Information & Security Policy

Overview

An Acceptable Use Policy are not to impose restrictions that are contrary to Chillibreeze established culture of openness, trust and integrity. Effective security is a team effort involving the participation and support of every Chillibreeze employee and affiliate who deals with information and/or information systems. It is the responsibility of every computer user to know these guidelines, and to conduct their activities accordingly.

Purpose

The purpose of this policy is to outline the acceptable use of computer equipment at Chillibreeze. These rules are in place to protect the employee and Chillibreeze. Inappropriate use exposes Chillibreeze to risks including virus attacks, compromise of network systems and services, and legal issues.

Scope

This policy applies to the use of information, electronic and computing devices, and network resources to conduct Chillibreeze business or interact with internal networks and business systems, whether owned or leased by Chillibreeze, the employee, or a third party. All employees, at Chillibreeze and its subsidiaries are responsible for exercising good judgment regarding appropriate use of information, electronic devices, and network resources in accordance with Chillibreeze policies and standards, and local laws and regulation.

This policy applies to employees at Chillibreeze, including all personnel affiliated with third parties. This policy applies to all equipment that is owned or leased by Chillibreeze

Policy

General Use and Ownership:

• Chillibreeze proprietary information stored on electronic and computing devices whether owned or leased by Chillibreeze, the employee or a third party, remains the sole property of Chillibreeze.
• You have a responsibility to promptly report the theft, loss or unauthorized disclosure of Chillibreeze proprietary information.
• You may access, use or share Chillibreeze proprietary information only to the extent it is authorized and necessary to fulfill your assigned job duties.
• Employees are responsible for exercising good judgment regarding the reasonableness of personal use. Individual departments are responsible for creating guidelines concerning personal use of Internet/Intranet/Extranet systems. In the absence of such policies, employees should be guided by departmental policies on personal use, and if there is any uncertainty, employees should consult their supervisor or manager.
• For security and network maintenance purposes, authorized individuals within Chillibreeze may monitor equipment, systems and network traffic at any time.
• Chillibreeze reserves the right to audit networks and systems on a periodic basis to ensure compliance with this policy.

Security and Proprietary Information:

• System level and user level passwords must comply with the Password Policy. Providing access to another individual, either deliberately or through failure to secure its access, is prohibited.
• All computing devices must be secured with a password-protected screensaver with the automatic activation feature set to 10 minutes or less. You must lock the screen or log off when the device is unattended.
• Postings by employees from a Chillibreeze email address to newsgroups should contain a disclaimer stating that the opinions expressed are strictly their own and not necessarily those of Chillibreeze, unless posting is in the course of business duties.
• Employees must use extreme caution when opening e-mail attachments received from unknown senders, which may contain malware.

Unacceptable Use:

The following activities are, in general, prohibited. Employees may be exempted from these restrictions during the course of their legitimate job responsibilities (e.g., systems administration staff may have a need to disable the network access of a host if that host is disrupting production services).

Under no circumstances is an employee of Chillibreeze authorized to engage in any activity that is illegal under local, state, federal or international law while utilizing Chillibreeze-owned resources.

The lists below are by no means exhaustive, but attempt to provide a framework for activities which fall into the category of unacceptable use.

