Acceptable Use Policy

EdTech Impact, the “Company”, Acceptable Use and Security Policies

Personnel are responsible for complying with Company policies when using Company information resources and/or on Company time. If requirements or responsibilities are unclear, please seek assistance from the Information Security Committee.
Personnel must promptly report harmful events or policy violations involving Company assets or information to their manager or a member of the Incident Handling Team. Events include, but are not limited to, the following:
- Technology incident: any potentially harmful event that may cause a failure, interruption, or loss in availability to Company Information Resources.
- Data incident: any potential loss, theft, or compromise of Company information.
- Unauthorised access incident: any potential unauthorised access to a Company Information Resource.
- Facility security incident: any damage or potentially unauthorised access to a Company owned, leased, or managed facility.
- Policy violation: any potential violation to this or other Company policies, standards, or procedures.
Personnel should not purposely engage in activities that may
- harass, threaten, impersonate, or abuse others;
- degrade the performance of Company Information Resources;
- deprive authorised Company personnel access to a Company Information Resource;
- obtain additional resources beyond those allocated;
- or circumvent Company computer security measures.
Personnel should not download, install, or run security programs or utilities that reveal or exploit weakness in the security of a system. For example, Company personnel should not run password cracking programs, packet sniffers, port scanners, or any other non-approved programs on any Company Information Resource.
All inventions, intellectual property, and proprietary information, including reports, drawings, blueprints, software codes, computer programs, data, writings, and technical information, developed on Company time and/or using Company Information Resources are the property of Company.
Use of encryption should be managed in a manner that allows designated Company personnel to promptly access all data.
Company Information Resources are provided to facilitate company business and should not be used for personal financial gain.
Personnel are expected to cooperate with incident investigations, including any criminal investigations.
Personnel are expected to respect and comply with all legal protections provided by patents, copyrights, trademarks, and intellectual property rights for any software and/or materials viewed, used, or obtained using Company Information Resources.
Personnel should not intentionally access, create, store or transmit material which Company may deem to be offensive, indecent, or obscene.

Access Management

Access to information is based on a “need to know“.
Personnel are permitted to use only those network and host addresses issued to them by Company IT and should not attempt to access any data or programs contained on Company systems for which they do not have authorization or explicit consent.
All remote access connections made to internal Company networks and/or environments must be made through approved, and Company-provided, virtual private networks (VPNs).
Personnel should not divulge any access information to anyone not specifically authorised to receive such information, including IT support personnel.
Personnel must not share their (personal authentication information, including:
- Account passwords,
- Personal Identification Numbers (PINs),
- Security Tokens (i.e. Smartcard),
- Multi-factor authentication information
- Access cards and/or keys,
- Digital certificates,
- Similar information or devices used for identification and authentication purposes.
Access cards and/or keys that are no longer required must be returned to physical security personnel.
Lost or stolen access cards, security tokens, and/or keys must be reported to physical security personnel as soon as possible.
A service charge may be assessed for access cards, security tokens, and/or keys that are lost, stolen, or are not returned.

Authentication/Passwords

All personnel are required to maintain the confidentiality of personal authentication information.
Any group/shared authentication information must be maintained solely among the authorised members of the group.
All passwords, including initial and/or temporary passwords, must be constructed, and implemented according to the following Company rules:
- Must meet all requirements including minimum length, complexity, and reuse history.
- Must not be easily tied back to the account owner by using things like username, social security number, nickname, relative’s names, birth date, etc.
- Must not be the same passwords used for non-business purposes.
Unique passwords should be used for each system, whenever possible.
User account passwords must not be divulged to anyone. Company support personnel and/or contractors should never ask for user account passwords.
If the security of a password is in doubt, the password should be changed immediately.
Personnel should not circumvent password entry with application remembering, embedded scripts or hard coded passwords in client software.
Security tokens (i.e. Smartcard) must be returned on demand or upon termination of the relationship with Company, if issued.

Clear Desk/Clear Screen

Personnel should log off from applications or network services when they are no longer needed.
Personnel should log off or lock their workstations and laptops when their workspace is unattended.
Confidential or internal information should be removed or placed in a locked drawer or file cabinet when the workstation is unattended and at the end of the workday if physical access to the workspace cannot be secured by other means.
Personal items, such as phones, wallets, and keys, should be removed or placed in a locked drawer or file cabinet when the workstation is unattended.
File cabinets containing confidential information should be locked when not in use or when unattended.
Physical and/or electronic keys used to access confidential information should not be left on an unattended desk or in an unattended workspace if the workspace itself is not physically secured.
Laptops should be either locked with a locking cable or locked away in a drawer or cabinet when the work area is unattended or at the end of the workday if the laptop is not encrypted.
Passwords must not be posted on or under a computer or in any other physically accessible location.
Copies of documents containing confidential information should be immediately removed from printers and fax machines.

