Data center security

BISIONA customer data is hosted by Oracle Cloud Infrastructure (OCI), which is certified SOC 2 Type 2. OCI maintains an impressive list of reports, certifications, and third-party assessments to ensure complete and ongoing state-of-the-art data center security. 

OCI infrastructure is housed in Oracle-controlled data centers throughout the world, and the data centers themselves are secured with a variety of physical controls to prevent unauthorized access. More information on OCI data centers and their security controls can be found here.

Application security

All communications between the BISIONA web application and the server are encrypted over TLS 1.2, which cannot be viewed by a third party. This level of encryption is used by banks and financial institutions. Data for BISIONA is encrypted at rest using AES-256 encryption.  

BISIONA maintains ongoing PCI compliance, abiding by stringent industry standards for storing, processing and transmitting credit card information online.  

BISIONA actively monitors ongoing security, performance and availability 24/7/365. We run automated security testing on an ongoing basis. We also contract a third party for penetration testing.  

Regarding privacy, we are members of the Privacy Shield framework, and you can view our full privacy policy here: https://www.bisiona.com/blog/legal-notice-and-privacy-policy/ 

Infrastructure security

BISIONA‘s infrastructure is hosted in a fully redundant, secured environment, with access restricted to operations support staff only. This allows us to leverage complete data and access segregation, firewall protection, and other security features. 

Security policy

BISIONA employs strict security standards and measures throughout the entire organization. Every team member is trained and kept up to date on the latest security protocols. We regularly undergo testing, training, and auditing of our practices and policies. 

1. Purpose, scope, and organization 

What is this document, why does it exist, what does it cover, and who oversees it? 

This policy defines behavioral, process, technical, and governance controls pertaining to security at BISIONA that all personnel are required to implement in order to ensure the confidentiality, integrity, and availability of the BISIONA service and data (“Policy”). All personnel must review and be familiar with the rules and actions set forth below.

This Policy defines security requirements for: 

• All BISIONA employees, contractors, consultants and any other third parties providing services to BISIONA (“personnel”),
• Management of systems, both hardware and software and regardless of locale, used to create, maintain, store, access, process or transmit information on behalf of BISIONA, including all systems owned by BISIONA, connected to any network controlled by BISIONA, or used in service of BISIONA’s business, including systems owned third party service providers, and
• Circumstances in which BISIONA has a legal, contractual, or fiduciary duty to protect data or resources in its custody.

In the event of a conflict, the more restrictive measures apply. 

1.1. Governance and evolution 

This Policy was created in close collaboration with and approved by BISIONA executives. At least annually, it is reviewed and modified as needed to ensure clarity, sufficiency of scope, concern for customer and personnel interests, and general responsiveness to the evolving security landscape and industry best practices. 

1.2. Security team 

The BISIONA security team oversees the implementation of this Policy, including

• Procurement, provisioning, maintenance, retirement, and reclamation of corporate computing resources, 
• All aspects of service development and operation related to security, privacy, access, reliability, and survivability, 
• Ongoing risk assessment, vulnerability management, incident response, and 
• Security-related human resources controls and personnel training. 

1.3. Risk management framework 

The security team maintains a Risk Management Framework derived from NIST SP 800-39 – “Managing Information Security Risk: Organization, Mission, and System View” and NIST SP 800-30 – “Guide for Conducting Risk Assessments”.

https://nvlpubs.nist.gov/nistpubs/legacy/sp/nistspecialpublication800-39.pdf 

Risk assessment exercises inform prioritization for ongoing improvements to BISIONA’s security posture, which may include changes to this Policy itself.

Our Risk Management Framework incorporates the following:

• Identification of relevant, potential threats. 
• A scheme for assessing the strength of implemented controls. 
• A scheme for assessing current risks and evaluating their severity. 
• A scheme for responding to risks. 

2. Personnel and office environment 

What are BISIONA’s expectations of its personnel and the workplace regarding systems and data? 

BISIONA is committed to protecting its customers, personnel, partners, and the company from illegal or damaging actions by individuals, either knowingly or unknowingly in the context of its established employment culture of openness, trust, maturity, and integrity.

