Information Security Policy Template
Company Name | [Company Name] |
Effective Date | [Date] |
Version | [Version Number, e.g., 1.0] |
Policy Owner | [CISO/IT Director] |
Document Classification | Confidential / Internal Use Only |
Purpose
This Information Security Policy establishes a comprehensive framework for protecting the confidentiality, integrity, and availability of [Company Name]'s information assets and technology infrastructure. It provides the foundation for a robust security program that safeguards sensitive data (including but not limited to cardholder data, personally identifiable information, intellectual property, and proprietary business information) against unauthorized access, disclosure, alteration, or destruction. This policy aims to ensure compliance with legal, regulatory, and contractual requirements (including PCI DSS 4.0.1), while supporting business objectives and enabling secure operations in an increasingly complex threat landscape.
Scope
This policy applies to all individuals accessing or using [Company Name]'s information assets, including employees, contractors, consultants, temporary staff, third-party service providers, and business partners. It covers all information assets owned, controlled, or processed by [Company Name], regardless of format (electronic, physical) or location (on-premises, cloud environments, remote work locations). This includes but is not limited to information systems, networks, applications, databases, endpoints, mobile devices, and physical facilities. The policy addresses security throughout the information lifecycle, from creation/acquisition through processing, storage, transmission, and disposal.
Roles and Responsibilities
Role/Group | Key Responsibilities |
---|---|
Board of Directors / Executive Management | - Provide strategic direction and oversight for the information security program - Approve the Information Security Policy and significant security investments - Ensure adequate resources are allocated to security initiatives - Review security status reports and key risk indicators |
CISO / IT Security Director | - Develop, implement, and maintain the information security program - Oversee security operations, risk management, and compliance activities - Report on security posture and significant risks to executive management - Coordinate security incident response - Serve as the primary point of contact for security matters |
Information Security Team | - Implement and operate security controls and monitoring systems - Conduct security assessments, vulnerability management, and penetration testing - Provide security guidance and subject matter expertise - Investigate security incidents and support remediation efforts - Develop and deliver security awareness training |
IT Department | - Implement technical security controls in accordance with policies - Maintain secure configurations for systems and network infrastructure - Apply security patches and updates in a timely manner - Support security monitoring and incident response activities |
Department Managers / Data Owners | - Identify and classify sensitive data within their areas of responsibility - Ensure department staff comply with security policies - Approve access to information resources under their control - Participate in risk assessments and business continuity planning |
Human Resources | - Conduct background checks for new employees - Include security responsibilities in job descriptions - Coordinate security awareness training completion - Manage security aspects of employee onboarding and offboarding |
Legal / Compliance | - Advise on legal and regulatory security requirements - Review security-related contracts and agreements - Support breach notification processes - Monitor changes in applicable laws and regulations |
All Users | - Comply with all information security policies, standards, and procedures - Protect information assets and report security incidents promptly - Complete required security awareness training - Maintain confidentiality of sensitive information |
Policy Requirements
1. Risk Management
[Company Name] shall maintain a formal risk management program to identify, assess, and mitigate information security risks. Risk assessments shall be conducted at planned intervals and when significant changes occur to the information environment or business operations.
Key Requirements:
- Conduct enterprise-wide risk assessments at least annually
- Perform targeted risk assessments for new systems, applications, or significant changes
- Maintain a risk register documenting identified risks and treatment plans
- Review and update risk treatment plans regularly
- Integrate security considerations into project management and system development
For detailed requirements, refer to: Risk Management Policy
2. Information Classification and Handling
All information assets shall be classified according to sensitivity and business value, with appropriate handling procedures defined for each classification level. Classification determines the security controls required throughout the information lifecycle.
Key Requirements:
- Classify information into defined categories (e.g., Restricted, Confidential, Internal, Public)
- Label sensitive information according to its classification
- Handle, store, transmit, and dispose of information according to its classification
- Review and update classifications periodically
- Implement data loss prevention controls for sensitive information
For detailed requirements, refer to: Data Protection & Encryption Policy
3. Access Control
Access to information systems and data shall be restricted based on the principles of least privilege and need-to-know. Strong authentication mechanisms shall be implemented, and access rights shall be regularly reviewed and updated.
Key Requirements:
- Implement formal user access provisioning and deprovisioning processes
- Require unique identification for all users
- Implement multi-factor authentication for remote access and privileged accounts
- Review access rights at least quarterly
- Implement role-based access control where feasible
- Maintain segregation of duties for critical functions
- Log and monitor access to sensitive systems and data
For detailed requirements, refer to: Access Management Policy
4. Network Security
[Company Name] shall implement and maintain network security controls to protect the confidentiality, integrity, and availability of information transmitted across networks. This includes segmentation, encryption, monitoring, and protection against threats.