Data Security

Personnel should use approved encrypted communication methods whenever sending confidential information over public computer networks (Internet).
Confidential information transmitted via any mail service must be secured in compliance with the Information Classification and Management Policy.
Only authorised cloud computing applications may be used for sharing, storing, and transferring confidential or internal information.
Information must be appropriately shared, handled, transferred, saved, and destroyed, based on the information sensitivity.
Personnel should not have confidential conversations in public places or over insecure communication channels, open offices, and meeting places.
Confidential information must be transported either by an Company employee or a courier approved by IT Management.
All electronic media containing confidential information must be securely disposed. Please contact IT for guidance or assistance.

Email and Electronic Communication

Auto-forwarding electronic messages outside the Company internal systems is prohibited.
Electronic communications should not misrepresent the originator or Company.
Personnel are responsible for the accounts assigned to them and for the actions taken with their accounts.
Accounts must not be shared without prior authorization from Company IT, with the exception of calendars and related calendaring functions.
Employees should not use personal email accounts to send or receive Company confidential information.
Any personal use of Company provided email should not:
- Involve solicitation.
- Be associated with any political entity, excluding the Company sponsored PAC.
- Have the potential to harm the reputation of Company.
- Forward chain emails.
- Contain or promote anti-social or unethical behavior.
- Violate local, UK, or international laws or regulations.
- Result in unauthorised disclosure of Company confidential information.
- Or otherwise violate any other Company policies.
Personnel should only send confidential information using approved secure electronic messaging solutions.
Personnel should use caution when responding to, clicking on links within, or opening attachments included in electronic communications.
Personnel should use discretion in disclosing confidential or internal information in Out of Office or other automated responses, such as employment data, internal telephone numbers, location information or other sensitive data.

Hardware and Software

All hardware must be formally approved by IT Management before being connected to Company networks.
Software installed on Company equipment must be approved by IT Management and installed by Company IT personnel.
All Company assets taken off-site should be physically secured at all times.
Personnel traveling to a High-Risk location, as defined by the UK Foreign Office, must contact IT for approval to travel with corporate assets.
Employees should not allow family members or other non-employees to access Company Information Resources.

Internet

The Internet must not be used to communicate Company confidential or internal information, unless the confidentiality and integrity of the information is ensured and the identity of the recipient(s) is established.
Use of the Internet with Company networking or computing resources must only be used for business-related activities. Unapproved activities include, but are not limited to:
- Recreational games,
- Streaming media,
- Personal social media,
- Accessing or distributing pornographic or sexually oriented materials,
- Attempting or making unauthorised entry to any network or computer accessible from the Internet.
- Or otherwise violate any other Company policies.
Access to the Internet from outside the Company network using a Company owned computer must adhere to all of the same policies that apply to use from within Company facilities.

Mobile Devices and Bring Your Own Device (BYOD)

The use of a personally owned mobile device to connect to the Company network is a privilege granted to employees only upon formal approval of IT Management.
All personally owned laptops and/or workstations must have approved virus and spyware detection/protection software along with personal firewall protection active.
Mobile devices that access Company email must have a PIN or other authentication mechanism enabled.
Confidential information should only be stored on devices that are encrypted in compliance with the Company Encryption Standard.
Company confidential information should not be stored on any personally owned mobile device.
Theft or loss of any mobile device that has been used to create, store, or access confidential or internal information must be reported to the Company Security Team immediately.
All mobile devices must maintain up-to-date versions of all software and applications.
All personnel are expected to use mobile devices in an ethical manner.
Jail-broken or rooted devices should not be used to connect to Company Information Resources.
Company IT Management may choose to execute “remote wipe” capabilities for mobile devices without warning (see Mobile Device Email Acknowledgement).
In the event that there is a suspected incident or breach associated with a mobile device, it may be necessary to remove the device from the personnel’s possession as part of a formal investigation.
All mobile device usage in relation to Company Information Resources may be monitored, at the discretion of Company IT Management.
Company IT support for personally owned mobile devices is limited to assistance in complying with this policy. Company IT support may not assist in troubleshooting device usability issues.
Use of personally owned devices must be in compliance with all other Company
Company reserves the right to revoke personally owned mobile device use privileges in the event that personnel do not abide by the requirements set forth in this policy.
Texting or emailing while driving is not permitted while on company time or using Company Only hands-free talking while driving is permitted, while on company time or when using Company resources.