This section outlines expected personnel behaviors affecting security and the acceptable use of computer systems at BISIONA. These rules are in place to protect our personnel and BISIONA itself, in that inappropriate use may expose customers and partners to risks including malware, viruses, compromise of networked systems and services, and legal issues.

2.1. Work behaviors 

The first line of defense in data security is the informed behavior of personnel, who play a significant role in ensuring the security of all data, regardless of format. Such behaviors include those listed in this section as well as any additional requirements specified in the employee handbook, specific security processes, and other applicable codes of conduct. 

Training 

All employees and contractors must complete the BISIONA security awareness and data handling training programs at least annually.

Unrecognized persons and visitors 

It is the responsibility of all personnel to take positive action to maintain physical security. Challenge any unrecognized person present in a restricted office location. Any challenged person who does not respond appropriately should be immediately reported to supervisory staff and the security team. All visitors to BISIONA offices must be registered as such or accompanied by a BISIONA employee.

Clean desk 

Personnel should maintain workspaces clear of sensitive or confidential material and take care to clear workspaces of such material at the end of each workday. 

Unattended devices 

Unattended devices must be locked. All devices will have an automatic screen lock function set to automatically activate upon no more than fifteen minutes of inactivity. 

Use of corporate assets 

Systems are to be used for business purposes in serving the interests of the company, and of our clients and partners in the course of normal business operations. Personnel are responsible for exercising good judgment regarding the reasonableness of personal use of systems. Only BISIONA-managed hardware and software is permitted to be connected to or installed on corporate equipment or networks and used to access BISIONA data. BISIONA-managed hardware and software includes those either owned by BISIONA or owned by BISIONA personnel but enrolled in a BISIONA device management system. Only software that has been approved for corporate use by BISIONA may be installed on corporate equipment. All personnel must read and understand the list of prohibited activities outlined in this Policy. Modifications or configuration changes are not permitted without explicit written consent by the BISIONA security team.

Removable storage, no backups, use of cloud storage 

Use of non-encrypted removable media such as USB drives is prohibited. Personnel may not configure work devices to make backups or copies of data outside corporate policies. Instead, personnel are expected to operate primarily “in the cloud” and treat local storage on computing devices as ephemeral. BISIONA data must be saved to company-approved secure cloud storage (e.g. Share Point) to ensure that even in the event of a corporate device being lost, stolen, or damaged, such artifacts will be immediately recoverable on a replacement device.

Forbidden activities 

The following activities are prohibited. Under certain conditions and with the explicit written consent of the security team, personnel may be exempted from certain of these restrictions during their legitimate job responsibilities (e.g. planned penetration testing, systems administration staff may have a need to disable the network access of a host if that host is disrupting production services). 

The list below is by no means exhaustive, but attempts to provide a framework for activities which fall into the category of unacceptable use. 

• Under no circumstances are personnel of BISIONA authorized to engage in any activity that is illegal under local, state, federal or international law while utilizing BISIONA-owned resources.

• Violations of the rights of any person or company protected by copyright, trade secret, patent or other intellectual property, or similar lOCI or regulations including, but not limited to, the installation or distribution of “pirated” or other software products that are not appropriately licensed for use by BISIONA.
• Violating or attempting to violate the terms of use or license agreement of any software product used by BISIONA is strictly prohibited.
• Unauthorized copying of copyrighted material including, but not limited to, digitization and distribution of photographs from magazines, books or other copyrighted sources, copyrighted music, and the installation of any copyrighted software for which BISIONA or the end user does not have an active license is strictly prohibited.
• Exporting software, technical information, encryption software or technology may result in a violation of international or regional export control on OCI. The appropriate management should be consulted prior to the export of any material that is in question. 
• Revealing your account password to others or allowing use of your account by others. This includes colleagues, as well as family and other household members when work is being done at home. 

• Making fraudulent offers of products, items, or services originating from any BISIONA account.
• Making statements about warranty, expressly or implied, unless it is a part of normal job duties and then only to the extent the warranties are consistent with BISIONA’s authorized warranties.
• Introduction of malicious programs into the network or server (e.g., viruses, worms, Trojan horses, e-mail bombs, etc.). 
• Effecting security breaches or disruptions of network communication. Security breaches include, but are not limited to, accessing data of which the employee is not an intended recipient or logging into a server or account that the employee is not expressly authorized to access. For purposes of this section, “disruption” includes, but is not limited to, network sniffing, ping floods, packet spoofing, denial of service, and forged routing information for malicious or unlawful purposes. 
• Except by or under the direct supervision of the security team, port scanning or security scanning, or other such software designed to exploit or find computer, software, or network vulnerabilities. 

