Information Security and Privacy Policy


The purpose of this document is to demonstrate the management board’s commitment to information security and privacy by providing the overarching policy statements to which all subordinate policies and control must adhere.


The Board of Directors and management of Good Growth Limited registered at 80-83 Long Lane, London, United Kingdom, EC1A 9ET operates primarily in the business of Marketing and Innovation Technology.

We are committed to preserving the confidentiality, integrity and availability of all the physical and electronic information and information-related assets to meet the purpose and goals of the organisation as summarised in 4.1(Understanding the organisation and its context).

Information and information security and privacy requirements will continue to be aligned with the organisation’s business goals and will take into account the internal and external issues affecting the organisation and the requirements of interested parties.

Our PIMS Objectives are outlined and measured in accordance with the requirements of the ISO/IEC standard 27001:2013 and ISO/IEC standard 27701:2019.

The PIMS is intended as a mechanism for managing information security and privacy related risks and improving the organisation to help deliver its overall purpose and goals.

The online platform environment including our approach to risk management provides the context for identifying, assessing, evaluating and controlling information-related risks through the establishment and maintenance of an PIMS.

The approach taken towards Risk Assessment and management, the Statement of Applicability and the wider requirements set out for meeting ISO 27001:2013 and ISO 27701:2019 identify how information security and privacy related risks are addressed.

The PIMS Board is responsible for the overall management and maintenance of the risk treatment plan with specific risk management activity tasked to the appropriate owner within the organisation. Additional risk assessments may, where necessary, be carried out to determine appropriate controls for specific risks, for example during special projects that are completed within the context .

Control objectives for each of these areas are supported by specific documented policies and procedures in the online environment and they align with the comprehensive controls listed in Annex A of the ISO 27001:2013 standard and Annex A and B of the ISO 27701: 2019 standard.

All employees and relevant Interested Parties associated to the PIMS have to comply with this policy. Appropriate training and materials to support it are available for those in scope of the PIMS and communication forums such as the PIMS communications group as per clause 7 (Leadership) are available to ensure engagement on an ongoing basis.

The PIMS is subject to review and improvement by the PIMS Board which is chaired by the Senior Information Risk Owner (SIRO) and has ongoing senior representation from appropriate parts of the organisation. Other executives/specialists needed to support the PIMS framework and to periodically review the security policy and broader PIMS are invited in the Board meetings and complete relevant work as required, all of which is documented in accordance with the standard.

We are committed to achieving and maintaining certification of the PIMS to ISO27001:2013 along with other relevant accreditations against which our organisation has sought certification.

This policy will be reviewed regularly to respond to any changes in the business, its risk assessment or risk treatment plan, and at least annually.


In this policy and the related set of policies contained within the online environment that incorporate our PIMS, ‘information security and privacy’is defined as:


This means that all relevant Interested Parties have, and will be made aware of, their responsibilities that are defined in their job descriptions or contracts to act in accordance with the requirements of the PIMS. The consequences of not doing so are described in the Code of Conduct. All relevant Interested Parties will receive information security and privacy awareness training and more specialised resources will receive appropriately specialised information security and privacy training.

the availability

This means that information and associated assets should be accessible to authorised users when required and therefore physically secure. The environment must be resilient and the organisation must be able to detect and respond rapidly to incidents or events that threaten the continued availability of assets, systems and information.


This involves ensuring that information is only accessible to those authorised to access it and preventing both deliberate and accidental unauthorised access to the organisation’s and relevant Interested Parties information, proprietary knowledge, assets and others systems in scope.

and integrity

This involves safeguarding the accuracy and completeness of information and processing methods, and therefore requires preventing deliberate or accidental, partial or complete, destruction or unauthorised modification, of either physical assets or electronic data.

of information and other relevant assets

The information can include digital information, printed or written on paper, transmitted by any means, or spoken in conversation, as well as information stored electronically. Assets include all information based processing devices owned by the organisation or those of relevant Interested Parties and BYOD in scope that are processing organisation related information.

of our organisation

The organisation and relevant Interested Parties that are within the scope of the PIMS have signed up to our security policy and accepted our PIMS.

Document Owner and Approval
The CPO is the owner of this document and is responsible for ensuring that this policy document is reviewed in line with the requirements set out in ISO 27001:2013.

A current version of this document is available to all members of staff in the PIMS controls environment and accessible via the various Policy Groups.

This information security privacy policy was approved by the PIMS Board and is issued on a version-controlled basis under the approval of the PIMS Board.

Mike Duke

Chief Product Officer Information Security Policy v1.9 page 4 Good Growth Ltd