Information Security Policy

Revision date: 29/09/2023

Number Value Description
1 Company Name

Smart Vision doo

VAT 104960344 , REG 20279788

2 Last Revision Date 9/29/2023
3 Document Owner Ivica Stankovic, General manager
4 Approval Date 9/29/2023
5 Effective Date 8/1/2023
6 Privacy Officer Nevena Vuković
7 Business Hours Monday – Friday, 09-17


1.1                PURPOSE

This policy defines the technical controls and security configurations users and Information Technology (IT) administrators are required to implement in order to ensure the integrity and availability of the data environment at SMART VISION DOO, hereinafter, referred to as the Company. It serves as a central policy document with which all employees and contractors must be familiar, and defines actions and prohibitions that all users must follow. The policy provides IT managers within the Company with policies and guidelines concerning the acceptable use of Company technology equipment, e-mail, Internet connections, voice-mail, facsimile, future technology resources and information processing.

The policy requirements and restrictions defined in this document shall apply to network infrastructures, databases, external media, encryption, hardcopy reports, films, slides, models, wireless, telecommunication, conversations, and any other methods used to convey knowledge and ideas across all hardware, software, and data transmission mechanisms. This policy must be adhered to by all Company employees or temporary workers at all locations and by contractors working with the Company as subcontractors.

1.2                SCOPE

This policy document defines common security requirements for all Company personnel and systems that create, maintain, store, access, process or transmit information. This policy also applies to information resources owned by others, such as contractors of the Company, entities in the private sector, in cases where Company has a legal, contractual or fiduciary duty to protect said resources while in Company custody. In the event of a conflict, the more restrictive measures apply. This policy covers the Company network system which is comprised of various hardware, software, communication equipment and other devices designed to assist the Company in the creation, receipt, storage, processing, and transmission of information. This definition includes equipment connected to any Company domain or VLAN, either hardwired or wirelessly, and includes all stand-alone equipment that is deployed by the Company at its office locations or at remote locales.

1.3                ACRONYMS / DEFINITIONS

Common terms and acronyms that may be used throughout this document.

GM – The General manager is responsible for the overall privacy and security practices of the company.

CIO – The Chief Information Officer

PO – The Privacy Officer is responsible for privacy compliance issues.

CST – Confidentiality and Security Team

Encryption – The process of transforming information, using an algorithm, to make it unreadable to anyone other than those who have a specific ‘need to know.’

External Media –i.e. CD-ROMs, DVDs, floppy disks, flash drives, USB keys, thumb drives, tapes

Firewall – a dedicated piece of hardware or software running on a computer which allows or denies traffic passing through it, based on a set of rules.

FTP – File Transfer Protocol

IT – Information Technology

LAN – Local Area Network – a computer network that covers a small geographic area, i.e. a group of buildings, an office.

SOW – Statement of Work – An agreement between two or more parties that details the working relationship between the parties and lists a body of work to be completed.

User – Any person authorized to access an information resource.

Privileged Users – system administrators and others specifically identified and authorized by Company management.

Users with edit/update capabilities – individuals who are permitted, based on job assignment, to add, delete, or change records in a database.

Users with inquiry (read only) capabilities – individuals who are prevented, based on job assignment, from adding, deleting, or changing records in a database. Their system access is limited to reading information only.

VPN – Virtual Private Network – Provides a secure passage through the public Internet. WAN – Wide Area Network – A computer network that enables communication across a broad area, i.e. regional, national.

Virus – a software program capable of reproducing itself and usually capable of causing great harm to files or other programs on the computer it attacks. A true virus cannot spread to another computer without human assistance.

1.4                PRIVACY OFFICER

The Company has established a Privacy Officer. This Privacy Officer will oversee all ongoing activities related to the development, implementation, and maintenance of the Practice privacy policies in accordance with applicable federal and state laws. The current Privacy Officer for the Company is:

Nevena Vuković,


The Company has established a Confidentiality / Security Team made up of key personnel whose responsibility it is to identify areas of concern within the Company and act as the first line of defense in enhancing the appropriate security posture.

All members identified within this policy are assigned to their positions by the GM. The term of each member assigned is at the discretion of the GM, but generally it is expected that the term will be one year. Members for each year will be assigned at the first meeting of the Quality Council in a new calendar year. This committee will consist of the positions within the Company most responsible for the overall security policy planning of the organization- the GM, PO, CMO, ISO, and the CIO (where applicable). The current members of the CST are:

Ivica Stanković,
Bojana Stanković,
Žarko Kovačević,

The Privacy Officer (PO) or other assigned personnel is responsible for maintaining a log of security enhancements and features that have been implemented to further protect all sensitive information and assets held by the Company. This log will also be reviewed during the quarterly meetings.

1.6                EMPLOYEE REQUIREMENTS

The first line of defense in data security is the individual Company user. Company users are responsible for the security of all data which may come to them in whatever format. The Company is responsible for maintaining ongoing training programs to inform all users of these requirements.

Home Use of Company Corporate Assets – Only computer hardware and software owned by and installed by the Company is permitted to be connected to or installed on Company equipment. Only software that has been approved for corporate use by the Company may be installed on Company equipment. Personal computers supplied by the Company are to be used solely for business purposes. All employees and contractors must read and understand the list of prohibited activities that are outlined below. Modifications or configuration changes are not permitted on computers supplied by the Company for home use.

Retention of Ownership – All software programs and documentation generated or provided by employees, consultants, or contractors for the benefit of the Company are the property of the Company unless covered by a contractual agreement. Nothing contained herein applies to software purchased by Company employees at their own expense.

1.7                PROHIBITED ACTIVITIES

Personnel are prohibited from the following activities. The list is not inclusive. Other prohibited activities are referenced elsewhere in this document.

