the confidentiality or sensitivity of the data. Backup copies of information, software and system images shall be taken regularly to protect against loss of data. Backups and restore capabilities shall be periodically tested, not less than annually.
Switchboard does not regularly back up user devices like laptops. Users are expected to store critical files and information in company-sanctioned file storage repositories.
Backups are configured to run daily at minimum on in-scope systems. The backup schedules are maintained within the backup application software.
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