Information Security and Privacy Policy
Purpose
The purpose of this document is to demonstrate the management board’s commitment to information security by providing the overarching policy statements to which all subordinate policies and controls must adhere.
Policy
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 security 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 ISMS objectives are outlined and measured in accordance with the requirements of ISO/IEC 27001:2022.
The ISMS is intended as a mechanism for managing information security 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 ISMS.
The approach taken towards risk assessment and management, the Statement of Applicability and the wider requirements set out for meeting ISO 27001:2022 identify how information security related risks are addressed.
The ISMS 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.
Control objectives for each of these areas are supported by specific documented policies and procedures in the online environment, and they align with the controls listed in Annex A of the ISO 27001:2022 standard.
All employees and relevant interested parties associated with the ISMS must comply with this policy. Appropriate training and materials to support it are available for those in scope of the ISMS, and communication forums such as the ISMS communications group (as per clause 7, Leadership) are available to ensure ongoing engagement.
The ISMS is subject to review and improvement by the ISMS Board, which is chaired by the Senior Information Risk Owner (SIRO) and has ongoing senior representation from appropriate parts of the organisation. Other executives and specialists needed to support the ISMS framework and to periodically review the security policy and broader ISMS are invited to 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 ISMS to ISO 27001:2022, 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.
Definitions
In this policy and the related set of policies contained within the online environment that comprise our ISMS, ‘information security’ is defined as:
Preserving
This means that all relevant interested parties have, and will be made aware of, their responsibilities as defined in their job descriptions or contracts to act in accordance with the requirements of the ISMS. The consequences of not doing so are described in the Code of Conduct. All relevant interested parties will receive information security awareness training, and more specialised roles will receive appropriately specialised information security 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.
Confidentiality
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 other systems in scope.
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
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 within the scope of the ISMS have signed up to our security policy and accepted our ISMS.
Document Owner and Approval
The Data Protection Officer 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 27001:2022.
A current version of this document is available to all members of staff in the ISMS controls environment and accessible via the various Policy Groups.
This information security policy was approved by the ISMS Board and is issued on a version-controlled basis under the approval of the ISMS Board.