  • Crashing an information system. Deliberately crashing an information system is strictly Users may not realize that they caused a system crash, but if it is shown that the crash occurred because of user action, a repetition of the action by that user may be viewed as a deliberate act.
  • Attempting to break into an information resource or to bypass a security feature. This includes running password-cracking programs or sniffer programs, and attempting to circumvent file or other resource permissions.
  • Introducing, or attempting to introduce, computer viruses, Trojan horses, peer-to-peer (“P2P”) or other malicious code into an information system.
  • Exception: Authorized information system support personnel, or others authorized by the Company Privacy Officer, may test the resiliency of a Such personnel may test for susceptibility to hardware or software failure, security against hacker attacks, and system infection.
  • Browsing. The willful, unauthorized access or inspection of confidential or sensitive information to which you have not been approved on a “need to know” basis is prohibited.
  • Personal or Unauthorized Software. Use of personal software is All software installed on Company computers must be approved by the Company.
  • Software Use. Violating or attempting to violate the terms of use or license agreement of any software product used by the Company is strictly prohibited.
  • System Use. Engaging in any activity for any purpose that is illegal or contrary to the policies, procedures or business interests of the Company is strictly prohibited.


As a productivity enhancement tool, The Company encourages the business use of electronic communications. However, all electronic communication systems and all messages generated on or handled by Company owned equipment are considered the property of the Company – not the property of individual users. Consequently, this policy applies to all Company employees and contractors, and covers all electronic communications including, but not limited to, telephones, e-mail, voice mail, instant messaging, Internet, fax, personal computers, and servers.

Company provided resources, such as individual computer workstations or laptops, computer systems, networks, e-mail, and Internet software and services are intended for business purposes. However, incidental personal use is permissible as long as:

  1. it does not consume more than a trivial amount of employee time or resources,
  2. it does not interfere with staff productivity,
  3. it does not preempt any business activity,
  4. it does not violate any of the following:
    1. Copyright violations
    2. Illegal activities
    3. Commercial use
    4. Political Activities
    5. Harassment
    6. Junk E-mail

Generally, while it is NOT the policy of the Company to monitor the content of any electronic communication, the Company is responsible for servicing and protecting the Company’s equipment, networks, data, and resource availability and therefore may be required to access and/or monitor electronic communications from time to time.

The Company reserves the right, at its discretion, to review any employee’s files or electronic communications to the extent necessary to ensure all electronic media and services are used in compliance with all applicable laws and regulations as well as Company policies.

Employees should structure all electronic communication with recognition of the fact that the content could be monitored, and that any electronic communication could be forwarded, intercepted, printed, or stored by others.

1.9                INTERNET ACCESS

Internet access is provided for Company users and is considered a great resource for the organization. This resource is costly to operate and maintain, and must be allocated primarily to those with business, administrative or contract needs. The Internet access provided by the Company should not be used for entertainment, listening to music, viewing the sports highlight of the day, games, movies, etc. Do not use the Internet as a radio or to constantly monitor the weather or stock market results.

Users must understand that individual Internet usage is monitored, and if an employee is found to be spending an excessive amount of time or consuming large amounts of bandwidth for personal use, disciplinary action will be taken.


Users should inform the appropriate Company personnel when the user’s software does not appear to be functioning correctly. The malfunction – whether accidental or deliberate – may pose an information security risk. If the user, or the user’s manager or supervisor, suspects a computer virus infection, the Company computer virus policy should be followed, and these steps should be taken immediately:

  • Stop using the computer.
  • Do not carry out any commands, including commands to data.
  • Do not close any of the computer’s windows or programs.
  • Do not turn off the computer or peripheral devices.
  • If possible, physically disconnect the computer from networks to which it is attached.
  • Inform the appropriate personnel or Company as soon as possible. Write down any unusual behavior of the computer (screen messages, unexpected disk access, unusual responses to commands) and the time when they were first noticed.
  • Write down any changes in hardware, software, or software use that preceded the malfunction.
  • Do not attempt to remove a suspected virus!

The ISO should monitor the resolution of the malfunction or incident, and report to the CST the result of the action with recommendations on action steps to avert future similar occurrences.


It is the responsibility of each Company employee or contractor to report perceived security incidents on a continuous basis to the appropriate supervisor or security person. A User is any person authorized to access an information resource. Users are responsible for the day-to- day, hands-on security of that resource. Users are to formally report all security incidents or violations of the security policy immediately to the Privacy Officer Users should report any perceived security incident to either their immediate supervisor, or to their department head, or to any member of the Company CST. Members of the CST are specified above in this document.

Reports of security incidents shall be escalated as quickly as possible. Each member of the Company CST must inform the other members as rapidly as possible. Each incident will be analyzed to determine if changes in the existing security structure are necessary. All reported incidents are logged, and the remedial action indicated. It is the responsibility of the CST to provide training on any procedural changes that may be required as a result of the investigation of an incident.

Security breaches shall be promptly investigated. If criminal action is suspected, the Company Privacy Officer shall contact the appropriate law enforcement and investigative authorities immediately.


When confidential or sensitive information from one individual is received by another individual while conducting official business, the receiving individual shall maintain the confidentiality or sensitivity of the information in accordance with the conditions imposed by the providing individual. All employees must recognize the sensitive nature of data maintained by the Company and hold all data in the strictest confidence. Any purposeful release of data to which an employee may have access is a violation of Company policy and will result in personnel action and may result in legal action.


Personal software shall not be used on Company computers or networks. If a need for specific software exists, submit a request to your supervisor or department head. Users shall not use Company purchased software on home or on non- Company computers or equipment.

Company proprietary data, including but not limited to information, IT Systems information, financial information, or human resource data, shall not be placed on any computer that is not the property of the Company without written consent of the respective supervisor or department head.

The Company Wide Area Network (“WAN”) is maintained with a wide range of security protections in place, which include features such as virus protection, e-mail file type restrictions, firewalls, anti-hacking hardware and software, etc. Since the Company does not control non- Company personal computers, the Company cannot be sure of the methods that may or may not be in place to protect Company sensitive information, hence the need for this restriction.


Special precautions are required to block Internet (public) access to Company information resources not intended for public access, and to protect confidential Company information when it is to be transmitted over the Internet.

The following security and administration issues shall govern Internet usage.