1. System and Network Activities:
   The following activities are strictly prohibited, with no exceptions:
   • Violations of the rights of any person or company protected by copyright, trade secret, patent or other intellectual property, or similar laws or regulations, including, but not limited to, the installation or distribution of "pirated" or other software products that are not appropriately licensed for use by Chillibreeze.
   • Unauthorized copying of copyrighted material including, but not limited to, digitization and distribution of photographs from magazines, books or other copyrighted sources, copyrighted music, and the installation of any copyrighted software for which Chillibreeze or the end user does not have an active license is strictly prohibited.
   • Accessing data, a server or an account for any purpose other than conducting Chillibreeze business, even if you have authorized access, is prohibited.
   • Exporting software, technical information, encryption software or technology, in violation of international or regional export control laws, is illegal. The appropriate management should be consulted prior to export of any material that is in question.
   • Introduction of malicious programs into the network or server (e.g. viruses, worms, Trojan horses, e-mail bombs, etc.).
   • Revealing your account password to others or allowing use of your account by others. This includes family and other household members when work is being done at home.
   • Using a Chillibreeze computing asset to actively engage in procuring or transmitting material that is in violation of sexual harassment or hostile workplace laws in the user's local jurisdiction.
   • Making fraudulent offers of products, items, or services originating from any Chillibreeze account.
   • Making statements about warranty, expressly or implied, unless it is a part of normal job duties.
   • 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.
   • Port scanning or security scanning is expressly prohibited unless prior notification to the IT Department is made.
   • 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.
   • Circumventing user authentication or security of any host, network or account.
   • Introducing honeypots, honeynets, or similar technology on the Chillibreeze network.
   • Interfering with or denying service to any user other than the employee's host (for example, denial of service attack).
   • Using any program/script/command, or sending messages of any kind, with the intent to interfere with, or disable, a user's terminal session, via any means, locally or via the Internet/Intranet/Extranet.
   • Providing information about, or lists of, Chillibreeze employees to parties outside Chillibreeze.
2. Email and Communication Activities:
   • When using company resources to access and use the Internet, users must realize they represent the company. Whenever employees state an affiliation to the company, they must also clearly indicate that "the opinions expressed are my own and not necessarily those of the company". Questions may be addressed to the IT Department.
   • Sending unsolicited email messages, including the sending of "junk mail" or other advertising material to individuals who did not specifically request such material (email spam).
   • Any form of harassment via email, telephone or paging, whether through language, frequency, or size of messages.
   • Unauthorized use, or forging, of email header information.
   • Solicitation of email for any other email address, other than that of the poster's account, with the intent to harass or to collect replies.
   • Creating or forwarding "chain letters", "Ponzi" or other "pyramid" schemes of any type.
   • Use of unsolicited email originating from within Chillibreeze networks of other Internet/Intranet/Extranet service providers on behalf of, or to advertise, any service hosted by Chillibreeze or connected via Chillibreeze network.
   • Posting the same or similar non-business-related messages to large numbers of Usenet newsgroups (newsgroup spam).
3. Personal blogging and Social Media:
   • Personal blogging by employees, whether using Chillibreeze property and systems or personal computer systems, is also subject to the terms and restrictions set forth in this Policy. Limited and occasional use of Chillibreeze systems to engage in blogging is acceptable, provided that it is done in a professional and responsible manner, does not otherwise violate Chillibreeze policy, is not detrimental to Chillibreeze best interests, and does not interfere with an employee's regular work duties. Blogging from Chillibreeze systems is also subject to monitoring.
   • Employees are prohibited from revealing any Chillibreeze confidential or proprietary information, trade secrets or any other material covered by Chillibreeze's Confidential Information policy when engaged in blogging.
   • Employees shall not engage in any blogging that may harm or tarnish the image, reputation and/or goodwill of Chillibreeze and/or any of its employees. Employees are also prohibited from making any discriminatory, disparaging, defamatory or harassing comments when blogging or otherwise engaging in any conduct prohibited by Chillibreeze.
   • Employees may also not attribute personal statements, opinions or beliefs to Chillibreeze when engaged in blogging. If an employee is expressing his or her beliefs and/or opinions in blogs, the employee may not, expressly or implicitly, represent themselves as an employee or representative of Chillibreeze. Employees assume any and all risk associated with blogging.
   • Apart from following all laws pertaining to the handling and disclosure of copyrighted or export controlled materials, Chillibreeze trademarks, logos and any other Chillibreeze intellectual property may also not be used in connection with any blogging activity.

Policy Compliance

1. Compliance Measurement:
   The IT team will verify compliance to this policy through various methods, including but not limited to, business tool reports, internal and external audits, and feedback to the policy owner.
2. Exceptions:
   Any exception to the policy must be approved by the IT team in advance.
3. Non-Compliance:
   An employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment.

Overview

Electronic email is pervasively used in almost all industry verticals and is often the primary communication and awareness method within an organization. At the same time, misuse of email can post many legal, privacy and security risks, thus it's important for users to understand the appropriate use of electronic communications.

Purpose

The purpose of this email policy is to ensure the proper use of Chillibreeze email system and make users aware of what Chillibreeze deems as acceptable and unacceptable use of its email system. This policy outlines the minimum requirements for use of email within Chillibreeze Network.

Scope

This policy covers appropriate use of any email sent from a Chillibreeze email address and applies to all employees and subsidiaries on behalf of Chillibreeze.

Policy

1. All use of email must be consistent with Chillibreeze policies and procedures of ethical conduct, safety, compliance with applicable laws and proper business practices.
2. Chillibreeze email account should be used primarily for Chillibreeze business-related purposes; personal communication is permitted on a limited basis, but non-Chillibreeze related commercial uses are prohibited.
3. All Chillibreeze data contained within an email message or an attachment must be secured according to the Data Protection Standard.
4. Email should be retained only if it qualifies as a Chillibreeze business record. Email is a Chillibreeze business record if there exists a legitimate and ongoing business reason to preserve the information contained in the email.
5. Email that is identified as a Chillibreeze business record shall be retained according to Chillibreeze Record Retention Schedule.
6. The Chillibreeze email system shall not to be used for the creation or distribution of any disruptive or offensive messages, including offensive comments about race, gender, hair color, disabilities, age, sexual orientation, pornography, religious beliefs and practice, political beliefs, or national origin. Employees who receive any emails with this content from any Chillibreeze employee should report the matter to their supervisor immediately.
7. Users are prohibited from automatically forwarding Chillibreeze email to a third party email system (noted in 4.8 below). Individual messages which are forwarded by the user must not contain Chillibreeze confidential or above information.
8. Users are prohibited from using third-party email systems and storage servers such as Google, Yahoo, and MSN Hotmail etc. to conduct Chillibreeze business, to create or memorialize any binding transactions, or to store or retain email on behalf of Chillibreeze.  Such communications and transactions should be conducted through proper channels using Chillibreeze-approved documentation.
9. Using a reasonable amount of Chillibreeze resources for personal emails is acceptable, but non-work related email shall be saved in a separate folder from work related email. Sending chain letters or joke emails from a Chillibreeze email account is prohibited.
10. Chillibreeze employees shall have no expectation of privacy in anything they store, send or receive on the company's email system.
11. Chillibreeze may monitor messages without prior notice. Chillibreeze is not obliged to monitor email messages.

