Kibernetinio saugumo prieigos ir duomenų teisių politika

Data system owner determines the access roles to the system in relation to the tasks of users. The compliance of the actual access rights with the planned ones must be monitored and the rights reassessed at regular intervals.

When reviewing access rights, care must also be taken to minimize admin rights and eliminate unnecessary accounts.

The organization must maintain a list of partners who have access to confidential information. System vendors and processors of personal data are listed separately from other stakeholders because they play an active role in the processing of data.

A supplier agreement will be drawn up with all partners directly or indirectly involved in the processing of data. The aim is to ensure that there is no misunderstanding between the organization and the supplier of parties' obligations regarding to complying with security requirements.

The organization shall include in the supplier agreement, as appropriate:

• the data used by the supplier (and possible data classification) and staff receiving access to data
• rules on the acceptable use of data
• confidentiality requirements for data processing staff
• parties responsibilities in meeting regulatory requirements
• parties' concrete responsibilities in relation to data security (e.g. access control, monitoring)
• reporting and correcting incidents
• requirements for the use of subcontractors
• allowing auditing supplier processes and controls related to the contract (and committing to correcting non-conformities)
• a commitment to return or destroy data at the end of the contract
• the supplier's responsibility to comply with organization's security guidelines

To ensure authorized access and prevent unauthorized access to data and other related resources, the organization has defined and implemented clear rules for physical and logical access control.

Rules are implemented and enforced through several different tasks, but are also combined into an access control policy for clear communication and review.

All accounts, access rights and privileges should be traceable to the role responsible for them and the person who approved them.

A responsible person has been appointed for the provider companies, who monitors the provider's activities, communications and compliance with the contract.

Responsible person must have sufficient skills to analyze cyber security requirements depending on the criticality of the provider. Responsible person also ensures that the provider appoints an own responsible person to ensure compliance with the contract and facilitate cooperation.

Admin rights are managed through a formal process aimed at limiting the allocation of admin rights and controlling their use.

Regarding admin rights:

• expiration requirements are defined
• admin rights are granted only to usernames not used for normal everyday use
• normal day-to-day use may not be performed with an admin account

The organisation must manage all of it’s users and their privileges. This includes all third party users, which have access into the organisations data or systems.

The organisation must remove users entirely or remove privileges from them when they are no longer needed e.g when employee role changes.

The organization maintains a centralized record of the access rights granted to each user ID to data systems and services. This recording is used to review access rights at times of employment change or in the onboarding process of new colleagues joining the same role.