• Executing any form of network monitoring which will intercept data not intended for the employee’s host, unless this activity is a part of the employee’s normal job/duty. 
• Circumventing user authentication or security of any host, network or account or 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. 
• Attempting to interfere with or deny service to any other user. 
• Providing information about, or lists of, BISIONA personnel to parties outside BISIONA.
• Installation of software which installs or includes any form of malware, spyware, or adware as defined by the security team. 

• Crashing an information system. Deliberately crashing an information system is strictly prohibited. Users may not realize that they caused a system crash, but if it is shown that the crash occurred as a result of user action, a repetition of the action by that user may be viewed as a deliberate act. 
• Attempts to subvert technologies used to affect system configuration of company-managed devices (e.g. MDM) or personal devices voluntarily used for company purposes (e.g. mobile Work Profiles). 

2.2. Personnel systems configuration, ownership, and privacy 

Centralized system configuration 

Personnel devices and their software configuration are managed remotely by members of the security team via configuration-enforcement technology, also known as MDM software. Such technology may be used for purposes including auditing/installing/removing software applications or system services, managing network configuration, enforcing password policy, encrypting disks, remote wipe & recovery, copying data files to/from employee devices, and any other allowed interaction to ensure that employee devices comply with this Policy.

Data and device encryption 

All devices must use modern full disk encryption to protect data in the event of a lost device. An example of valid full disk encryption is VeraCrypt using XTS-AES-128 encryption with a 256-bit key. This is enforced using MDM software. 

Device heartbeat and remote wipe 

Devices must support the ability to report their status and be remotely wiped. This is enforced using MDM software. 

Prevent removable storage 

Devices must prevent usage of removable storage. This is enforced using MDM software. 

Endpoint/Antivirus/Antimalware protection 

Devices must automatically install and configure the BISIONA provided antivirus software for endpoint protection. Configured software will report status and potential threats, allowing for remote administration and reporting by the security team. This is enforced using MDM software.

Retention of ownership 

All software programs, data, and documentation generated or provided by personnel while providing services to BISIONA or for the benefit of BISIONA are the property of BISIONA unless otherwise covered by a contractual agreement.

Personnel privacy 

While BISIONA’s network administration desires to provide a reasonable level of privacy, users should be aware that the data they create on the corporate systems remains the property of BISIONA. Due to the need to protect BISIONA’s network, management does not intend to guarantee the privacy of personnel’s personal information stored on any network device belonging to BISIONA. Personnel are responsible for exercising good judgment regarding the reasonableness of personal use such as general web browsing or personal email. If there is any uncertainty, personnel should consult the security team or their manager.

Personnel 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. 

BISIONA reserves the right, at its discretion, to review personnel’s files or electronic communications to the extent necessary to ensure all electronic media and services are used in compliance with all applicable lOCI and regulations as well as corporate policies.

BISIONA reserves the right to audit networks and systems on a periodic basis to ensure compliance with this policy. For security and network maintenance purposes, authorized individuals within BISIONA may monitor equipment, systems and network traffic at any time.

2.3. Human resources practices 

Background checks 

Background checks are conducted for personnel with access to production infrastructure prior to their start date. The consequences of problematic background check results may range from a limitation of security privileges to revocation of employment offer, to termination. 

Training 

The security team maintains a company-wide security awareness program delivered to all personnel at least annually. The program covers security awareness, policies, processes, and training to ensure that personnel are sufficiently informed to meet their obligations. Those most responsible for maintaining security at BISIONA, including the security team itself as well as key engineering/operations staff, undergo more technical continuing education.

Separation 

In the case of personnel termination or resignation, the security team coordinates with human resources to implement a standardized separation process to ensure that all accounts, credentials, and access of outgoing employees are reliably disabled. 