Policy Compliance

1. Compliance Measurement:
   The IT team will verify compliance to this policy through various methods, including but not limited to, periodic walk-throughs, video monitoring, business tool reports, internal and external audits, and feedback to the policy owner.
2. Exceptions:
   Any exception to the policy must be approved by the IT team in advance.
3. Non-Compliance:
   An employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment.

Overview

Passwords are an important aspect of computer security.  A poorly chosen password may result in unauthorized access and/or exploitation of Chillibreeze's resources.  All users, including customers with access to Chillibreeze systems, are responsible for taking the appropriate steps, as outlined below, to select and secure their passwords.

Purpose

The purpose of this policy is to establish a standard for creation of strong passwords, the protection of those passwords, and the frequency of change.

Scope

The scope of this policy includes all personnel who have or are responsible for an account (or any form of access that supports or requires a password) on any system that resides at any Chillibreeze facility, has access to the Chillibreeze network, or stores any non-public Chillibreeze information.

Policy

1. Password Creation:
   • All user-level and system-level passwords must conform to the Password Construction Guidelines.
   • Users must not use the same password for Chillibreeze accounts as for other non-Chillibreeze access (for example, personal ISP account, option trading, benefits, and so on).
   • Where possible, users must not use the same password for various Chillibreeze access needs.
   • User accounts that have system-level privileges granted through group memberships or programs such as sudo must have a unique password from all other accounts held by that user to access system-level privileges.
   • Where Simple Network Management Protocol (SNMP) is used, the community strings must be defined as something other than the standard defaults of public, private, and system and must be different from the passwords used to log in interactively. SNMP community strings must meet password construction guidelines.
2. Password Change:
   • All system-level passwords (for example, root, enable, NT admin, application administration accounts, and so on) must be changed on at least a quarterly basis.
   • All user-level passwords (for example, email, web, desktop computer, and so on) must be changed at least every three months. The recommended change interval is for every month.
   • Password cracking or guessing may be performed on a periodic or random basis by the IT Team or its delegates. If a password is guessed or cracked during one of these scans, the user will be required to change it to be in compliance with the Password Construction Guidelines.
3. Password Protection:
   • Passwords must not be shared with anyone except with his/her own team and manager. All passwords are to be treated as sensitive, Confidential Chillibreeze information.
   • Passwords must not be inserted into email messages, Alliance cases or other forms of electronic communication.
   • Passwords must not be revealed over the phone to anyone.
   • Do not reveal a password on questionnaires or security forms.
   • Do not hint at the format of a password (for example, "my family name").
   • Do not write passwords down and store them anywhere in your office. Do not store passwords in a file on a computer system or mobile devices (phone, tablet) without encryption.
   • Do not use the "Remember Password" feature of applications (for example, web browsers).
   • Any user suspecting that his/her password may have been compromised must report the incident and change all passwords.
   • Use of Passwords and Passphrases:
     • Passphrases are generally used for public/private key authentication. A public/private key system defines a mathematical relationship between the public key that is known by all, and the private key, that is known only to the user. Without the passphrase to "unlock" the private key, the user cannot gain access.
     • Passphrases are not the same as passwords. A passphrase is a longer version of a password and is, therefore, more secure. A passphrase is typically composed of multiple words. Because of this, a passphrase is more secure against "dictionary attacks".
     • A good passphrase is relatively long and contains a combination of upper and lowercase letters and numeric and punctuation characters. An example of a good passphrase:
       "The*?#>*@TrafficOnThe101Was*&#!#ThisMorning"

   All of the rules above that apply to passwords apply to passphrases.

Policy Compliance

1. Compliance Measurement:
   The IT team will verify compliance to this policy through various methods, including but not limited to, periodic walk-thrus, video monitoring, business tool reports, internal and external audits, and feedback to the policy owner.
2. Exceptions:
   Any exception to the policy must be approved by the IT team in advance.
3. Non-Compliance:
   An employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment.