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Information Security Policy

Protecting Information. Securing Trust.

At BrainSeeds, information security is fundamental to the trust placed in us by students, parents, professionals, educators, educational institutions and organisations.

Effective Date: [Insert Date] Last Updated: [Insert Date]

Security is more than technology.

We recognise that protecting information requires strong security controls, responsible people, secure technology, controlled access and appropriate processes.

01

Strong security controls

02

Responsible people

03

Secure technology

04

Controlled access

05

Appropriate processes

06

Continuous monitoring

07

Staff awareness

08

Third-party oversight

09

Incident preparedness

10

Continuous improvement

Information-security philosophy

Protect the information. Protect the individual. Protect the trust.

This Information Security Policy establishes the principles BrainSeeds uses to protect information against unauthorised access, alteration, disclosure, loss, destruction and misuse.

Purpose & Scope

A structured approach to information security.

The policy establishes a structured approach to protecting BrainSeeds information and technology resources, while defining the core principles that guide how information should be protected and made appropriately available.

Three foundational principles

Protect the right information, in the right way.

The policy seeks to support three connected principles: Confidentiality, Integrity and Availability.

C
Confidentiality Information should only be accessible to authorised individuals and systems.
I
Integrity Information should remain accurate, complete and protected from unauthorised modification.
A
Availability Authorised users should be able to access appropriate information and services when reasonably required.
SECTION 03

What the policy covers

This policy applies to information and technology resources used in connection with BrainSeeds services, including where applicable:

Websites
Assessment platforms
Applications
Databases
Cloud infrastructure
Servers
Computers and devices
Networks
Communication systems
Administrative systems
Learning platforms
Customer-support systems
Backup systems
Third-party technology services
Information processed by authorised personnel

The policy applies to

Employees Management Assessment professionals Trainers Consultants Contractors Technical personnel Support personnel Authorised third-party service providers
Information & Classification

Know what information needs protection.

BrainSeeds may process different categories of information across its services. The level of protection required may vary according to the sensitivity of the information.

SECTION 04

Information we seek to protect

BrainSeeds may process different categories of information, including the following.

01

Personal Information

  • Name
  • Contact information
  • Account information
  • Educational information
  • Professional information
02

Assessment Information

  • Assessment responses
  • Scores
  • Assessment reports
  • Psychometric profiles
  • Multiple Intelligence profiles
  • Personality-related information
  • Aptitude and competency information
  • Learning preferences
03

Development Information

  • Development goals
  • Personalised learning plans
  • Training participation
  • Progress information
  • Reassessment records
  • Career interests
04

Transaction Information

  • Payment-related information
  • Billing information
  • Transaction records
05

Technical Information

  • Device information
  • IP-related information
  • Browser information
  • Authentication information
  • System logs
  • Security events
06

Organisational Information

  • School or institution information
  • Corporate programme information
  • Business information
  • Administrative information
Not every BrainSeeds service collects every category.
SECTION 05

Information classification

BrainSeeds may classify information according to its sensitivity and the level of protection required. A practical classification framework may include:

01 Public

Public

Information intended for public communication.

Examples:
  • Website content
  • Public course descriptions
  • Published articles
  • Public announcements
02 Internal

Internal

Information intended primarily for authorised BrainSeeds personnel.

Examples:
  • Internal procedures
  • Operational documents
  • Internal communications
03 Controlled access

Confidential

Information requiring controlled access.

Examples:
  • Customer information
  • Business information
  • Internal financial information
  • Programme records
04 Heightened protection

Sensitive / Highly Confidential

Information requiring heightened protection.

Examples may include:
  • Children's information
  • Assessment responses
  • Psychometric profiles
  • Individual developmental information
  • Personal career profiles
  • Authentication information
  • Security information

The classification of information should influence how it is stored, accessed, transmitted and retained.

Security Architecture

Security belongs in the design.

BrainSeeds seeks to incorporate security considerations into systems and processes from the beginning rather than treating security as an afterthought.