Key Requirements:
- Implement network segmentation, including isolation of the Cardholder Data Environment
- Deploy firewalls and intrusion detection/prevention systems
- Encrypt sensitive data transmitted over public networks
- Regularly review and update network security configurations
- Monitor network traffic for suspicious activities
- Secure wireless networks with strong encryption and authentication
- Conduct regular vulnerability scans and penetration tests
For detailed requirements, refer to: Network Security Policy
5. System and Application Security
Systems and applications shall be securely configured, patched, and maintained throughout their lifecycle. Security requirements shall be integrated into system development, acquisition, and change management processes.
Key Requirements:
- Maintain secure configuration standards for all system components
- Implement a patch management process to address vulnerabilities promptly
- Conduct regular vulnerability assessments and remediate findings based on risk
- Protect systems against malware and other threats
- Securely decommission systems at end-of-life
- Implement security controls for mobile devices and remote access
- Conduct security testing before deployment to production
- Maintain separate development, test, and production environments
For detailed requirements, refer to: System & Configuration Management Policy and Vulnerability Management Policy
6. Secure Development
Security shall be integrated throughout the software development lifecycle. Applications shall be designed, developed, and tested with security in mind to prevent vulnerabilities and protect sensitive data.
Key Requirements:
- Train developers in secure coding practices
- Perform security code reviews and vulnerability assessments
- Test for common security vulnerabilities before deployment
- Implement secure authentication and session management
- Validate all input and encode output to prevent injection attacks
- Protect sensitive data in applications
- Maintain an inventory of all custom and third-party applications
For detailed requirements, refer to: Secure Development Policy
7. Encryption and Key Management
Sensitive data shall be protected using appropriate encryption technologies. Cryptographic keys shall be securely generated, stored, used, and destroyed according to industry standards and best practices.
Key Requirements:
- Encrypt cardholder data, personally identifiable information, and other sensitive data at rest and in transit
- Implement strong encryption algorithms and protocols
- Manage cryptographic keys securely throughout their lifecycle
- Document and implement key rotation procedures
- Protect cryptographic keys from unauthorized access
- Maintain an inventory of cryptographic keys and their purposes
For detailed requirements, refer to: Data Protection & Encryption Policy
8. Change Management
Changes to information systems, applications, and infrastructure shall follow a formal change management process to minimize risk and ensure security is maintained throughout the change lifecycle.
Key Requirements:
- Document and approve all changes before implementation
- Assess security impact of proposed changes
- Test changes before deployment to production
- Maintain separation of duties in the change process
- Document rollback procedures for all changes
- Review emergency changes retrospectively
- Regularly review and update security configurations
For detailed requirements, refer to: Change Management Policy
9. Physical and Environmental Security
Physical security controls shall be implemented to prevent unauthorized physical access to information systems and protect against environmental threats. Critical systems shall have appropriate environmental controls and monitoring.
Key Requirements:
- Implement physical access controls for facilities and secure areas
- Maintain visitor management procedures
- Protect against environmental threats (fire, water, temperature, power)
- Secure equipment against theft or unauthorized access
- Implement clean desk and clear screen policies
- Maintain logs of physical access to sensitive areas
- Securely dispose of physical media containing sensitive information
For detailed requirements, refer to: Physical Security Policy
10. Third-Party Security
Security requirements shall be established for relationships with third parties that access, process, store, or transmit information on behalf of [Company Name]. Third-party security shall be assessed before engagement and monitored throughout the relationship.
Key Requirements:
- Conduct security due diligence before engaging third parties
- Include security requirements in contracts and agreements
- Assess third-party compliance with security requirements
- Monitor third-party security posture throughout the relationship
- Manage risks associated with third-party access to systems and data
- Ensure secure return or destruction of data upon termination of relationship
- Maintain an inventory of all third-party relationships
For detailed requirements, refer to: Third Party Service Provider (TPSP) Management Policy
11. Incident Management
[Company Name] shall maintain an incident response capability to detect, report, assess, respond to, and learn from information security incidents. Incident response procedures shall be tested regularly to ensure effectiveness.
Key Requirements:
- Define and document incident response procedures
- Establish an incident response team with defined roles and responsibilities
- Report and respond to security incidents promptly
- Investigate root causes of incidents
- Document and communicate lessons learned
- Test incident response procedures at least annually
- Coordinate with external parties (law enforcement, regulators) as needed
For detailed requirements, refer to: Incident Response Plan
12. Business Continuity and Disaster Recovery
Business continuity and disaster recovery plans shall be developed and maintained to ensure the availability of critical information systems and data in the event of a disruption. Plans shall be tested regularly to verify effectiveness.
Key Requirements:
- Identify critical systems and recovery time objectives
- Develop and document business continuity and disaster recovery plans
- Implement backup and recovery procedures for critical systems and data
- Test recovery capabilities at least annually
- Train personnel on their roles in business continuity and disaster recovery
- Review and update plans based on test results and organizational changes
- Maintain redundancy for critical systems and infrastructure
For detailed requirements, refer to: Business Continuity and Disaster Recovery Policy
13. Compliance
[Company Name] shall comply with applicable legal, regulatory, and contractual requirements related to information security. Compliance shall be regularly assessed and documented.