Prior approval of the Company Privacy Officer or appropriate personnel authorized by the Company shall be obtained before:

  • An Internet, or other external network connection, is established;
  • Company information (including notices, memoranda, documentation and software) is made available on any Internet-accessible computer (e.g. web or ftp server) or device;
  • Users may not install or download any software (applications, screen savers, ). If users have a need for additional software, the user is to contact their supervisor;
  • Use shall be consistent with the goals of the Company. The network can be used to market services related to the Company, however use of the network for personal profit or gain is
  • Confidential or sensitive data – including credit card numbers, telephone calling card numbers, logon passwords, and other parameters that can be used to access goods or services – shall be encrypted before being transmitted through the Internet.
  • The encryption software used, and the specific encryption keys (e.g., passwords, pass phrases), shall be escrowed with the Company Privacy Officer or appropriate personnel, to ensure they are safely maintained/stored. The use of encryption software and keys, which have not been escrowed as prescribed above, is prohibited, and may make the user subject to disciplinary action.


Any user desiring to transfer secure e-mail with a specific identified external user may request to exchange public keys with the external user. Once verified, the certificate is installed on both recipients’ workstations, and the two may safely exchange secure e-mail.


This software allows Company personnel to exchange e-mail with remote users who have the appropriate encryption software on their system. The two users exchange private keys that will be used to both encrypt and decrypt each transmission. Any Company staff member who desires to utilize this technology may request this software from the Privacy Officer or appropriate personnel.

1.16             USER LOGON IDS

Individual users shall have unique logon IDs and passwords. An access control system shall identify each user and prevent unauthorized users from entering or using information resources. Security requirements for user identification include:

  • Each user shall be assigned a unique identifier.
  • Users shall be responsible for the use and misuse of their individual logon ID.

All user login IDs are audited at least twice yearly and all inactive logon IDs are revoked. The Company Human Resources Department notifies the Security Officer or appropriate personnel upon the departure of all employees and contractors, at which time login IDs are revoked.

The logon ID is locked or revoked after a maximum of three (3) unsuccessful logon attempts which then require the passwords to be reset by the appropriate Administrator.

Users who desire to obtain access to Company tice systems or networks must have a completed and signed Network Access Form. This form must be signed by the supervisor or department head of each user requesting access.

1.17             PASSWORDS User Account Passwords

User IDs and passwords are required gain access to all Company networks and workstations. All passwords are restricted by a corporate-wide password policy to be of a “Strong” nature. This means that all passwords must conform to restrictions and limitations that are designed to make the password difficult to guess. Users are required to select a password obtain access to any electronic information both at the server level and at the workstation level. When passwords are reset, the user will be automatically prompted to manually change that assigned password.

Password Length – Passwords are required to be a minimum of eight characters.

Content Requirements – Passwords must contain a combination of upper and lower case alphabetic characters, numeric characters, and special characters.

Change Frequency – Passwords must be changed every 365 days. Compromised passwords  shall be changed immediately.

Reuse – The previous six passwords cannot be reused.

Restrictions on Sharing Passwords – Passwords shall not be shared, written down on paper, or stored within a file or database on a workstation and must be kept confidential.

Restrictions on Recording Passwords – Passwords are masked or suppressed on all online screens, and are never printed or included in reports or logs. Passwords are stored in an encrypted format.


Users of Company information resources shall sign, as a condition for employment, an appropriate confidentiality agreement. The agreement shall include the following statement, or a paraphrase of it:

I understand that any unauthorized use or disclosure of information residing on the Company information resource systems may result in disciplinary action consistent with the policies and procedures of federal, state, and local agencies.

Temporary workers and third-party employees not already covered by a confidentiality agreement shall sign such a document prior to accessing Company information resources.

Confidentiality agreements shall be reviewed when there are changes to contracts or other terms of employment, particularly when contracts are ending or employees are leaving an organization.

1.19             ACCESS CONTROL

Information resources are protected by the use of access control systems. Access control systems include both internal (i.e. passwords, encryption, access control lists, constrained user interfaces, etc.) and external (i.e. port protection devices, firewalls, host-based authentication, etc.).

Rules for access to resources (including internal and external telecommunications and networks) have been established by the information/application owner or manager responsible for the resources. Access is granted only by the completion of a Network Access Request Form. This form can only be initiated by the appropriate department head and must be signed by the department head and the Security Officer or appropriate personnel.

This guideline satisfies the “need to know” requirement of the regulation, since the supervisor or department head is the person who most closely recognizes an employee’s need to access data. Users may be added to the information system, network, or EHR only upon the signature of the Security Officer or appropriate personnel who is responsible for adding the employee to the network in a manner and fashion that ensures the employee is granted access to data only as specifically requested.

Identification and Authentication Requirements

The host security management program shall maintain current user application activity authorizations. Each initial request for a connection or a session is subject to the authorization process previously addressed.


If an employee changes positions at the Company, employee’s new supervisor or department head shall promptly notify the Information Technology (“IT”) Department of the change of roles by indicating on the Network Access Request Form both the roles or access that need to be added and the roles or access that need to be removed so that employee has access to the minimum necessary data to effectively perform their new job functions.

No less than annually, the IT Manager shall facilitate entitlement reviews with department heads to ensure that all employees have the appropriate roles, access, and software necessary to perform their job functions effectively while being limited to the minimum necessary data to facilitate compliance and protect data.


Upon termination of an employee, whether voluntary or involuntary, employee’s supervisor or department head shall promptly notify the IT Department by indicating “Remove Access” on the employee’s Network Access Request Form and submitting the Form to the IT.

Department. If employee’s termination is voluntary and employee provides notice, employee’s supervisor or department head shall promptly notify the IT Department of employee’s last scheduled work day so that their user account(s) can be configured to expire. The employee’s department head shall be responsible for ensuring that all keys, ID badges, and other access devices as well as Company equipment and property is returned to the Company prior to the employee leaving the Company on their final day of employment.


Certain direct link connections may require a dedicated or leased phone line. These facilities are authorized only by the Privacy Officer or appropriate personnel and ordered by the appropriate personnel. Telecommunication equipment and services include but are not limited to the following:

  • phone lines
  • phone headsets
  • software type phones installed on workstations
  • mobile phones
  • iPhone type devices
  • call routing software
  • call reporting software
  • phone system administration equipment
  • local phone lines
  • telephone equipment


The security of Company systems can be jeopardized from third party locations if security practices and resources are inadequate. When there is a need to connect to a third-party location, a risk analysis should be conducted. The risk analysis should consider the type of access required, the value of the information, the security measures employed by the third party, and the implications for the security of Company systems. The Privacy Officer or appropriate personnel should be involved in the process, design and approval.


