SOC 2 Criteria: CC1.2, CC1.3, CC2.1, CC5.1, CC5.2, CC5.3
ISO 27001 Requirements: 6.2
ISO 27001 Annex A: A.5.1.1, A.6.1.5, A.6.2.1, A.6.2.2, A.7.1.2, A.7.2.2, A.7.2.3, A.7.3.1, A.11.2.8, A.11.2.9, A.12.6.1, A.18.1.2
Keywords: Corrective action, Security training, Clean desk
Userflow’s Information Security Policy has been developed to: establish a general approach to information security and the minimization of information misuse, compromise or loss; document security processes and measures; uphold ethical standards and meet the company’s regulatory, legal, contractual, and other obligations; control business risk; and ensure that the appropriate company image and reputation is presented.
This policy applies to:
This policy is the overarching policy over the rest of the security policies, which make up Userflow’s information security program (ISP). The series of security policies includes:
It is the policy of Userflow that information, as defined hereinafter, in all its forms–written, spoken, recorded electronically or printed–will be protected from accidental or intentional unauthorized modification, destruction or disclosure throughout its life-cycle. This protection includes an appropriate level of security over the equipment and software used to process, store, and transmit that information. Ultimately, the information security goal of Userflow is to maintain:
Userflow’s information security objectives, consistent with the company’s information security program are:
The acting Security Officer/CISO is responsible for:
The objectives and measures outlined by the ISP policies shall be maintained and enforced by the roles and responsibilities specified in each policy and the company Skills Matrix.
At minimum on an annual basis, a security and/or compliance committee composed of senior management and key personnel must discuss, evaluate and document the company’s ISP, ensuring strategic goals and objectives are continually being developed.
At a minimum on an annual basis, all ISP policies must be reviewed, modified and/or edited to meet necessary security standards. All policies must be signed and approved by authorized personnel.
Policies and/or procedures must be accessible to employees for review at all times via the compliance automation SaaS, Drata. Policies pertaining to positions must be reviewed and signed upon hire and on an annual basis by all employees.
Requests for any exceptions to any policies included within the ISP must be approved by Userflow’s Executive Management after proper review. Any approved exceptions will be reviewed annually.
Management shall ensure that employees, contractors and third party users:
All new hires are required to complete information security awareness training as part of their new employee onboarding process and annually thereafter. New hire onboarding will be completed within 30 days after the date the employee or contractor is hired. Ongoing training will include security and privacy requirements as well as training in the correct use of information assets and facilities.
Additional specialized training will be required for individuals responsible for maintaining system security. Specialized topics would include spam, phishing, OWASP Top Ten list, and SANS Top 25 list. In addition, consistent with assigned roles and responsibilities, incident response and contingency training to personnel will be done:
The organization will properly document that the training has been provided to all employees.
All employees are required to acknowledge in writing their understanding of the Information Security Program which includes a Code of Conduct upon hire and annually thereafter.
Authorized users will ensure that all sensitive/confidential materials, hardcopy or electronic, are removed from their workspace and locked away when the items are not in use or an employee leaves his/her workstation. This will also increase awareness about protecting sensitive information. As such:
Use of Userflow computers, networks, and Internet access is a privilege granted by management and may be revoked at any time for inappropriate conduct carried out on such systems, including, but not limited to:
Such access will be discontinued upon termination of employment, completion of contract, end of service of non-employee, or disciplinary action arising from violation of this policy. In the case of a change in job function and/or transfer, the original access code will be discontinued, and only reissued if necessary and a new request for access is approved.
All user IDs that have been inactive for thirty (30) days will be revoked. The privileges granted to users must be reevaluated by management annually. In response to feedback from management, systems administrators must promptly revoke all privileges no longer needed by users.
Remote Access Tools:
All remote access tools used to communicate between Userflow assets and other systems must comply with the following policy requirements:
Mobile Endpoint and Storage Devices
Protecting endpoint devices issued by Userflow or storing company data is the responsibility of every employee. This pertains to all devices that connect to the company network, regardless of ownership. Mobile endpoint and storage devices are defined to include: desktop systems (in telework environment), laptops, PDAs, mobile phones, plug-ins, Universal Serial Bus (USB) port devices, Compact Discs (CDs), Digital Versatile Discs (DVDs), flash drives, modems, handheld wireless devices, wireless networking cards, and any other existing or future mobile computing or storage device, either personally owned or Userflow owned. An inventory of company-owned assets will be properly maintained.
