Technical and Organizational Measures Applied by EmailLabs
Data Protection Measures
Technical and Organizational Measures
VERCOM implements policies, procedures, standards, and guidelines related to information security, typically within the context of an Information Security Management System, as defined in ISO/IEC 27001 and ISO 27018 standards.
Access
VERCOM S.A. conducts a risk analysis and implements appropriate controls in its systems to prevent unauthorized access to data. These controls encompass a combination of legal, technical, physical, procedural, and human layers to prevent unauthorized misuse, destruction, disclosure, or modification of data.
The area of rooms, facilities, or buildings containing information, information systems, or other network infrastructure is physically and durably protected, using risk-oriented security measures.
Formal procedures for granting access to data have been introduced.
Access to data is restricted to authorized employees only.
Access is granted based on the principle of least privilege, minimizing necessary and justified access directly related to the employee's job responsibilities.
Access to data can only be granted to an identified individual with associated individual user accounts, and audit records of these activities must be logged and made available upon request. The use of privileged access rights and non-personal accounts is limited and controlled.
Data is made available on a "need-to-know" basis. Users or clients (external or internal) cannot have access to data that does not concern them.
Portable media is secured through encryption and appropriately labelled.
Multi-factor authentication is implemented for all authorized access.
A periodic access review is conducted at least once a year.
Responsibility
For each access to client data, there is an identifiable person or automated process responsible.
Formal processes governing the granting, removal, or modification of access to data are in place. All such actions are recorded and made available to the client within 48 hours upon their request.
Systems, hardware, and software used for data processing are maintained in accordance with these security requirements.
Security Incident Response
All detected security incidents and data breaches affecting client data or services provided to the client must be reported by VERCOM S.A. without undue delay, within a maximum of 48 hours after detection.
A report of a personal data breach includes at least the following information:
Nature of the personal data affected.
Categories and number of individuals affected.
Number of personal data records affected.
Measures taken to remedy the data breach.
Potential consequences and negative impact of the data breach.
As applicable:
Criminal background check (for teams handling banks, and financial institutions).
Creditworthiness check.
Continuity of Operations and Backups
VERCOM has a business continuity plan that includes appropriate sections on incident management and crisis situations, resilience, backups, and data recovery procedures after a failure, which are subject to review and testing at least once a year.
VERCOM securely stores copies of current, essential system software, images, data, and documentation to ensure rapid and controlled recovery of informational resources.
Data Integrity, Change Management, and Vulnerability Management
All data provided by users and data entered by users must be approved to maintain data integrity.
A formalized change management process has been implemented.
Vulnerability management for threats and patches has been introduced, including regular updates to ensure continuous system integrity and timely mitigation of new security threats.
Strict separation of data between production environments and development or testing environments is required. Storing production data in non-production environments such as development or test environments is not permitted.
Penetration tests are conducted at least once a year, and a summary of the results is provided to the Customer upon request.
Encryption
All sensitive data (such as Personally Identifiable Information - PII) must be encrypted during transmission and at rest.
Antivirus Protection
VERCOM S.A. consistently raises user awareness and implements appropriate controls and policies for detecting, preventing, and recovering data in the event of malicious software (viruses, malware).
VERCOM S.A. conducts periodic training for employees in this area.
Legal Responsibility
Full compliance with GDPR and other applicable laws, regulations, and contractual obligations is required.
Security Training
All employees with access to data or information must undergo appropriate security training. Vercom assesses employees' knowledge levels after training.
Asset Ownership
All informational assets (data, systems, processes, etc.) must have a designated responsible owner within VERCOM S.A.
Upon completion of assigned tasks or when data is no longer needed for processing activities, it will be returned to the client and securely destroyed.
Non-Repudiation
Controls must be implemented to ensure that actions and events will have legal effect and cannot be challenged or repudiated by VERCOM S.A. The actions must meet the requirements of authorized individuals within VERCOM S.A, including the Data Protection Officer (DPO) and the authorized representative.
Periodic Review
VERCOM S.A. conducts a periodic review of access, security controls, and risks at least once a year to ensure that the security of assets is not compromised.
Right to Audit
During the term of the agreement with VERCOM S.A., the client and its associated entities have the right to conduct a security assessment at an agreed-upon and convenient time to ensure an adequate level of data protection. This security protection will encompass measures related to technical, physical, procedural, and human controls.
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