Key Requirements:
- Identify and document applicable compliance requirements
- Implement controls to meet compliance requirements
- Conduct regular compliance assessments
- Remediate compliance gaps in a timely manner
- Maintain evidence of compliance activities
- Monitor changes to compliance requirements
- Report compliance status to executive management
For detailed requirements, refer to: Governance-Compliance Policy
14. Security Awareness and Training
All personnel shall receive appropriate information security awareness education and training. Role-specific security training shall be provided based on job responsibilities and access to sensitive information.
Key Requirements:
- Provide security awareness training for all personnel upon hire and at least annually
- Deliver role-specific security training for personnel with specialized security responsibilities
- Communicate security policies, procedures, and updates to all personnel
- Conduct phishing simulations and other security awareness exercises
- Maintain records of security training completion
- Evaluate the effectiveness of security awareness programs
- Provide additional training when significant changes occur
For detailed requirements, refer to: Security Awareness and Training Policy
15. Acceptable Use
[Company Name] shall define acceptable use requirements for information systems, networks, applications, and data to ensure they are used responsibly and securely in accordance with business objectives and security policies.
Key Requirements:
- Use company information systems and resources for authorized business purposes
- Protect authentication credentials (passwords, tokens, smart cards)
- Maintain confidentiality of sensitive information
- Use email and internet services responsibly and securely
- Comply with software licensing agreements
- Report security incidents and suspicious activities promptly
- Adhere to clean desk and clear screen policies
- Use only authorized software and hardware
- Secure mobile devices, laptops, and removable media
- Exercise caution when working in public places
- Comply with data protection and privacy requirements
- Understand that [Company Name] may monitor system usage
- Acknowledge that violations may result in disciplinary action
For detailed requirements, refer to: Acceptable Use Policy and AI Acceptable Use Policy
Enforcement
- Compliance with this Information Security Policy and its supporting policies is mandatory for all individuals within the scope of this policy.
- Violations may result in disciplinary action, up to and including termination of employment or contract, in accordance with [Company Name]'s HR policies and procedures.
- Security violations that may constitute criminal offenses may be reported to law enforcement authorities.
- Exceptions to this policy must be documented, risk-assessed, approved by the CISO/IT Director, and reviewed periodically. Exceptions involving high risks may require executive management approval.
Revision History
Version | Date | Author | Change Details |
---|---|---|---|
1.0 | [Date] | [Author Name] | Initial policy release |
[Ver #] | [Date] | [Author Name] | [Summary of changes] |
Approval
Name | Title | Signature | Date |
---|---|---|---|
[CEO Name] | Chief Executive Officer | [Date] | |
[CISO Name] | Chief Information Security Officer | [Date] |
Appendix A: Related Policies and Documents
Policy/Document | Description | Owner |
---|---|---|
Access Management Policy | Detailed requirements for user access management, authentication, and authorization | CISO/IT Security |
Acceptable Use Policy | Detailed requirements for appropriate use of information systems and resources | CISO/IT Security |
AI Acceptable Use Policy | Detailed requirements for responsible use of AI and Large Language Model technologies | CISO/IT Security |
Business Continuity and Disaster Recovery Policy | Requirements for ensuring business continuity and recovery from disruptions | CISO/Business Continuity Manager |
Change Management Policy | Requirements for managing changes to systems, applications, and infrastructure | CISO/IT Operations |
Data Protection & Encryption Policy | Requirements for data classification, protection, encryption, and key management | CISO/Data Protection Officer |
Endpoint & Cloud Security Policy | Requirements for securing endpoints, cloud services, and remote access | CISO/IT Security |
Governance-Compliance Policy | Requirements for security governance, compliance, and risk management | CISO/Compliance Officer |
Incident Response Plan | Procedures for detecting, reporting, and responding to security incidents | CISO/Incident Response Manager |
Network Security Policy | Requirements for securing network infrastructure and communications | CISO/Network Security |
Physical Security Policy | Requirements for physical access controls and environmental protections | CISO/Facilities Manager |
Secure Development Policy | Requirements for secure software development practices | CISO/Development Manager |
Security Awareness and Training Policy | Requirements for security awareness, education, and training | CISO/Training Coordinator |
System & Configuration Management Policy | Requirements for secure system configuration and maintenance | CISO/IT Operations |
Third Party Service Provider (TPSP) Management Policy | Requirements for managing security risks associated with third parties | CISO/Vendor Management |
Vulnerability Management Policy | Requirements for identifying, assessing, remediating, and monitoring security vulnerabilities | CISO/IT Security |
Multi-Tenant Service Provider Policy | Requirements for multi-tenant service providers | CISO/IT Security |
Your perspective on this PCI DSS requirement matters! Share your implementation experiences, challenges, or questions below. Your insights help other organizations improve their compliance journey and build a stronger security community.Comment Policy