2.4. Physical office environment 

Access to BISIONA offices is mediated by a staffed front office and programmable door control access. All doors shall remain locked or staffed under normal business conditions. The security team may provide approval to unlock doors for short periods of time in order to accommodate extenuating physical access needs. 

Internet-based security cameras are positioned to record time-stamped video of ingress/egress, which are stored off-site. 

2.5. Office network 

Internet access shall be provided to devices via wired ethernet and WPA2 wifi. Networking switches and routers shall be placed in a locked networking closet with only the security team having access. BISIONA executives and the security team may grant access to the networking closet to individuals on a case-by-case and as-needed basis. A network firewall that blocks all WAN-sourced traffic shall be put in place. WAN-accessible network services shall not be hosted within the office environment. 

3. Personnel identity and access management 

How does BISIONA define, control, and maintain user identity and permissions for personnel? 

3.1. User accounts and authentication 

Each individual having access to any BISIONA-controlled system does so via a G Suite user account denoting their system identity. Such user accounts are required to have a unique username, a unique strong password of at least 8 characters, and a two-factor authentication (2FA) mechanism.

Logging into BIsiona systems 

Logins by personnel may originate only from BISIONA-managed devices. Authentication is performed by an account management system. Repeated failed attempts to authenticate may result in the offending user account being locked or revoked.

Logging into third party systems 

Whenever available, third-party systems must be configured to delegate authentication to BISIONA’s G Suite account authentication system (described above) thereby consolidating authentication controls into a single user account system that is centrally managed by the security team.

When authentication to G Suite is not available, unique strong passwords must be created and stored in the BISIONA approved password management system. Passwords must be paired with two-factor/MFA authentication.

Revocation and auditing of user accounts 

User accounts are revoked (that is, disabled but not deleted) immediately upon personnel separation. As a further precaution, all user accounts are audited at least quarterly, and any inactive user accounts are revoked. 

3.2. Access management 

BISIONA adheres to the principle of least privilege, and every action attempted by a user account is subject to access control checks.

Role-based access control 

BISIONA employs a role-based access control (RBAC) model utilizing Google-supplied facilities such as organizational units, user accounts, user groups, and sharing controls.

Web browsers and extensions 

BISIONA may require use of a specified web browser(s) for normal business use and for access to corporate data such as email. For certain specified roles such as software development and web design, job activities beyond those mentioned above necessitate the use of a variety of browsers, and these roles may do so as needed for those activities.

Any browser that is allowed to access corporate data such as email is subject to a whitelist-based restriction on which browser extensions can be installed. 

Administrative access 

Access to administrative operations is strictly limited to security team members and further restricted still as a function of tenure and the principle of least privilege. 

Regular review 

Access control policies are reviewed regularly with the goal of reducing or refining access whenever possible. Changes in job function by personnel trigger an access review as well. 

3.3. Termination 

Upon termination of personnel, whether voluntary or involuntary, the security team will follow BISIONA’s personnel exit procedure, which includes revocation of the associated user account and reclamation of company-owned devices, office keys or access cards, and all other corporate equipment and property prior to the final day of employment. 

4. Provenance of technology 

How does BISIONA build, adopt, configure, and maintain technology to fulfill its security intentions? 

4.1. Software development 

BISIONA stores source code and configuration files in private TFS repositories. The security and development teams conduct code reviews and execute a static code analysis tool on every code commit. Reviewers shall check for compliance with BISIONA’s conventions and style, potential bugs, potential performance issues, and that the commit is bound to only its intended purpose.

Security reviews shall be conducted on every code committed to security-sensitive modules. Such modules include those that pertain directly to authentication, authorization, access control, auditing, and encryption. 

All major pieces of incorporated open-source software libraries and tools shall be reviewed for robustness, stability, performance, security, and maintainability. 

The security and development teams shall establish and adhere to a formal software release process. 

Sensitive data which does not need to be decrypted (e.g. passwords) is salted and hashed using approved functions such as Bcrypt. 

Sensitive data which must be decrypted (e.g. tokens) must use an approved encryption provider for HSM functions, such as KMS. 

