Security Policy

PURPOSE

To provide direction to employees that will protect sensitive, confidential information relating to our customers, our donors and our agency.

I. EXECUTIVE SUMMARY

1. Vision and Philosophy
   1. The Idaho Youth Ranch puts securing our customers’ personal data as one of the company’s highest priorities. We understand that every time a customer provides us with credit card and bank account information, or other sensitive personally identifying information, they trust that we will protect it—and this policy is designed to ensure that this trust is not misplaced. The foundation of our information security program is a set of strong policies that are in balance with business operational needs.
2. Security Environment
   1. The Idaho Youth Ranch utilizes customer data to deliver products and services to our customers. Accordingly, all customer information to include cardholder data as well as other sensitive customer and company information, will be protected by all staff, contractors, partners and services providers in accordance with well defined policies and procedures.
   2. The Idaho Youth Ranch will operate on the security principle of “that which is not explicitly allowed is explicitly denied.” Attempts by anyone to access, monitor, use or share information that is not explicitly allowed to them by our security program will be considered a security violation. Further, access to sensitive information will be permitted on a “need to know” basis, such that employees have access to only those data and systems required to perform their assigned jobs. We will deploy systems, processes, policies, and training to protect our mission critical data assets and customer privacy. Most important, we will monitor and enforce compliance to our policies.
3. Vendor Management
   1. Vendors, partners and other third parties will be required to comply with the same standards established for Idaho Youth Ranch staff. All vendors storing or otherwise accessing our customer’s card holder data must provide proof of PCI DSS Compliance.
4. Sanctions for Policy Violation
   1. Failure to comply with Security policies and guidelines may result in corrective action by the Idaho Youth Ranch depending upon the type and severity of the violation, whether it causes any liability of loss to the company, and/or the presence of any repeated violation(s). Each situation will be judged on a case-by-case basis. Sanctions may include termination of employment and/or referral for criminal or civil prosecution, warnings, or additional security awareness training. There is no requirement for advance notices, written or verbal warnings, or probationary periods.

II. INFORMATION CLASSIFICATION, STORAGE, AND DESTRUCTION

1. All Idaho Youth Ranch information is categorized into two main classifications: Public and Confidential.
2. Public information, such as advertising and marketing materials is information that has been declared public knowledge by someone with the authority to do so, and can freely be given to anyone without any possible damage to the Idaho Youth Ranch.
3. Confidential comprises all other information such as sales data, customer addresses, employee files, etc, that should not be made available outside the company. A subset of confidential information is “Critical Confidential” information, which should be restricted to “need to know” access only, such as trade secrets, financial, technical, and personnel information, and other information integral to the success of the company. Customer sales and donation authorizations containing credit card number and CVV2 codes or bank account numbers (PANs) and PANs provided to employees in the course of entering a telephone transaction, fall into the “Critical Confidential” information category.
4. Idaho Youth Ranch personnel are encouraged to use common sense judgment in securing confidential information to the proper extent. “Critical Confidential” information will be stored in a limited access area (i.e. locked file drawer or safe), and only those employees with a “need to know” will be provided access to that information. If an employee is uncertain of the sensitivity of a particular piece of information, he/she should contact their manager.
5. Under no circumstances is a CVV2 code to be stored, even in paper format. If provided on a paper authorization form, after the transaction is successfully processed, it is to be redacted (completely eliminated) on all stored documents.
6. When “Critical Confidential” information in paper form need no longer be stored for any operational or regulatory reason, it must be disposed of via cross-cut shredding or incineration. Any digital information in the “Critical Confidential” category, whether on tape, CD/DVD, or located on a computer hard drive, will be completely erased and rendered unreadable by commercially reasonable methods. (As the Idaho Youth Ranch has contracted with a third party for storage of PANs, none will be stored by the company in digital form.) When feasible, non-critical “Confidential” information should be disposed of in the same manner.

III. PAYMENT PROCESSING SYSTEM

1. The Idaho Youth Ranch utilizes a web-based SaaS system provided by PaySimple, a PCI DSS Certified payment processing service provider, for all payment processing functions. All credit card and ACH transactions, whether authorized over the phone, in writing via mail, or online are transmitted, processed, and stored via the PaySimple Solution system for charitable donations. Telephone and online transactions are directly entered into the system. Mailed transactions are entered into the system, and the paper authorization form is then stored in a secure locked cabinet or safe for only as long as required by business operational needs. In no circumstances are PANs stored electronically for any reason – secure storage is completely relegated to the PaySimple system.
2. Idaho Youth Ranch employees have access to the PaySimple system for processing payments and reporting – but never have access to un-encrypted credit card or bank account numbers. Each user is granted system access permissions based on the minimum functionality required to perform job responsibilities.
3. During the course of performing their job responsibilities, telephone sales representatives will have access to full credit card numbers, billing addresses, and CVV2 codes. Telephone operators are expressly directed to enter this information directly into the PaySimple system – and are never to record any PANs or CVV2s on paper, nor to repeat or otherwise transmit this information to any third parties.