Security by Design

Where appropriate, security considerations should be incorporated throughout the technology lifecycle. The objective is to identify and reduce security risks before they become incidents.

01

Planning

02

System design

03

Software development

04

Configuration

05

Testing

06

Deployment

07

Maintenance

08

Change management

09

Decommissioning

Access with purpose.

Access to BrainSeeds information should be based on legitimate business or service requirements.

Guiding principle

The right person. The right information. The right purpose. The right level of access.

01

User authentication

02

Role-based permissions

03

Least-privilege access

04

Administrative controls

05

Restricted database access

06

Secure account management

07

Periodic access reviews

08

Removal of unnecessary privileges

Access follows responsibility.

Different BrainSeeds users may require different levels of access. Access should be aligned with responsibilities rather than job title alone.

01

Student

May access their own permitted assessment and learning information.

02

Parent / Guardian

May access information relating to their child where authorised and legally appropriate.

03

Trainer

May access information necessary to deliver an assigned programme.

04

Assessment Professional

May access information required for assessment interpretation or professional services.

05

Institution Administrator

May access information permitted under the relevant institutional programme.

06

System Administrator

May have technical access necessary for system administration, subject to appropriate controls.

07

Management

May access information required for legitimate operational, governance or oversight purposes.

Personnel should not access information simply because they technically can.

Identity & Privileged Access

Every account. Every privilege. Purposeful.

BrainSeeds seeks to protect user accounts through appropriate authentication controls, while applying additional controls to administrative and privileged access where appropriate.

Authentication &
Account Security

Depending on the system, controls may include the following:

01

Strong password requirements

02

Secure password storage

03

Account verification

04

Session management

05

Login monitoring

06

Multi-factor authentication where appropriate

07

Account lockout or protective controls

08

Password reset procedures

User responsibility

Users are responsible for protecting their own authentication credentials and should never share:

  • Passwords
  • One-time authentication codes
  • Security tokens
  • Recovery credentials

Administrative &
Privileged Access

Administrative accounts can create heightened security risks. BrainSeeds therefore seeks to apply additional controls to privileged access, including where appropriate.

Why additional controls matter

Privileged access should only be used when necessary for legitimate administrative or technical purposes.

01

Separate administrative accounts

02

Restricted administrator permissions

03

Strong authentication

04

Logging

05

Monitoring

06

Periodic review

07

Removal of unnecessary privileges

Data Protection Architecture

Protecting information where it moves.

BrainSeeds seeks to protect information through appropriate safeguards across transmission, storage and controlled database environments.

SECTION 11

Data Encryption

Where technically appropriate, BrainSeeds seeks to use encryption to protect information.

01

Data transmitted over networks

02

Sensitive information stored within systems

03

Backups

04

Administrative communications

05

Other appropriate security-sensitive environments

The exact encryption technologies and configurations may vary depending on the system, service provider and technical architecture.

SECTION 12

Secure Data Transmission

BrainSeeds seeks to protect information while it moves between users, systems and authorised service providers.

01 →

Secure communication

Secure communication protocols and encrypted connections may be used where appropriate.

02 →

Protected exchange

Protected APIs, authentication, access controls and secure file-transfer mechanisms may form part of the safeguards.

03 →

Authorised destination

Information is intended to move between users, systems and authorised service providers through appropriate safeguards.

Secure communication protocols
Encrypted connections
Protected APIs
Authentication
Access controls
Secure file-transfer mechanisms

Sensitive information should not knowingly be transmitted through insecure channels where a secure alternative is reasonably available.

SECTION 13

Database Security

BrainSeeds databases may contain information requiring controlled access. Database-security measures may include the following.

01

Access restrictions

02

Authentication

03

Encryption where appropriate

04

Role-based permissions

05

Network restrictions

06

Monitoring

07

Backup procedures

08

Administrative controls

09

Data lifecycle management

Secure Development

Security across the application lifecycle.

BrainSeeds seeks to develop and maintain applications with appropriate security considerations, with security considered throughout the application lifecycle.

