Privacy Policy
1. Purpose
Information is a major asset that IVFtech ApS has a responsibility and requirement to protect. Protecting information assets is not simply limited to covering the stocks of information (electronic data or paper records) that the organization maintains. It also addresses the people that use them, the processes they follow, and the physical computer equipment used to access them. This Information Protection Policy addresses all these areas to ensure that high confidentiality, quality, and availability standards of information are maintained. The following policy details the basic requirements and responsibilities for the proper management of information assets at IVFtech ApS. The policy specifies the means of information handling and transfer within the business.
2. Scope
This Information Protection Policy applies to all the systems, people, and business processes that make up the business's information systems. This includes all executives, committees, departments, partners, employees, contractual third parties, and agents of the organization who have access to information systems or information used for IVFtech ApS purposes.
3. Definition
This policy should be applied whenever business information systems or information is used. Information can take many forms and includes, but is not limited to, the following:
- Hard copy data printed or written on paper.
- Data stored electronically.
- Communications sent by post/courier or using electronic means.
- Stored tape or video.
4. Risks
IVFtech ApS recognizes that there are risks associated with users accessing and handling information in order to conduct official business. This policy aims to mitigate the following risks:
- Non-reporting of information security incidents.
- Inadequate destruction of data.
- The loss of direct control of user access to information systems and facilities.
Non-compliance with this policy could have a significant effect on the efficient operation of the organization and may result in financial loss and an inability to provide necessary services to our customers.
5. Applying the Policy
For information on how to apply this policy, readers are advised to refer to Appendix 1.
6. Policy Compliance
If any user is found to have breached this policy, they may be subject to IVFtech ApS’s disciplinary procedure. If a criminal offense is considered to have been committed, further action may be taken to assist in the prosecution of the offender(s). If you do not understand the implications of this policy or how it may apply to you, seek advice from Kamilla Bjerg Boserup.
7. Policy Governance
The following table identifies who within IVFtech ApS is accountable, responsible, informed, or consulted with regards to this policy. The following definitions apply:
- Responsible: The person(s) responsible for developing and implementing the policy.
- Accountable: The person who has ultimate accountability and authority for the policy.
- Consulted: The person(s) or groups to be consulted prior to final policy implementation or amendment.
- Informed: The person(s) or groups to be informed after policy implementation or amendment.
- Responsible: Kamilla Bjerg Boserup – Managing Director.
- Accountable: Kamilla Bjerg Boserup – Managing Director.
- Informed: All Directors, Staff, & Consultants.
8. Review and Revision
This policy will be reviewed as it is deemed appropriate, but no less frequently than every 12 months. Policy review will be undertaken by Kamilla Bjerg Boserup.
9. References
The following IVFtech ApS policy documents are directly relevant to this policy, and are referenced within this document:
- Information and IT Security - PR.002.001.
- Privacy Policy for IVFtech ApS - OP.062.006.
10. Key Messages
- The business must draw up and maintain inventories of all important information assets.
- All information assets, where appropriate, must be assessed and classified by the owner.
- Access to information assets, systems, and services must be conditional on acceptance of the appropriate Acceptable Usage Policy.
- Users should not be allowed to access information until Kamilla Bjerg Boserup is satisfied that they understand and agree to the legislated responsibilities for the information that they will be handling.
- PROTECT and RESTRICTED information must not be disclosed to any other person or organization via any insecure methods including paper-based methods, fax, and telephone.
11. Appendix 1
11.1 Applying the Policy – Information Asset Management
11.1.1 Identifying Information Assets
The process of identifying important information assets should be sensible and pragmatic. Important information assets will include, but are not limited to, the following:
- Filing cabinets and stores containing paper records.
- Computer databases.
- Data files and folders.
- Software licenses.
- Physical assets (computer equipment and accessories, PDAs, cell phones).
- Key services.
- Key people.
- Intangible assets such as reputation and brand.
IVFtech ApS must draw up and maintain inventories of all important information assets that it relies upon. These should identify each asset and all associated data required for risk assessment, information/records management, and disaster recovery. At a minimum, it must include the following:
- Designated owner.
11.1.2 Personal Information
Personal information is any information about a living, identifiable individual. The business is legally responsible for it. Its storage, protection, and use are governed by the General Data Protection Regulation (GDPR) and applicable national data protection laws in Denmark.
11.1.3 Assigning Asset Owners
All important information assets must have a nominated owner and should be accounted for. An owner must be a member of staff whose seniority is appropriate for the value of the asset they own. The owner’s responsibility for the asset and the requirement for them to maintain it should be formalized and agreed.
11.1.4 Unclassified Information Assets
Items of information that are of limited or no practical value should not be assigned a formal owner or inventoried. Information should be destroyed if there is no legal or operational need to keep it, and temporary owners should be assigned within each department to ensure that this is done.
11.1.5 Information Assets with Short-Term or Localized Use
For new documents that have a specific, short-term localized use, the creator of the document will be the originator. This includes letters, spreadsheets, and reports created by staff. All staff must be informed of their responsibility for the documents they create.
11.1.6 Corporate Information Assets
For information assets whose use throughout the organization is widespread and whose origination is as a result of a group or strategic decision, a corporate owner must be designated, and the responsibility clearly documented. This should be the person who has the most control over the information.
11.2 Information Storage
All electronic information will be stored on centralized facilities to allow regular backups to take place. Staff should not be allowed to access information until Kamilla Bjerg Boserup is satisfied that they understand and agree to the legislated responsibilities for the information that they will be handling.