IV. ACCESS CONTROLS

1. Idaho Youth Ranch employees will be granted access to sensitive company data and any archived authorization or reports containing card data or other confidential customer information on a “need to know” basis. Access to payment processing systems and other company applications will also be granted on the basis or the minimum level required to perform assigned job responsibilities.
   1. Users will only be given sufficient rights to all systems to enable them to perform their job function. User rights will be kept to a minimum at all times.
   2. A payment processing system Administrator will be responsible for issuing user accounts, provisioning user account permissions and processing limits, and monitoring system usage.
   3. Access to the PaySimple Solution payment processing system will be by individual username and password.
   4. Usernames and passwords must not be shared by users; passwords must be at least 8 alpha numeric characters and should not be written down.
   5. Passwords will expire every 90 days and must be unique over any 360 day period.
   6. User accounts will be locked after 5 consecutive failed logins.
   7. Any paper receipts, reports, or other documents containing card holder data will be secured in a locked file drawer or safe, with access granted on a limited and documented basis. All documents containing card holder data must be checked-out and checked-in by an authorized manager.
   8. A payment processing system Administrator will be notified of all employees leaving the company and immediately revoke access to all systems and storage facilities.

V. ANTI-VIRUS / ANTI-PHISHING

1. The Idaho Youth Ranch has implemented McAfee for the purpose of computer virus, worm, and trojan horse prevention, detection, and cleanup. In order to ensure the security of our computing environment, the following must be adhered to by all employees using Idaho Youth Ranch computers or systems.
   1. All computers accessing company systems, and/or utilizing the PaySimple payment processing system, must use the approved anti-virus/anti-phishing protection software and configuration.
   2. The virus/phishing protection software must not be disabled or bypassed.
   3. The settings and automatic update frequency for the virus/phishing protection software must not be altered in a manner that will reduce its effectiveness.
   4. Employees should NEVER open files or macros attached to an e-mail from an unknown, suspicious or untrustworthy source.
   5. Employees should never download files from unknown or suspicious sources.
   6. Employees should never complete any forms accessed via links embedded in an email from an unknown, suspicious or untrustworthy source.

VI. ACCEPTABLE USE

1. The Idaho Youth Ranch is committed to protecting its employees, partners, and the company from illegal or damaging actions by individuals, either knowingly or unknowingly. All computer related systems and equipment including but not limited to the computer equipment, software, e-mail accounts, and web browsers are the property of the Idaho Youth Ranch. These systems and data are to be used for business purposes in serving the interests of the company, and our customers in the course of normal operations. Effective security is a team effort involving the participation and support of every Idaho Youth Ranch employee and affiliate who deals with information and/or information systems. It is the responsibility of every employee to know these guidelines, and to conduct their activities accordingly.
2. Key Acceptable Use Policy Provisions:
   1. Users should be aware that the data they create on the corporate systems remains the property of the Idaho Youth Ranch. There is no exception or privacy or guarantee of confidentiality of information stored on or accessed via any network, computer, or electronic device belonging to the Idaho Youth Ranch.
   2. Keep passwords secure and do not share accounts. Authorized users are responsible for the security of their passwords and accounts. PaySimple payment processing system passwords are changed every 90 days.
   3. Employees must use extreme caution when opening e-mail attachments received from unknown senders, which may contain viruses, e-mail bombs, or Trojan horse code.
   4. Under no circumstances is an employee of the Idaho Youth Ranch authorized to engage in any activity that is illegal under local, state, federal, or international law while utilizing Idaho Youth Ranch-owned resources.
   5. The following activities are strictly prohibited, with no exceptions:
      1. Effecting security breaches or disruptions of network communication. Security breaches include, but are not limited to, accessing data of which the employee is not an intended recipient or logging into a server or account that the employee is not expressly authorized to access, unless these duties are within the scope of regular duties. For purposes of this section, “disruption” includes, but is not limited to, network sniffing, pinged floods, packet spoofing, denial of service, and forged routing information for malicious purposes.
      2. Executing any form of network monitoring which will intercept data not intended for the employee’s host, unless this activity is a part of the employee’s normal job/duty.
      3. Circumventing user authentication or security of any host, network, or account.
      4. Providing information about, or lists of, the Idaho Youth Ranch’s employees to parties outside of the Idaho Youth Ranch, except as may be required for certain Human Resource functions or as required by statute or as compelled by court order.
      5. Providing information about or lists of the Idaho Youth Ranch’s customers, including but not limited to PANs, and other sensitive customer information, to any external party or unauthorized internal party; except as may be required to generate mailing lists. Lists generated for the purpose of creating mailing lists must never contain any critical confidential information.

VII. VENDOR MANAGEMENT

1. All vendors that will have access to “Critical Confidential” information, including customer credit card numbers and bank account numbers, must be covered by a formal contract that includes the following guarantees:
   1. Service providers must comply with all PCI DSS requirements, and maintain and provide proof of PCI DSS certification as a service provider.
   2. Service providers must acknowledge responsibility for security of the cardholder data they possess, including but not limited to:
      1. Protect cardholder data as specified by the PCI DSS, in processing or storing payment card data on behalf of the Idaho Youth Ranch.
      2. Report any known or suspect compromise of that data to the Idaho Youth Ranch as soon as possible.
      3. Allow for audits by VISA/MasterCard/American Express/Discover or VISA/MasterCard/American Express/Discover-approved entities in the event of a cardholder data compromise.
      4. Ensure continued security of the cardholder data retained during and after contract terminations.
2. As part of the Vendor Management Program, the Idaho Youth Ranch will perform due diligence on each vendor prior to signing any contract to confirm that the above guarantees have been adequately met.
3. On at least a yearly basis, the Idaho Youth Ranch will review all vendors that have access to “Critical Confidential” information to ensure that:
   1. PCI DSS compliance certification is up-to-date.
   2. Other procedures in place to protect confidential information continue to adequately protect customers and are being properly executed.