4.2. Configuration and change management 

The BISIONA security and development teams shall document the configuration of all adopted systems and services, whether hosted by BISIONA or are third party hosted. Industry best practices and vendor-specific guidance shall be identified and incorporated into system configurations. All configurations shall be reviewed on at least an annual basis. Any changes to configurations must be approved by appointed individuals and documented in a timely fashion.

System configurations must address the following controls in a risk-based fashion and in accordance with the remainder of this policy: 

• Data-at-rest protection encryption 
• Data-in-transit protection of confidentiality, authenticity, and integrity for incoming and outgoing data 
• Data and file integrity 
• Malware detection and resolution 
• Capturing event logs 

• Authentication of administrative users 
• Access control enforcement 
• Removal or disabling of unnecessary software and configurations 
• Allocation of sufficient hardware resources to support loads that are expected at least twelve months into the future. 
• Production data is not used in development or test systems. 

4.3. Third party services 

For every third-party service or sub-processor that BISIONA adopts, the compliance team shall review the service and vendor, on an annual basis, to gain assurance that their security posture is consistent with BISIONA’s for the type and sensitivity of data the service will store or access.

5. Data classification and processing 

How does BISIONA manage data classifications and data processing? 

5.1. Data classification 

BISIONA maintains the following Data Confidentiality Levels:

• Confidential: Information only available for specific roles within the organization. Data must be encrypted at rest and in transit. Access to data requires 2FA/MFA.
• Restricted: Access restricted to specific roles within the organization and authorized third parties. Data must be encrypted at rest and in transit. Access to data requires 2FA/MFA.

• Internal: Information is available to all employees and authorized third parties. Data must be encrypted at rest and in transit.
• Public: Information is available to the public.

Data Confidentiality is determined by: 

• All customer information will be addressed as Confidential The value of the information, based on impacts identified during the risk assessment process. 
• Sensitivity and criticality of the information, based on the highest risk calculated for each data item during the risk assessment. 

• Policy, legal, regulatory, and contractual obligations. 

Additionally, data may be separated into data type classifications to enforce processing rules for customer data. For each data class, the BISIONA security and development teams may provision and dedicate specific information network slot to store and process data of that class, and only data of that class, unless otherwise explicitly stated.

5.2. BIsiona employee access to customer data 

BISIONA employees may access Customer Data only under the following conditions.

• From managed devices. 
• For the purpose of providing customer support or incident response. 
• For no longer than is needed to fulfill the purpose of access. 
• In an auditable manner. 
• Customer Data is not used in development or test systems. 
• Product usage metadata may be utilized for analytics, performance monitoring, and service/feature improvement. 

5.3. Customer access 

BISIONA provides web user interfaces (UIs), application programming interfaces (APIs), and data export facilities to provide customers access to their data. 

5.4. Exceptional cases 

The security team in conjunction with executive management may approve emergency exceptions to any of the above rules, in response to security incidents, service outages, or significant changes to the BISIONA operating environment, when it is deemed that such exceptions will benefit and protect the security and mission of BISIONA, our customers, and visitors of customers’ websites provided by BISIONA as a SaaS. 

5.5. Data encryption 

BISIONA protects all data in transit with TLS 1.2 and all data at rest with AES-256 encryption from Oracle. Cryptographic keys are assigned to specific roles based on least privilege access and keys are automatically rotated yearly. Usage of keys is monitored and logged.

Resources must maintain data encryption at rest and in transit for their entire lifecycle, including backups, during decommissioning or when removed from service temporarily. 

5.6. Data retention 

On expiration of services, BISIONA will delete all customer data from BISIONA’s systems in accordance with applicable law as soon as reasonably practicable, unless applicable law or regulations require otherwise. 

5.7. Data sanitization and secure disposal 

BISIONA uses Oracle Cloud Infrastructure for all infrastructure. OCI provides the following guidance regarding their data lifecycle policies:

“Oracle uses physical destruction and logical data erasure processes so that data doesn’t persist in decommissioned hardware”.  

Storage media destruction 

Oracle Asset Management requirements explicitly prohibit the removal of storage media that contains customer data from the data hall in which it is stored. Each data hall in a data center contains a secure media disposal bin. When a hard disk or other storage media is faulty or removed from production for disposal, it’s placed in this secure bin for storage until it’s degaussed and shredded. 

