Information Transfer Policy

Objective

The purpose of this policy is to define the way in which FundApps maintains the security of information transferred within FundApps and with any external entity.

Scope

This policy applies to all FundApps Information Systems.

Policy

Information transferred within FundApps as well as with external entities must comply with the rules set out in the Transmission section of the Data Classification and Protection Standard, as well as the Acceptable Use section of the Employee guide.

Information must be transmitted through FundApps Information Systems (which include the FundApps managed email system). Exceptions to this requirement must be validated by the Head of Information Security, the CTO or the CEO.

Information transmitted to FundApps through email must be scanned for malware before being downloaded by end users.

Endpoint Detection and Response tools must be deployed to all FundApps devices in order to detect and respond to any malware which may have been transferred to FundApps devices.

Information transferred must be cryptographically encrypted in line with the Cryptographic Policy.

Information protected by a strict ACL (Access Control List) must be transferred in a way which continues to guarantee the ACL is maintained. For example, one should share the link to the information system the information is maintained in, rather than the information itself.

Sensitive information must not be shared over the phone in public places.

Transferring information with clients

When transferring sensitive information with clients, usage of FundApps' platform API or User Interface should be privileged. Sending the information through email as an encrypted password protected attachment is an acceptable alternative.

Upon contract termination, the client may require for FundApps to send information stored in the FundApps platform. The transfer of this information must be made in adherence with any relevant clause in the client contract and the requirements set out in this policy.