Physical Security

Photographic, video, audio, or other recording equipment, such as cameras and cameras in mobile devices, is not allowed in secure areas.
Personnel must display photo ID access card at all times while in the building.
Personnel must badge in and out of access-controlled areas. Piggy-backing, tailgating, door propping and any other activity to circumvent door access controls are prohibited.
Visitors accessing card-controlled areas of facilities must be accompanied by authorised personnel at all times.
Eating or drinking are not allowed in data centers. Caution must be used when eating or drinking near workstations or information processing facilities.

Privacy

Information created, sent, received, or stored on Company Information Resources are not private and may be accessed by Company IT employees at any time, under the direction of Company executive management and/or Human Resources, without knowledge of the user or resource owner.
Company may log, review, and otherwise utilize any information stored on or passing through its Information Resource
Systems Administrators, Company IT, and other authorised Company personnel may have privileges that extend beyond those granted to standard business personnel. Personnel with extended privileges should not access files and/or other information that is not specifically required to carry out an employment-related task.

Removable Media

The use of removable media for storage of Company information must be supported by a reasonable business case.
All removable media use must be approved by Company IT prior to use.
Personally, owned removable media use is not permitted for storage of Company
Personnel are not permitted to connect removable media from an unknown origin without prior approval from the Company
Confidential and internal Company information should not be stored on removable media without the use of encryption.
All removable media must be stored in a safe and secure environment.
The loss or theft of a removable media device that may have contained any Company information must be reported to the Company

Security Training and Awareness

All new personnel must complete an approved security awareness training class prior to, or at least within 30 days of, being granted access to any Company Information Resources.
All personnel must be provided with and acknowledge they have received and agree to adhere to the Company Information Security Policies before they are granted to access to Company Information Resources.
All personnel must complete the annual security awareness training.

Social Media

Communications made with respect to social media should be made in compliance with all applicable Company
Personnel are personally responsible for the content they publish online.
Creating any public social media account intended to represent Company, including accounts that could reasonably be assumed to be an official Company account, requires the permission of the Company Communications Departments.
When discussing Company or Company -related matters, you should:
- Identify yourself by name,
- Identify yourself as an Company representative, and
- Make it clear that you are speaking for yourself and not on behalf of Company, unless you have been explicitly approved to do so.
Personnel should not misrepresent their role at Company.
When publishing Company-relevant content online in a personal capacity, a disclaimer should accompany the content. An example disclaimer could be; “The opinions and content are my own and do not necessarily represent Company’s position or opinion.”
Content posted online should not violate any applicable laws (i.e. copyright, fair use, financial disclosure, or privacy laws).
The use of discrimination (including age, sex, race, color, creed, religion, ethnicity, sexual orientation, gender, gender expression, national origin, citizenship, disability, or marital status or any other legally recognised protected basis under UK, state, or local laws, regulations, or ordinances) in published content that is affiliated with Company will not be tolerated.
Confidential information, internal communications and non-public financial or operational information may not be published online in any form.
Personal information belonging to customers may not be published online.
Personnel approved to post, review, or approve content on Company social media sites must follow the Company Social Media Management Procedures.

VoiceMail

Personnel should use discretion in disclosing confidential or internal information in voicemail greetings, such as employment data, internal telephone numbers, location information or other sensitive data.
Personnel should not access another user’s voicemail account unless it has been explicitly authorised.
Personnel must not disclose confidential information in voicemail messages.

Incidental Use

As a convenience to Company personnel, incidental use of Information Resources is permitted. The following restrictions apply:
- Incidental personal use of electronic communications, Internet access, fax machines, printers, copiers, and so on, is restricted to Company approved personnel; it does not extend to family members or other acquaintances.
- Incidental use should not result in direct costs to Company.
- Incidental use should not interfere with the normal performance of an employee’s work duties.
- No files or documents may be sent or received that may cause legal action against, or embarrassment to, Company or its customers.
Storage of personal email messages, voice messages, files and documents within Company Information Resources must be nominal
All information located on Company Information Resources are owned by Company may be subject to open records requests and may be accessed in accordance with this policy.

Enforcement

Personnel found to have violated this policy may be subject to disciplinary action, up to and including termination of employment, and related civil or criminal penalties.

Any vendor, consultant, or contractor found to have violated this policy may be subject to sanctions up to and including removal of access rights, termination of contract(s), and related civil or criminal penalties.