SECTION 14

Application Security

Depending on the system, security practices may include:

01

Secure authentication

02

Input validation

03

Access-control validation

04

Session security

05

Secure APIs

06

Error handling

07

Logging

08

Vulnerability management

09

Secure configuration

10

Software updates

SECTION 15

Secure Software Development

Where BrainSeeds develops or customises software, security should be considered during requirements, design, development, testing, deployment, maintenance and retirement.

01

Requirements

Identify security and privacy requirements.

02

Design

Consider threats, permissions and data flows.

03

Development

Apply secure coding practices.

04

Testing

Identify security weaknesses and unexpected behaviour.

05

Deployment

Use appropriate configuration and access controls.

06

Maintenance

Address vulnerabilities and security improvements.

07

Retirement

Securely decommission systems and access.

SECTION 16

Vulnerability Management

Technology vulnerabilities can emerge as software and threats evolve. BrainSeeds seeks to identify and address relevant vulnerabilities through appropriate processes.

01

Software updates

02

Security patches

03

Dependency management

04

Vulnerability scanning

05

Configuration reviews

06

Security testing

07

Risk assessment

08

Remediation

09

Monitoring

Risk prioritisation

Priority may depend on several factors.

The priority assigned to a vulnerability may depend on factors such as those shown here.

Severity
Exploitability
Exposure
Information affected
Business impact
Availability of mitigation
Endpoint · Network · Cloud

Protection across connected environments.

BrainSeeds seeks to protect authorised devices, networks, communications infrastructure and cloud environments through appropriate controls.

SECTION 17

Malware &
Endpoint Protection

BrainSeeds seeks to protect computers and other authorised devices used to access its information systems. Where appropriate, safeguards may include:

01

Security software

02

Endpoint protection

03

Operating-system updates

04

Application updates

05

Restricted administrative privileges

06

Device access controls

07

Secure configuration

08

Malware detection

Personnel should not knowingly install unauthorised or suspicious software on systems used for BrainSeeds activities.

SECTION 18

Network Security

BrainSeeds seeks to protect networks and communications infrastructure through appropriate controls. Depending on the architecture, these may include:

Connected systems Systems and communication infrastructure requiring protection.
Network protection
Appropriate controls Depending on the architecture
Secure access Access restrictions and secure remote access may form part of the safeguards.
Firewalls
Network segmentation
Secure protocols
Access restrictions
Monitoring
Intrusion detection or prevention capabilities
Secure remote access
Administrative controls

Network-security measures should be appropriate to the sensitivity of the systems and information involved.

SECTION 19

Cloud Security

BrainSeeds may use cloud infrastructure and hosted technology services. Cloud environments may support a range of technology functions.

Cloud environments may be used for:

Application hosting
Database hosting
Storage
Backup
Disaster recovery
Analytics
Communication
Other technology functions

BrainSeeds seeks to manage cloud security through appropriate:

Access controls
Authentication
Configuration management
Encryption
Logging
Backup
Monitoring
Vendor management

Shared responsibility: Responsibility for security may be shared between BrainSeeds and cloud providers depending on the service model.

Resilience & Recovery

Ready to recover. Ready to continue.

Backups, recovery capabilities and continuity processes form part of the resilience approach described in the BrainSeeds Information Security Policy.

SECTION 20

Backup & Data Recovery

Backups are an important part of resilience and recovery. Where appropriate, BrainSeeds may maintain backups of relevant systems and information.

01

Scheduled backups

02

Access restrictions

03

Secure storage

04

Backup monitoring

05

Recovery testing

06

Appropriate retention

07

Protection against unauthorised modification

Backups should not be treated as an excuse for indefinite data retention. They should operate consistently with BrainSeeds' Data Retention & Deletion Policy.

SECTION 21

Disaster Recovery

BrainSeeds seeks to maintain appropriate capabilities to recover important systems following significant disruption.

Recovery context

Significant disruption can take many forms.

Recovery priorities should consider service criticality, impact on users, information involved, operational requirements and security considerations.