For endpoint devices:
For storage devices:
Userflow takes handling and safeguarding of intellectual property very seriously. Intellectual property rights include software or document copyright, design rights, trademarks, patents and source code licenses.
To ensure this the following procedures will be maintained:
Userflow will identify its information security requirements through utilizing different methods, ensure the results of the identification are documented and reviewed by all stakeholders, and will integrate the requirements and associated processes in early stages of projects.
The following terms and conditions of employment at Userflow are the contractual obligations for employees or contractors for the safeguarding of information. They include, but are not limited to:
Userflow’s discipline policy and procedures are designed to provide a structured corrective action process to improve and prevent a recurrence of undesirable employee behavior and performance issues. It has been designed to be consistent with Userflow cultural values, Human Resources (HR) best practices, and employment laws.
Userflow reserves the right to combine or skip steps depending on the facts of each situation and the nature of the offense. The level of disciplinary intervention may also vary. Some of the factors that will be considered are whether the offense is repeated despite coaching, counseling, or training, the employee’s work record, and the impact the conduct and performance issues have on the organization.
Step 1: Verbal Warning and Counseling
This initial step creates an opportunity for the immediate supervisor to schedule a meeting with an employee to bring attention to an existing performance, conduct or attendance issue. The supervisor should discuss with the employee the nature of the problem or the violation of company policies and procedures. The supervisor is expected to clearly describe expectations and the steps the employee must take to improve performance or resolve the problem.
Step 2: Formal Written Warning
If the employee does not promptly correct any performance, conduct or attendance issues that were identified in Step 1, a written warning will become formal documentation of the performance, conduct, or attendance issues and consequences. The employee will sign a copy of the document to acknowledge receipt and understanding of the formal warning. During Step 2, the immediate supervisor and HR representative will meet with the employee to review any additional incidents or information about the performance, conduct or attendance issues as well as any prior relevant corrective action plans. Management will outline the consequences for the employee of his or her continued failure to meet performance or conduct expectations.
A formal performance improvement plan (PIP) requiring the employee’s immediate and sustained corrective action will be issued after a Step 2 meeting. A warning outlining that the employee may be subject to additional discipline up to and including termination if immediate and sustained corrective action is not taken may also be included in the written warning.
Step 3: Suspension and Final Written Warning
There may be performance, conduct, or safety incidents so problematic and harmful that the most effective action may be the temporary removal of the employee from the workplace. When immediate action is necessary to ensure the safety of the employee or others, the immediate supervisor may suspend the employee pending the results of an investigation. Suspensions that are recommended as part of the normal progression of this progressive discipline policy and procedure are subject to approval from a next-level manager and HR.
Step 4: Recommendation for Termination of Employment
The last step in the progressive discipline procedure is a recommendation to terminate employment. Generally, Userflow will try to exercise the progressive nature of this policy by first providing warnings, a final written warning or suspension from the workplace before proceeding to a recommendation to terminate employment. However, Userflow reserves the right to combine and skip steps depending on the circumstances of each situation and the nature of the offense. Furthermore, employees may be terminated without prior notice or disciplinary action.
Management’s recommendation to terminate employment must be approved by HR and the supervisor’s immediate manager. Final approval may be required from the CEO.
Performance and Conduct Issues Not Subject to Progressive Discipline
Behavior that is illegal is not subject to progressive discipline, and such behavior may be reported to local law enforcement authorities. Theft, substance abuse, intoxication, fighting and other acts of violence at work are grounds for immediate termination.
Userflow Management, under the explicit authority granted by the company CEO, retains the authority and responsibility to monitor and enforce compliance with this Policy and other policies, standards, procedures, and guidelines. Monitoring activities may be conducted on an on-going basis or on a random basis whenever deemed necessary by Management and may require investigating the use of the Company’s information resources. The company reserves the right to review any and all communications and activities without notice.
Userflow will take appropriate precautions to ensure that monitoring activities are limited to the extent necessary to determine whether the communications or activities are in violation of Company policies, standards, procedures, and guidelines or in accordance with normal business processing performance or quality activities.
Violation of the controls established in this Policy is prohibited and will be appropriately addressed. Disciplinary actions for violations may include verbal and/or written warnings, suspension, termination, and/or other legal remedies and will be consistent with our published HR standards and practices.
|Version||Date||Editor||Description of Changes|
|V1||October 20th, 2021||Userflow||Initial Creation|