Access to Company computer systems or corporate networks should not be granted until a review of the following concerns has been made, and appropriate restrictions or covenants included in a statement of work (“SOW”) with the party requesting access.

  • Applicable sections of the Company Information Security Policy have been reviewed and considered.
  • Policies and standards established in the Company information security program have been enforced.
  • A risk assessment of the additional liabilities that will attach to each of the parties to the agreement.
  • The right to audit contractual responsibilities should be included in the agreement or SOW.
  • A description of each service to be made available.
  • Each service, access, account, and/or permission made available should only be the minimum necessary for the third party to perform their contractual obligations.
  • A detailed list of users that have access to the Company computer systems must be maintained and auditable.
  • If required under the contract, permission should be sought to screen authorized users.
  • Dates and times when the service is to be available should be agreed upon in advance.
  • Procedures regarding protection of information resources should be agreed upon in advance and a method of audit and enforcement implemented and approved by both parties.
  • The right to monitor and revoke user activity should be included in each agreement.
  • Language restrictions on copying and disclosing information should be included in all agreements.
  • Responsibilities regarding hardware and software installation and maintenance should be understood and agreed upon in agreements.
  • Measures to ensure the return or destruction of programs and information at the end of the contract should be written in the agreement.
  • If physical protection measures are necessary because of contract stipulations, these should be included in the agreement.
  • A formal method to grant authorized users who will access to the data collected under the agreement should be formally established before any users are granted access.
  • Mechanisms should be in place to ensure that security measures are being followed by all parties to the agreement.
  • A detailed list of the security measures which will be undertaken by all parties to the agreement should be published in advance of the agreement.

1.25             FIREWALLS

Authority from the Privacy Officer or appropriate personnel must be received before any employee or contractor is granted access to a Company router or firewall.

2                    Malicious Code


Antivirus software is installed on all Company personal computers and servers. Virus update patterns are updated daily on the Company servers and workstations. Virus update engines and data files are monitored by appropriate administrative staff that is responsible for keeping all virus patterns up to date.


Only software created by Company application staff, if applicable, or software approved by the Privacy Officer or appropriate personnel will be used on internal computers and networks. All new software will be tested by appropriate personnel in order to ensure compatibility with the currently installed software and network configuration. In addition, appropriate personnel must scan all software for viruses before installation.

Although shareware and freeware can often be useful sources of work-related programs, the use and/or acquisition of such software must be approved by the Privacy Officer or appropriate personnel.

All data and program files that have been electronically transmitted to a Company computer or network from another location must be scanned for viruses immediately after being received. Contact the appropriate Company personnel for instructions for scanning files for viruses.

Every CD-ROM, DVD and USB device is a potential source for a computer virus. Therefore, it be scanned for virus infection prior to copying information to a Company computer or network.

Computers shall never be “booted” from a CD-ROM, DVD or USB device received from an outside source. Users shall always remove, CD-ROM, DVD or USB device   from the computer when not in use. This is to ensure that the CD-ROM, DVD or USB device is not in the computer when the machine is powered on. A CD-ROM, DVD or USB device infected with a boot virus may infect a computer in that manner, even if the, CD-ROM, DVD or USB device is not “bootable”.

2.3                RETENTION OF OWNERSHIP

All software programs and documentation generated or provided by employees, consultants, or contractors for the benefit of the Company are the property of the Company unless covered by a contractual agreement. Employees developing programs or documentation must sign a statement acknowledging Company ownership at the time of employment.

Nothing contained herein applies to software purchased by Company employees at their own expense.

3               Encryption

3.1                DEFINITION

Encryption is the translation of data into a secret code. Encryption is the most effective way to achieve data security. To read an encrypted file, you must have access to a secret key or password that enables you to decrypt it. Unencrypted data is called plain text; encrypted data is referred to as cipher text.

3.2                ENCRYPTION KEY

An encryption key specifies the particular transformation of plain text into cipher text, or vice versa during decryption.

If justified by risk analysis, sensitive data and files shall be encrypted before being transmitted through networks. When encrypted data are transferred between agencies, the agencies shall devise a mutually agreeable procedure for secure key management. In the case of conflict, the Company shall establish the criteria in conjunction with the Privacy Officer or appropriate personnel. The Company employs several methods of secure data transmission.


4              Telecommuting

With the increased availability of broadband access and VPNs, telecommuting has become more viable for many organizations. The Company considers telecommuting to be an acceptable work arrangement in certain circumstances. This policy is applicable to all employees and contractors who work either permanently or only occasionally outside of the Company office environment. It applies to users who work from their home full time to employees on temporary travel, to users who work from a remote office location, and to any user who connects to the Company network and/or hosted EHR, if applicable, from a remote location.

While telecommuting can be an advantage for users and for the organization in general, it presents new risks in the areas of confidentiality and security of data. Workers linked to the Company’s network become an extension of the wide area network and present additional environments that must be protected against the danger of spreading Trojans, viruses, or other malware. This arrangement also exposes the corporate as well as data to risks not present in the traditional work environment.

4.1                GENERAL REQUIREMENTS

Telecommuting workers are required to follow all corporate, security, confidentiality, HR, or Code of Conduct policies that are applicable to other employees/contractors.

  • Need to Know: Telecommuting Users will have access based on the same ‘need to know’ as they have when in the office.
  • Password Use: The use of a strong password, is even more critical in the telecommuting environment. Do not share your password or write it down where a family member or visitor can see it.
  • Training: Personnel who telecommute must complete the same annual privacy training as all other employees.
  • Contract Specific: There may be additional requirements specific to the individual contracts to which an employee is assigned.

4.2                REQUIRED EQUIPMENT

Employees approved for telecommuting must understand that the Company will not provide all equipment necessary to ensure proper protection of information to which the employee has access; however, the following lists define the equipment and environment required:

Company Provided:

Company supplied desktop or laptop.

If using VPN, a Company issued hardware firewall is required. If printing, a Company supplied printer.

If approved by your supervisor, a Company supplied phone.

Employee Provided:

Broadband connection and fees,

A lockable file cabinet or safe to secure documents when away from the home office.


Virus Protection: Home users must never stop the update process for Virus Protection. Virus Protection software is installed on all Company personal computers and is set to update the virus pattern daily. This update is critical to the security of all data and must be allowed to complete.

VPN and Firewall Use: Established procedures must be rigidly followed when accessing Company information of any type. The Company requires the use of VPN software and a firewall device. Disabling a virus scanner or firewall is reason for termination.

Lock Screens: No matter what location, always lock the screen before walking away from the workstation. The data on the screen may be protected or may contain confidential information. Be sure the automatic lock feature has been set to automatically turn on after 15 minutes of inactivity.


Data Backup: Backup procedures have been established that encrypt the data being moved to an external media. Use only that procedure – do not create one on your own. If there is not a backup procedure established, or if you have external media that is not encrypted, contact the appropriate Company personnel for assistance. Protect external media by keeping it in your possession when traveling.

Transferring Data to the Company: Transferring of data to the Company requires the use of an approved VPN connection to ensure the confidentiality and integrity of the data being transmitted. Do not circumvent established procedures, nor create your own method, when transferring data to the Company.

External System Access: If you require access to an external system, contact your supervisor or department head. Privacy Officer or appropriate personnel will assist in establishing a secure method of access to the external system.

E-mail: Do not send any individual-identifiable information via e-mail unless it is encrypted. If you need assistance with this, contact the Privacy Officer or appropriate personnel to ensure an approved encryption mechanism is used for transmission through e-mail.

Non- Company Networks: Extreme care must be taken when connecting Company equipment to a home or hotel network. Although the Company actively monitors its security status and maintains organization wide protection policies to protect the data within all contracts, the Practice has no ability to monitor or control the security procedures on non- Company networks.

Protect Data in Your Possession: View or access only the information that you have a need to see to complete your work assignment. Regularly review the data you have stored to ensure that the amount of level data is kept at a minimum and that old data is eliminated as soon as possible. Store electronic data only in encrypted workspaces. If your laptop has not been set up with an encrypted workspace, contact the Privacy Officer or appropriate personnel for assistance.

Hard Copy Reports or Work Papers: Never leave paper records around your work area. Lock all paper records in a file cabinet at night or when you leave your work area.

Data Entry When in a Public Location: Do not perform work tasks which require the use of sensitive corporate information when you are in a public area, i.e. airports, airplanes, hotel lobbies. Computer screens can easily be viewed from beside or behind you.

Sending Data Outside the Company: All external transfer of data must be associated with an official contract, non-discloser agreement, or appropriate Business Associate Agreement. Do not give or transfer information to anyone outside the Company without the written approval of your supervisor.


  • Do not throw any media containing sensitive, protected information in the trash.
  • Return all external media to your supervisor.
  • External media must be wiped clean of all data. The Privacy Officer or appropriate personnel has very definitive procedures for doing this – so all external media must be sent to them.
  • The final step in this process is to forward the media for disposal by a certified destruction agency.

5             Specific Protocols and Devices


Due to an emergence of wireless access points in hotels, airports, and in homes, it has become imperative that a Wireless Usage policy be developed and adopted to ensure the security and functionality of such connections for Company employees. This policy outlines the processes and procedures for acquiring wireless access privileges, utilizing wireless access, and ensuring the security of Company laptops and mobile devices.

Approval Procedure In order to be granted the ability to utilize the wireless network interface on your Company laptop or mobile device you will be required to gain the approval of your immediate supervisor or department head and the Privacy Officer or appropriate personnel of the Company. The Network Access Request Form is used to make such a request. Once this form is completed and approved you will be contacted by appropriate Company personnel to setup your laptop and schedule training.

Software Requirements The following is a list of minimum software requirements for any Company laptop that is granted the privilege to use wireless access:

  • Windows, Linux, MacOS
  • Antivirus software
  • Full Disk Encryption
  • Appropriate VPN

If your laptop does not have all of these software components, please notify your supervisor or department head so these components can be installed.

Training Requirements Once you have gained approval for wireless access on your Company computer, you will be required to attend a usage and security training session to be provided by the Privacy Officer or appropriate personnel. This training session will cover the basics of connecting to wireless networks, securing your computer when connected to a wireless network, and the proper method for disconnecting from wireless networks. This training will be conducted within a reasonable period of time once wireless access approval has been granted, and in most cases will include several individuals at once.


Transportable media included within the scope of this policy includes, but is not limited to, SD cards, DVDs, CD-ROMs, and USB key devices.

The purpose of this policy is to guide employees/contractors of the Company in the proper use of transportable media when a legitimate business requirement exists to transfer data to and from Company networks. Every workstation or server that has been used by either Company employees or contractors is presumed to have sensitive information stored on its hard drive. Therefore, procedures must be carefully followed when copying data to or from transportable media to protect sensitive Company data. Since transportable media, by their very design, are easily lost, care and protection of these devices must be addressed. Since it is very likely that transportable media will be provided to a Company employee by an external source for the exchange of information, it is necessary that all employees have guidance in the appropriate use of media from other companies.

The use of transportable media in various formats is common practice within the Company. All users must be aware that sensitive data could potentially be lost or compromised when moved outside of Company networks. Transportable media received from an external source could potentially pose a threat to Company networks.

USB key devices are handy devices which allow the transfer of data in an easy to carry format. They provide a much-improved format for data transfer when compared to previous media formats, like diskettes, CD-ROMs, or DVDs. The software drivers necessary to utilize a USB key are normally included within the device and install automatically when connected. They now come in a rugged titanium format which connects to any key ring. These factors make them easy to use and to carry, but unfortunately easy to lose.

Rules governing the use of transportable media include:

  • No sensitive data should ever be stored on transportable media unless the data is maintained in an encrypted format.
  • All USB keys used to store Company data or sensitive data must be an encrypted USB key issued by the Privacy Officer or appropriate The use of a personal USB key is strictly prohibited.
  • Users must never connect their transportable media to a workstation that is not issued by the Company.
  • Non-Company workstations and laptops may not have the same security protection standards required by the Company, and accordingly virus patterns could potentially be transferred from the non-Company device to the media and then back to the Company workstation.

Example: Do not copy a work spreadsheet to your USB key and take it home to work on your home PC.

  • Data may be exchanged between Company workstations/networks and workstations used within the The very nature of data exchange requires that under certain situations data be exchanged in this manner.

6              Disposal of External Media / Hardware


The following steps must be adhered to:

  • It is the responsibility of each employee to identify media which should be shredded and to utilize this policy in its destruction.
  • External media should never be thrown in the trash.
  • When no longer needed all forms of external media are to be sent to the Privacy Officer or appropriate personnel for proper disposal.
  • The media will be secured until appropriate destruction methods are used based on NIST 800-88 guidelines.


All equipment to be disposed of will be wiped of all data, and all settings and configurations will be reset to factory defaults. No other settings, configurations, software installation or options will be made. Asset tags and any other identifying logos or markings will be removed.


As the older Company computers and equipment are replaced with new systems, the older machines are held in inventory for a wide assortment of uses:

  • Older machines are regularly utilized for spare parts.
  • Older machines are used on an emergency replacement basis.
  • Older machines are used for testing new software.
  • Older machines are used as backups for other production equipment.
  • Older machines are used when it is necessary to provide a second machine for personnel who travel on a regular basis.
  • Older machines are used to provide a second machine for personnel who often work from home.

7              Change Management

Statement of Policy

To ensure that Company is tracking changes to networks, systems, and workstations including software releases and software vulnerability patching in information systems that contain electronic protected information. Change tracking allows the Information Technology (“IT”) Department to efficiently troubleshoot issues that arise due to an update, new implementation, reconfiguration, or other change to the system.


  1. The IT staff or other designated Company employee who is updating, implementing, reconfiguring, or otherwise changing the system shall carefully log all changes made to the system.
    1. When changes are tracked within a system, i.e. Windows updates in the Add or Remove Programs component or electronic record updates performed and logged by the vendor, they do not need to be logged on the change management tracking log; however, the employee implementing the change will ensure that the change tracking is available for review if necessary.
  2. The employee implementing the change will ensure that all necessary data backups are performed prior to the change.
  3. The employee implementing the change shall also be familiar with the rollback process in the event that the change causes an adverse effect within the system and needs to be removed.

8            Information System Activity Review

Statement of Policy

To establish the process for conducting, on a periodic basis, an operational review of system activity including, but not limited to, user accounts, system access, file access, security incidents, audit logs, and access report. The Company shall conduct on a regular basis an internal review of records of system activity to minimize security violations.


  1. See policy entitled Audit Controls for a description of the technical mechanisms that track and record activities on Company’s information.
  2. The Information Technology Services shall be responsible for conducting reviews of the Company information systems’ Such person(s) shall have the appropriate technical skills with respect to the operating system and applications to access and interpret audit logs and related information appropriately.
  3. The Security Officer shall develop a report format to capture the review Such report shall include the reviewer’s name, date and time of performance, and significant findings describing events requiring additional action (e.g., additional investigation, employee training and/or discipline, program adjustments, modifications to safeguards). To the extent possible, such report shall be in a checklist format.
  4. Such reviews shall be conducted annually. Audits also shall be conducted if Company has reason to suspect wrongdoing. In conducting these reviews, the Information Technology Services shall examine audit logs for security-significant events including, but not limited to, the following:
    1. Logins – Scan successful and unsuccessful login Identify multiple failed login attempts, account lockouts, and unauthorized access.
    2. File accesses – Scan successful and unsuccessful file access Identify multiple failed access attempts, unauthorized access, and unauthorized file creation, modification, or deletion.
    3. Security incidents – Examine records from security devices or system audit logs for events that constitute system compromises, unsuccessful compromise attempts, malicious logic (e.g., viruses, worms), denial of service, or scanning/probing incidents.
    4. User Accounts – Review of user accounts within all systems to ensure users that no longer have a business need for information systems no longer have such access to the information and/or system.

All significant findings shall be recorded using the report format referred to in Section 2 of this policy and procedure.

  1. The Information Technology Services shall forward all completed reports, as well as recommended actions to be taken in response to the findings, to the Security Officer for review. The Security Officer shall be responsible for maintaining such reports. The Security Officer shall consider such reports and recommendations in determining whether to make changes to the Company’s administrative, physical, and technical safeguards. In the event a security incident is detected through such auditing, such matters shall be addressed pursuant to the policy entitled Employee Responsibilities (Report Security Incidents).

9          Data Integrity

Statement of Policy

Company shall implement and maintain appropriate electronic mechanisms to corroborate that has not been altered or destroyed in an unauthorized manner.

The purpose of this policy is to protect Company’s I from improper alteration or destruction.


To the fullest extent possible, Company shall utilize applications with built-in intelligence that automatically checks for human errors.

Company shall acquire appropriate network-based and host-based intrusion detection systems. The Security Officer shall be responsible for installing, maintaining, and updating such systems.

To prevent transmission errors as data passes from one computer to another, Company will use encryption, as determined to be appropriate, to preserve the integrity of data.

Company will check for possible duplication of data in its computer systems to prevent poor data integration between different computer systems.

To prevent programming or software bugs, Company will test its information systems for accuracy and functionality before it starts to use them. Company will update its systems when IT vendors release fixes to address known bugs or problems.

  1. Company will install and regularly update antivirus software on all workstations to detect and prevent malicious code from altering or destroying data.
  2. To prevent exposing magnetic media to a strong magnetic field, workforce members shall keep magnetic media away from strong magnetic fields and heat. For example, computers should not be left in automobiles during the summer months.

10        Contingency Plan

Statement of Policy

To establish and implement policies and procedures for responding to an emergency or other occurrence (e.g., fire, vandalism, system failure, natural disaster) that damages systems.

Company is committed to maintaining formal practices for responding to an emergency or other occurrence that damages. Company shall continually assess potential risks and vulnerabilities to protect information in its possession, and develop, implement, and maintain appropriate administrative, physical, and technical security measures in accordance with the security rule.


  1. Data Backup Plan
    1. Company, under the direction of the Security Officer, shall implement a data backup plan to create and maintain retrievable.
    2. At the conclusion of each day, Monday through Friday, an incremental backup of all servers shall be backed up to NAS. On Saturday, a full backup of all servers shall be backed up to One month of backup data will be maintained at all times in a remote location. Backup media that is no longer in service will be disposed of in accordance with the Disposal of External Media/Hardware policy.
    3. The Security Officer shall monitor storage and removal of backups and ensure all applicable access controls are enforced.
    4. The Security Officer shall test backup procedures on an annual basis to ensure that exact copies can be retrieved and made available. Such testing shall be documented by the Security Officer. To the extent such testing indicates need for improvement in backup procedures, the Security Officer shall identify and implement such improvements in a timely manner.
  2. Disaster Recovery and Emergency Mode Operations Plan
    1. The Security Officer shall be responsible for developing and regularly updating the written disaster recovery and emergency mode operations plan for the purpose of:
      1. Restoring or recovering any loss and/or systems necessary to make available in a timely manner caused by fire, vandalism, terrorism, system failure, or other emergency; and
      2. Continuing operations during such time information systems are Such written plan shall have a sufficient level of detail and explanation that a person unfamiliar with the system can implement the plan in case of an emergency or disaster. Copies of the plan shall be maintained on-site and at the off-site locations at which backups are stored or other secure off-site location.
    2. The disaster recovery and emergency mode operation plan shall include the following:
      1. Current copies of the information systems inventory and network configuration developed and updated as part of Company’s risk analysis.
      2. Current copy of the written backup procedures developed and updated pursuant to this policy.
      3. An inventory of hard copy forms and documents needed to record.
      4. Identification of an emergency response Members of such team shall be responsible for the following:
        1. Determining the impact of a disaster and/or system unavailability on Company’s operations.
        2. In the event of a disaster, securing the site and providing ongoing physical security.
        3. Retrieving lost data.
        4. Identifying and implementing appropriate “work-arounds” during such time information systems are unavailable.
        5. Taking such steps necessary to restore operations.
      5. Procedures for responding to loss of electronic data including, but not limited to retrieval and loading of backup data or methods for recreating data should backup data be The procedures should identify the order in which data is to be restored based on the criticality analysis performed as part of Company’s risk analysis.
      6. Telephone numbers and/or e-mail addresses for all persons to be contacted in the event of a disaster, including the following:
        1. Members of the immediate response team,
        2. Facilities at which backup data is stored,
        3. Information systems vendors, and
        4. All current workforce members.
    3. The disaster recovery team shall meet on at least an annual basis to:
      1. Review the effectiveness of the plan in responding to any disaster or emergency experienced by Company;
      2. In the absence of any such disaster or emergency, plan drills to test the effectiveness of the plan and evaluate the results of such drills; and
      3. Review the written disaster recovery and emergency mode operations plan and make appropriate changes to the plan. The Security Officer shall be responsible for convening and maintaining minutes of such The Security Officer also shall be responsible for revising the plan based on the recommendations of the disaster recovery team.

11         Security Awareness and Training

Statement of Policy

To establish a security awareness and training program for all members of Company’s workforce, including management.

All workforce members shall receive appropriate training concerning Company’s security policies and procedures. Such training shall be provided prior to the effective date of the security rule and on an ongoing basis to all new employees. Such training shall be repeated annually for all employees.


  1. Security Training Program
    1. The Security Officer shall have responsibility for the development and delivery of initial security All workforce members shall receive such initial training addressing the requirements of the security rule including the updates to regulations. Security training shall be provided to all new workforce members as part of the orientation process. Attendance and/or participation in such training shall be mandatory for all workforce members. The Security Officer shall be responsible for maintaining appropriate documentation of all training activities.
    2. The Security Officer shall have responsibility for the development and delivery of ongoing security training provided to workforce members in response to environmental and operational changes impacting the, addition of new hardware or software, and increased threats.
  2. Security Reminders
    1. The Security Officer shall generate and distribute to all workforce members routine security reminders on a regular Periodic reminders shall address password security, malicious software, incident identification and response, and access control. The Security Officer may provide such reminders through formal training, e-mail messages, discussions during staff meetings, screen savers, log-in banners, newsletter/intranet articles, posters, promotional items such as coffee mugs, mouse pads, sticky notes, etc. The Security Officer shall be responsible for maintaining appropriate documentation of all periodic security reminders.
    2. The Security Officer shall generate and distribute special notices to all workforce members providing urgent updates, such as new threats, hazards, vulnerabilities, and/or countermeasures.
  3. Protection from Malicious Software
    1. As part of the aforementioned Security Training Program and Security Reminders, the Security Officer shall provide training concerning the prevention, detection, containment, and eradication of malicious Such training shall include the following:
      1. Guidance on opening suspicious e-mail attachments, e-mail from unfamiliar senders, and hoax e-mail,
      2. The importance of updating anti-virus software and how to check a workstation or other device to determine if virus protection is current,
      3. Instructions to never download files from unknown or suspicious sources,
      4. Recognizing signs of a potential virus that could sneak past antivirus software or could arrive prior to an update to anti-virus software,
      5. The importance of backing up critical data on a regular basis and storing the data in a safe place,
      6. Damage caused by viruses and worms, and
      7. What to do if a virus or worm is
  4. Password Management
    1. As part of the aforementioned Security Training Program and Security Reminders, the Security Officer shall provide training concerning password management . Such training shall address the importance of confidential passwords in maintaining computer security, as well as the following requirements relating to passwords:
      1. Passwords must be changed every 365 days.
      2. A user cannot reuse the last 6 passwords.
      3. Passwords must be at least eight characters and contain upper case letters, lower case letters, numbers, and special characters.
      4. Commonly used words, names, initials, birthdays, or phone numbers should not be used as passwords.
      5. A password must be promptly changed if it is suspected of being disclosed, or known to have been disclosed.
      6. Passwords must not be disclosed to other workforce members (including anyone claiming to need a password to “fix” a computer or handle an emergency situation) or individuals, including family members.
      7. Passwords must not be written down, posted, or exposed in an insecure manner such as on a notepad or posted on the workstation.
      8. Employees should refuse all offers by software and/or Internet sites to automatically login the next time that they access those resources.
      9. Any employee who is directed by the Security Officer to change his/her password to conform to the aforementioned standards shall do so immediately.

12         Security Management Process

Statement of Policy

To ensure Company conducts an accurate and thorough assessment of the potential risks and vulnerabilities to the confidentiality, integrity, and availability.

Company shall conduct an accurate and thorough risk analysis to serve as the basis for Company’s security rule compliance efforts. Company shall re-assess the security risks and evaluate the effectiveness of its security measures and safeguards as necessary in light of changes to business practices and technological advancements.


  1. The Security Officer shall be responsible for coordinating Company’s risk The Security Officer shall identify appropriate persons within the organization to assist with the risk analysis.
  2. The risk analysis shall proceed in the following manner:
    1. Document Company’s current information systems.
      1. Update/develop information systems inventory. List the following information for all hardware (i.e., network devices, workstations, printers, scanners, mobile devices) and software (i.e., operating system, various applications, interfaces): date acquired, location, vendor, licenses, maintenance schedule, and function. Update/develop network diagram illustrating how organization’s information system network is configured.
      2. Update/develop facility layout showing location of all information systems equipment, power sources, telephone jacks, and other telecommunications equipment, network access points, fire and burglary alarm equipment, and storage for hazardous materials.
      3. For each application identified, identify each licensee (e., authorized user) by job title and describe the manner in which authorization is granted.
      4. For each application identified:
        1. Describe the data associated with that application.
        2. Determine whether the data is created by the organization or received from a third party. If data is received from a third party, identify that party and the purpose and manner of receipt.
        3. Determine whether the data is maintained within the organization only or transmitted to third parties. If data is transmitted to a third party, identify that party and the purpose and manner of transmission.
        4. Define the criticality of the application and related data as high, medium, or Criticality is the degree of impact on the organization if the application and/or related data were unavailable for a period of time.
        5. Define the sensitivity of the data as high, medium, or Sensitivity is the nature of the data and the harm that could result from a breach of confidentiality or security incident.
        6. For each application identified, identify the various security controls currently in place and locate any written policies and procedures relating to such controls.
      5. Identify and document threats to confidentiality, integrity, and availability (referred to as “threat agents”), received, maintained, or transmitted by Company. Consider the following:
        1. Natural threats, g., earthquakes, storm damage.
        2. Environmental threats, g., fire and smoke damage, power outage, utility problems.
        3. Human threats
          1. Accidental acts, e.g., input errors and omissions, faulty application programming or processing procedures, failure to update/upgrade software/security devices, lack of adequate financial and human resources to support necessary security controls
          2. Inappropriate activities, e.g., inappropriate conduct, abuse of privileges or rights, workplace violence, waste of corporate assets, harassment
          3. Illegal operations and intentional attacks, g., eavesdropping, snooping, fraud, theft, vandalism, sabotage, blackmail
          4. External attacks, g., malicious cracking, scanning, demon dialing, virus introduction
        4. Identify and document vulnerabilities in Company’s information A vulnerability is a flaw or weakness in security policies and procedures, design, implementation, or controls that could be accidentally triggered or intentionally exploited, resulting in unauthorized access, modification, denial of service, or repudiation (i.e., the inability to identify the source and hold some person accountable for an action). To accomplish this task, conduct a self- analysis utilizing the standards and implementation specifications to identify vulnerabilities.
    2. Determine and document probability and criticality of identified risks.
      1. Assign probability level, e., likelihood of a security incident involving identified risk.
        1. “Very Likely” (3) is defined as having a probable chance of occurrence.
        2. “Likely” (2) is defined as having a significant chance of occurrence.
        3. “Not Likely” (1) is defined as a modest or insignificant chance of occurrence.
      2. Assign criticality level.
        1. “High” (3) is defined as having a catastrophic impact on the practice including a significant number of records which may have been lost or compromised.
        2. “Medium” (2) is defined as having a significant impact including a moderate number of records within the practice which may have been lost or compromised.
        3. “Low” (1) is defined as a modest or insignificant impact including the loss or compromise of some records.
      3. Determine risk score for each identified risk. Multiply the probability score and criticality Those risks with a higher risk score require more immediate attention.
    3. Identify and document appropriate security measures and safeguards to address key vulnerabilities. To accomplish this task, review the vulnerabilities you have identified in relation to the standards and implementation specifications. Focus on those vulnerabilities with high risk scores, as well as specific security measures and safeguards required by the Security Rule.
    4. Develop and document an implementation strategy for critical security measures and safeguards.
      1. Determine timeline for implementation.
      2. Determine costs of such measures and safeguards and secure funding.
      3. Assign responsibility for implementing specific measures and safeguards to appropriate person(s).
      4. Make necessary adjustments based on implementation experiences.
      5. Document actual completion dates.
    5. Evaluate effectiveness of measures and safeguards following implementation and make appropriate adjustments.
  3. The Security Officer shall be responsible for identifying appropriate times to conduct follow-up evaluations and coordinating such evaluations. The Security Officer shall identify appropriate people within the organization to assist with such evaluations. Such evaluations shall be conducted upon the occurrence of one or more of the following events: changes in the security regulations; new federal, state, or local laws or regulations affecting the security; changes in technology, environmental processes, or business processes that may affect security policies or procedures; or the occurrence of a serious security incident. Follow-up evaluations shall include the following:
    1. Inspections, reviews, interviews, and analysis to assess adequacy of administrative and physical safeguards. Such evaluation shall include interviews to assess employee compliance; after-hours walk-through inspections to assess physical security, password protection (i.e., not posted), and workstation sessions terminated (i., employees logged out); review of latest security policies and procedures for correctness and completeness; and inspection and analysis of training, incident, and media logs for compliance.
    2. Analysis to assess adequacy of controls within the network, operating systems and applications. As appropriate, Company shall engage outside vendors to evaluate existing physical and technical security measures and make recommendations for improvement.



Policy and Procedure

Title: Information Security Policy  
Approval Date: 9/29/2023 Next Review:
Effective Date: 8/1/2023 Information Technology


Managing director Ivica Stanković, Belgrade, Serbia