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Privacy & Data Policy

 

The General Data Protection Regulation (GDPR) replaces the Data Protection Act on the 25th May 2018.   This is my policy for handling your personal data under GDPR.

 

For the purposes of the GDPR, Looking Glass Photography is the data controller  and your data will not be held by any externally hosted third party.

 

As part of the booking process for any Photo Shoot, I will take, process and store all personal data you have provided in my diary. Upon completion of your shoot, your data will be on both your order form and my order form copy.

 

As part of the data gathering process, you will be required to tick a box on the contact form, acknowledging that the data you supplied can be held by Looking Glass Photography.

 

All parties have the right to request deletion of their data at any time, but removal will only be possible subject to any applicable financial accounting regulations.   If, for example, your stored personal data is used to create invoices for goods or services provided by Looking Glass Photography, your data has to be retained in order to comply with HMRC regulations for tax purposes.   As such, your data may be held on record for a period between 6 and 10 years, in accordance with HMRC regulations.

 

Should you choose to order products through me your contact details will not be provided to my supplier.  All orders are despatched from me personally.   No financial data of yours will be given to any third party.  

 

Your details will never be provided to any person or company, nor will your data ever be sold to any third party.

 

Please contact me if you have any further questions relating to this policy.

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Information Security Policy  

 

 

Looking Glass Photography

___________________________________________

 

(Company Name)

     

 

 

 

 

 

 

 

 

090719

___________________

 

(Date)

 

 

 

Contents

1.Introduction3

2.Information Security Policy3

3.Acceptable Use Policy4

4.Disciplinary Action4

5.Protect Stored Data4

6.Information Classification5

7.Access to the sensitive cardholder data5

8.Physical Security6

9.Protect Data in Transit7

10.Disposal of Stored Data8

11.Security Awareness and Procedures8

12.Network security9

13.System and Password Policy10

14.Anti-virus policy11

15.Patch Management Policy11

16.Remote Access policy12

17.Vulnerability Management Policy12

18.Configuration standards:12

19.Change control Process13

20.Audit and Log review15

21.Secure Application development17

22.Penetration testing methodology18

23.Incident Response Plan20

24.Roles and Responsibilities25

25.Third party access to card holder data25

26.User Access Management26

27.Access Control Policy26

28.Wireless Policy28

Appendix A29

Appendix B30

 

1.Introduction

 

This Policy Document encompasses all aspects of security surrounding confidential company information and must be distributed to all company employees. All company employees must read this document in its entirety and sign the form confirming they have read and understand this policy fully. This document will be reviewed and updated by Management on an annual basis or when relevant to include newly developed security standards into the policy and distribute it all employees and contracts as applicable.

 

2.Information Security Policy

 

Looking Glass Photography handles sensitive cardholder information daily.  Sensitive Information must have adequate safeguards in place to protect them, to protect cardholder privacy, to ensure compliance with various regulations and to guard the future of the organisation.

Looking Glass Photography commits to respecting the privacy of all its customers and to protecting any data about customers from outside parties.  To this end management are committed to maintaining a secure environment in which to process cardholder information so that we can meet these promises.

Employees handling Sensitive cardholder data should ensure:

 

lHandle Company and cardholder information in a manner that fits with their sensitivity;

lLimit personal use of Looking Glass Photography information and telecommunication systems and ensure it doesn’t interfere with your job performance;

lLooking Glass Photography reserves the right to monitor, access, review, audit, copy, store, or delete any electronic communications, equipment, systems and network traffic for any purpose;

lDo not use e-mail, internet and other Company resources to engage in any action that is offensive, threatening, discriminatory, defamatory, slanderous, pornographic, obscene, harassing or illegal;

lDo not disclose personnel information unless authorised;

lProtect sensitive cardholder information;

lKeep passwords and accounts secure;

lRequest approval from management prior to establishing any new software or hardware, third party connections, etc.;

lDo not install unauthorised software or hardware, including modems and wireless access unless you have explicit management approval;

lAlways leave desks clear of sensitive cardholder data and lock computer screens when unattended;

lInformation security incidents must be reported, without delay, to the individual responsible for incident response locally – Please find out who this is.

We each have a responsibility for ensuring our company’s systems and data are protected from unauthorised access and improper use.  If you are unclear about any of the policies detailed herein you should seek advice and guidance from your line manager.

3.Acceptable Use Policy

 

The Management’s intentions for publishing an Acceptable Use Policy are not to impose restrictions that are contrary to Looking Glass Photography established culture of openness, trust and integrity. Management is committed to protecting the employees, partners and the Company from illegal or damaging actions by individuals, either knowingly or unknowingly. Looking Glass Photography will maintain an approved list of technologies and devices and personnel with access to such devices as detailed in Appendix B.

 

•Employees are responsible for exercising good judgment regarding the reasonableness of personal use.

•Employees should ensure that they have appropriate credentials and are authenticated for the use of technologies

•Employees should take all necessary steps to prevent unauthorized access to confidential data which includes card holder data.

•Employees should ensure that technologies should be used and setup in acceptable network locations

•Keep passwords secure and do not share accounts.

•Authorized users are responsible for the security of their passwords and accounts.

•All PCs, laptops and workstations should be secured with a password-protected screensaver with the automatic activation feature.

•All POS and PIN entry devices should be appropriately protected and secured so they cannot be tampered or altered.

•Because information contained on portable computers is especially vulnerable, special care should be exercised.

•Postings by employees from a Company email address to newsgroups should contain a disclaimer stating that the opinions expressed are strictly their own and not necessarily those of Looking Glass, unless posting is in the course of business duties.

•Employees must use extreme caution when opening e-mail attachments received from unknown senders, which may contain viruses, e-mail bombs, or Trojan horse code.