Data erasure 

When a customer releases a VM instance, an API call starts the workflow to delete the instance. When a new bare metal compute instance is added to the service or is released by a customer or service, the hardware goes through the provisioning workflow before it’s released to inventory for reassignment. This automated workflow discovers the physical media connected to the host. Then, the workflow initiates secure erasure by running the applicable erasure command for the media type. 

Hosts intended for customer use also have a network-attached disk that’s used to cache the customer’s storage volume. This disk is erased using the AT Attachment (ATA) security erase command. When the erasure process is complete, the workflow starts a process to flash the BIOS, update drivers, and return the hardware to a known good state. The workflow also tests the hardware for faults. If the workflow fails or detects a fault, it flags the host for further investigation. 

When a customer terminates a block storage volume, the key is irrevocably deleted, which renders the data permanently inaccessible.” 

6. Vulnerability and incident management 

How does BISIONA detect, and respond to vulnerabilities and security incidents? 

6.1. Vulnerability detection and response 

The BISIONA security and development teams shall use all of the following measures to detect vulnerabilities that may arise in BISIONA’s information systems.

• Cross-checking vulnerability databases with all systems and software packages that support critical BISIONA services.
• Periodical automated source code scanners. 
• Periodical code reviews on every mayor release. 
• Vulnerability scanning on BISIONA services using Oracle cloud Guard: https://www.oracle.com/security/cloud-security/cloud-guard/ 

The BISIONA security team shall evaluate the severity of every detected vulnerability in terms of the likelihood and potential impact of an exploit and shall develop mitigation strategies and schedules accordingly. Suitable mitigations include complete remediation or implementing compensating controls.

6.2. Incident detection and response 

The BISIONA security team maintains an internal Incident Response Policy which contains steps for preparation, identification, containment, investigation, eradication, recovery, and follow-up/postmortem.

The BISIONA security team shall use all the following measures to detect security incidents.

• Continuous monitoring of OCI network traffic and workloads for malicious or unauthorized activities. 
• Continuous monitoring of logs to detect potentially malicious or unauthorized activity. 
• Conduct reviews on the causes of any service outages. 
• Respond to notices of potential incidents from employees, contractors, or external parties. 

The BISIONA security team shall decide whether every indicator is representative of an actual security incident. The severity, scope, and root cause of every incident shall be evaluated, and every incident shall be resolved in a manner and timeframe commensurate with the severity and scope.

If a data breach affecting a customer has been detected, BISIONA will maintain communication with the customer about the severity, scope, root cause, and resolution of the breach.

BISIONA will execute tabletop exercises in a yearly basis to test policy internal knowledge and debug the policy.

7. Business continuity and disaster recovery 

How will BISIONA prevent and recover from events that could interfere with expected operations? 

7.1 Availability and resiliency 

BISIONA services shall be configured in such a manner so as to withstand long-term outages to individual servers, availability zones, and geographic regions. BISIONA infrastructure and data is replicated in multiple geographic regions to ensure this level of availability. BISIONA availability and status information can be found at status.BISIONA.com. 

7.2 Disaster recovery 

BISIONA targets a Data Recovery Point Objective (RPO) of near-zero for at least 7 days, and up to 24 hours beyond 7 days.

Due to the distributed nature of BISIONA services, Recovery Time Objectives (RTO) are near-zero for geographic disasters. RTO for systemic disasters involving data recovery is targeted at 6 hours.

BISIONA tests backup and recovery processes on at least a monthly basis.

7.3 Business continuity 

Business risk assessment and business impact analysis 

BISIONA’s risk assessment committee will include business risk assessment and business impact analysis for each Key Business System that is used by the organization. The outcome of ongoing risk assessments will update or create recovery plans for Key Business Systems and update prioritization of systems compared to other key systems.

Distribution, relocation, and remote work 

BISIONA prioritizes policies, tools, and equipment which enables independent, distributed remote work for all staff if emergencies or disasters strike. If the organization’s primary work site is unavailable, staff can work from home, or an alternate work site shall be designated by management.

Notification and communication 

BISIONA has established internal communications using secure, distributed providers using industry standard security protocols. Staff and management will be notified via existing channels during any emergency event, or when any data recovery plan is initiated or deactivated.