Hardware failure
Software failure
Cybersecurity incidents
Data corruption
Infrastructure outages
Natural disasters
Human error
Third-party service disruption

Recovery priorities should consider

Criticality of the service
Impact on users
Information involved
Operational requirements
Security considerations
SECTION 22

Business Continuity

Information security is closely connected with business continuity. BrainSeeds seeks to maintain appropriate processes to continue essential services during significant disruptions.

Continuity planning may consider:

Planning for significant disruptions may take into account operational, technological and organisational dependencies.

  • Critical systems
  • Key personnel
  • Alternative processes
  • Communication
  • Technology dependencies
  • Third-party dependencies
  • Recovery priorities

Continuity principle

Keep essential services moving through significant disruption.

Business-continuity planning connects information security with the processes needed to maintain essential services when significant disruptions occur.

Security Operations

See the signal.
Respond with structure.

BrainSeeds seeks to use appropriate logging, monitoring and incident-management practices to help identify suspicious activity, investigate incidents and improve security.

Security activity can leave a useful trail

Where appropriate, BrainSeeds may maintain logs relating to activity across authentication, accounts, administration, applications, systems and infrastructure.

  • Authentication
  • Account activity
  • Administrative actions
  • System events
  • Security events
  • Application events
  • Infrastructure events

What monitoring can help us do

Logs may support operational and security activities when reviewed and used appropriately.

Detect suspicious activity
Investigate incidents
Troubleshoot problems
Support accountability
Improve security
Access to security logs should itself be appropriately restricted.

No technology environment can reasonably be assumed to be completely free of security risk.

If a potential security incident is identified, BrainSeeds seeks to respond through an appropriate incident-management process.

Unauthorised access
Data disclosure
Account compromise
Malware
Phishing
Ransomware
Data loss
Data corruption
Security vulnerability
Unauthorised system modification

Depending on the nature of an incident, the response may include:

01

Identification

Determine that a potential incident has occurred.

02

Containment

Take reasonable steps to prevent further impact.

03

Investigation

Determine what happened and what information or systems may be affected.

04

Remediation

Address the underlying issue.

05

Recovery

Restore affected systems and services safely.

06

Notification

Make notifications where required by applicable law or appropriate to the circumstances.

07

Lessons Learned

Review the incident and improve controls.

Structured response

Incident handling is presented as a sequence that can move from identification through recovery and review, depending on the nature of the incident.

Continuous improvement

Lessons learned provide an opportunity to review the incident and improve controls.

Human Security Layer

Security improves when people know what to notice.

BrainSeeds places importance on prompt incident reporting, awareness of phishing and social engineering, and clear responsibilities for everyone who has access to BrainSeeds information.

26 · Security Incident Reporting

Report suspected incidents promptly

Employees, contractors and authorised users should report suspected security incidents promptly. Early reporting can significantly reduce potential impact.

Suspicious emails Lost devices Unexpected login activity Suspected credential theft Unauthorised access Accidental disclosure Malware warnings Suspicious system behaviour
Prompt reporting helps create an opportunity to respond before a potential security issue has a greater impact.

27 · Phishing & Social Engineering

Human behaviour is an important component of cybersecurity. BrainSeeds seeks to raise awareness of common social-engineering threats.

Phishing
Fake login pages
Impersonation
Social engineering
Fraudulent support requests
Malicious attachments
Credential theft
Verify unusual requests, particularly requests involving:
Passwords Financial transactions Personal information Administrative access Security credentials
28 · Employee & Personnel Security

Access comes with responsibilities.

Individuals with access to BrainSeeds information are expected to understand their responsibilities. Depending on their role, personnel may be required to follow appropriate security and confidentiality practices.

01

Maintain confidentiality

02

Follow security procedures

03

Protect credentials

04

Use authorised systems

05

Report incidents

06

Avoid unauthorised disclosure

07

Complete appropriate security awareness activities

Access should be removed or adjusted when personnel change roles or leave the organisation.