 

4.Disciplinary Action  

 

Violation of the standards, policies and procedures presented in this document by an employee will result in disciplinary action, from warnings or reprimands up to and including termination of employment. Claims of ignorance, good intentions or using poor judgment will not be used as excuses for non compliance.

 

5.Protect Stored Data  

 

•All sensitive cardholder data stored and handled by Looking Glass and its employees must be securely protected against unauthorised use at all times. Any sensitive card data that is no longer required by Looking Glass for business reasons must be discarded in a secure and irrecoverable manner.

•If there is no specific need to see the full PAN (Permanent Account Number), it has to be masked when displayed.

•PAN'S which are not protected as stated above should not be sent to the outside network via end user messaging technologies like chats, ICQ messenger etc.,

 

 

 

 

It is strictly prohibited to store:

1.The contents of the payment card magnetic stripe (track data) on any media whatsoever.  

2.The CVV/CVC (the 3 or 4 digit number on the signature panel on the reverse of the payment card) on any media whatsoever.  

3.The PIN or the encrypted PIN Block under any circumstance.

 

6.Information Classification

 

Data and media containing data must always be labelled to indicate sensitivity level

 

•Confidential data might include information assets for which there are legal requirements for preventing disclosure or financial penalties for disclosure, or data that would cause severe damage to Looking Glass if disclosed or modified.  Confidential data includes cardholder data.

•Internal Use data might include information that the data owner feels should be protected to prevent unauthorized disclosure;

•Public data is information that may be freely disseminated.

 

7.Access to the sensitive cardholder data

 

All Access to sensitive cardholder should be controlled and authorised. Any Job functions that require access to cardholder data should be clearly defined.

•Any display of the card holder should be restricted at a minimum of the first 6 and the last 4 digits of the cardholder data.

•Access rights to privileged user ID’s should be restricted to least privileges necessary to perform job responsibilities

•Privileges should be assigned to individuals based on job classification and function (Role based access control)

•Access to sensitive cardholder information such as PAN’s, personal information and business data is restricted to employees that have a legitimate need to view such information.

•No other employees should have access to this confidential data unless they have a genuine business need.

•If cardholder data is shared with a Service Provider (3rd party) then a list of such Service Providers will be maintained as detailed in Appendix B.

•Looking Glass will ensure a written agreement that includes an acknowledgement is in place that the Service Provider will be responsible for the for the cardholder data that the Service Provider possess.

•Looking Glass will ensure that a there is an established process including proper due diligence is in place before engaging with a Service provider.

• Looking Glass will have a process in place to monitor the PCI DSS compliance status of the Service provider.

 

 

 

8.Physical Security  

 

Access to sensitive information in both hard and soft media format must be physically restricted to prevent unauthorised individuals from obtaining sensitive data.

 

•Employees are responsible for exercising good judgment regarding the reasonableness of personal use.

•Employees should ensure that they have appropriate credentials and are authenticated for the use of technologies

•Employees should take all necessary steps to prevent unauthorized access to confidential data which includes card holder data.

•Employees should ensure that technologies should be used and setup in acceptable network locations

•A list of devices that accept payment card data should be maintained.

•The list should include make, model and location of the device

•The list should have the serial number or a unique identifier of the device

•The list should be updated when devices are added, removed or relocated

•POS devices surfaces should be periodically inspected to detect tampering or substitution.

•Personnel using the devices should be trained and aware of handling the POS devices

•Personnel using the devices should verify the identity of any third party personnel claiming to repair or run maintenance tasks on the devices, install new devices or replace devices.

•Personnel using the devices should be trained to report suspicious behaviour and indications of tampering of the devices to the appropriate personnel.  

•A “visitor” is defined as a vendor, guest of an employee, service personnel, or anyone who needs to enter the premises for a short duration, usually not more than one day.

•Keep passwords secure and do not share accounts. Authorized users are responsible for the security of their passwords and accounts.

•Media is defined as any printed or handwritten paper, received faxes, floppy disks, back-up tapes, computer hard drive, etc.  

•Media containing sensitive cardholder information must be handled and distributed in a secure manner by trusted individuals.  

•Visitors must always be escorted by a trusted employee when in areas that hold sensitive cardholder information.

•Procedures must be in place to help all personnel easily distinguish between employees and visitors, especially in areas where cardholder data is accessible. “Employee” refers to full-time and part-time employees, temporary employees and personnel, and consultants who are “resident” on Looking Glass sites. A “visitor” is defined as a vendor, guest of an employee, service personnel, or anyone who needs to enter the premises for a short duration, usually not more than one day.

•Network Jacks located in public and areas accessible to visitors must be disabled and enabled when network access is explicitly authorised.

•All POS and PIN entry devices should be appropriately protected and secured so they cannot be tampered or altered.

•Strict control is maintained over the external or internal distribution of any media containing card holder data and has to be approved by management

•Strict control is maintained over the storage and accessibility of media

•All computer that store sensitive cardholder data must have a password protected screensaver enabled to prevent unauthorised use.

 

 

9.Protect Data in Transit  

 

All sensitive cardholder data must be protected securely if it is to be transported physically or electronically.

 

•Card holder data (PAN, track data etc) must never be sent over the internet via email, instant chat or any other end user technologies.

•If there is a business justification to send cardholder data via email or via the internet or any other modes then it should be done after authorization and by using a strong encryption mechanism (i.e. – AES encryption, PGP encryption, IPSEC, GSM, GPRS, Wireless technologies etc.,).    

•The transportation of media containing sensitive cardholder data to another location must be authorised by management, logged and inventoried before leaving the premises. Only secure courier services may be used for the transportation of such media. The status of the shipment should be monitored until it has been delivered to its new location.