Introduction
Esendex is certified and operates to the ISO 27001 Information Security standard. A copy of our certificate can be found here.
This standard is applied to all areas of the business; both our office and production environments are certified on an annual basis by an accredited external auditor.
A customer facing version of our Information Security Management System (ISMS) Manual detailing these measures is also available to customers on request. The manual provides statements on how we implement the ISO 27001 controls at Esendex.
As an illustrative, high level overview, Esendex has taken the following measures, among others:
Access Control
- Access to all systems by employees is controlled by a username and unique password. Esendex has a Password Policy which sets minimum complexity requirements and procedures to ensure passwords are changed on a regular basis by all staff
- All access at Esendex is on the basis of least privilege, as such employees only have access to the minimum amount of data that they need to do their job
- Access to customer data is heavily restricted as a result of our “least privilege” policy, all access is frequently reviewed to ensure that new starter, movers and leavers procedures are being adhered to by all relevant teams.
Firewalls
- We use firewalls on all internet facing elements of our infrastructure to protect data and control traffic into and out of the business. Firewalls are also enabled on all employee endpoints at all times
- IDS and IPS are enabled on our production environment firewalls.
Antivirus
- All our employee endpoints and servers within our payment environments are protected using appropriate real-time anti-virus, anti-spyware and anti-malware software
- An Anti Malware policy is in place to ensure that staff are fully aware of their obligations and do not obstruct the operation of the application.
Secure Equipment Including Laptops and Mobile Phones
- All company laptops and mobile phones are full disk encrypted and are individually password protected. All Esendex created documentation must be stored in secure online storage, never on employee endpoints
- Customer data is only stored within Esendex production environments, Esendex employees do not store customer data on their endpoints or process data outside of our secured production environments. Due to the majority of staff using laptops, removable storage is not generally needed. If used, the removable storage is subject to the same controls as our mobile device policy
- Employees are made aware of the risks of taking company equipment out of the office and the importance of protecting their own equipment.
Data in Transit / Encryption
- All transfers of customer end user information from Esendex owned and controlled hardware and networks is by way of VPN connections, this is how your data is transmitted to Network Operators for communications delivery
- Connections from you to our systems are secured depending on the method used:
- If you connect to us using our web applications, the connection is encrypted and authenticated using TLS 1.2
- If you use an SFTP automation to transfer files to Esendex, it is secured via SSH
- If you connect to us using one of our APIs – the security of the connection will be dependent on your integration, we strongly recommend that you use HTTPS in your integration to us, rather than HTTP.
Backup, Disaster Recovery and Business Continuity
We schedule and conduct regular backups to ensure that all data is stored safely, securely and remains available for the purpose of restoration in a disaster recovery situation.
- Full system backups of servers and databases are taken daily
- Transaction log backups are taken every 15 minutes
- Certain backups are stored in our Disaster Recovery Data Centre location
- We have Business Continuity and Disaster Recovery plans to ensure that we can minimise business damage from a major issue affecting staff, office and data centre locations & equipment.
Monitoring
- Our platform is continuously monitored by our operations team, Esendex has a dedicated on-call team that ensure that all platforms are monitored 24/7/365, any issues are raised with stakeholders and will be subject to our robust incident management procedures to ensure our estate remains secure and error free
- We subscribe to industry vulnerability reporting mediums and review all industry known vulnerabilities on a regular basis, with new threats being assessed on a daily basis. Where we discover that we are using a potentially vulnerable component, this risk is assessed in the context our business operations and environment and if appropriate, we will patch the issue as soon as possible
- We have processes in place to ensure that all data storing equipment is physically and securely destroyed at end of life, we do not recycle media and maintain copies of media destruction certificates from our trusted and certified suppliers for secure document destruction.
- We conduct penetration tests on an annual basis using a certified third party supplier. In addition to this, we undertake external and internal vulnerability scans using Authorised Scanning Vendors and vulnerability assessment applications.
Employee Training and Education
All employees:
- are subject to strict pre-employment vetting in line with our Hiring Policy, they must successfully complete aptitude testing and have a number of checks carried out prior to a full offer of employment being made. These checks include: education, employment, right to work and criminal record checks. Additional checks are required for certain roles i.e. finance related;
- They are trained on the importance of data security at Esendex and learn of the measures they must take to protect personal, company and customer data as part of their induction process and each month as part of our ongoing e-learning initiative;
- All staff have confidentiality and security obligations clearly set out as part of their contract of employment.
Policies and Procedures
In addition to the above, we maintain, enforce and support policies to ISO27001 standard for:
- physical premises security;
- security of data held on site;
- the secure storage, deletion and disposal of customer data;
- prohibition on the use of personal devices and accounts for work purposes;
- acceptable use of Esendex owned equipment.
All of these measures and the entire ISO systems are audited internally by the compliance team and externally by our third party accreditation body on an annual basis, the compliance team also conduct security sweeps on an ad-hoc basis to ensure that certain policies are being adhered to by all staff.
Risks
Esendex continuously assesses all risks. Risk assessments detail treatment plans that act as recommendations to help the business reduce the impact and/or probability of the identified risk. Risks and treatment plans are regularly reviewed, we assess risks related to our systems, staff, assets and operational activities. Esendex has identified this as an area that, whilst compliant with requirements such as ISO 27001, we adhere to the principle of continual improvement.
We use enterprise risk management software to support and enhance our approach to risk management. We identify dependencies as risks to our business and security objectives through risk registers, with activities arising to treat those risks effectively.
Breach Notifications
Esendex takes all of the above measures to secure your data as part of our Data Processing activities. In the event of a data breach, we will inform you without undue delay of any security issue that has led to a data breach including your customer data.
We have also:
- Implemented security measures into our IT systems, networks, and general business practices to detect and respond to security issues in an effective manner
- Developed an Incident Response Procedure to respond to all incidents and trained all staff in how to respond when an incident happens
- Defined customer communications in the event of any incident.
Data Protection Officers
Esendex has a dedicated compliance team that is responsible for all Data Protection questions, requests, issues and queries across the organisation. Any questions that you have in relation to Data Protection can be raised with your account manager, subject access requests are detailed in the section below.
The Rights of Data Subjects
Esendex will not respond directly to any request raised by one of your customers whose data we have processed. We will contact you to make you aware of the request and assist you in meeting your obligations under the Privacy Act. Examples of where we may need to assist to meet the rights of a data subject include:
Right to Access
Data that you transferred to Esendex can be made available for this purpose, providing it is still stored by Us. Such requests can be raised with Esendex by contacting our Support Team. There may be a charge associated with requests of this nature – please contact your account manager for details. Requests will be fulfilled within 30 days of us receiving the request from you.
Records of Processing Activity
Esendex only processes your data on your instructions and for the purpose of providing the communications service that is part of the performance of the contract between You and Us. The sole purposes of our processing activities is the transmission and delivery of communications to your end users.
We keep a record of all the messages that we send on your behalf in line with our data retention policy. This is for no longer than two years from the date that the communication is sent.
Third Party Transfers
Esendex passes your information to network operators for the purpose of delivering your communication to the End Users handset or Network Termination Equipment. This type of transfer is intrinsic to the provision of our products and services.
A feature of our service – Sent Items Download – is hosted within Microsoft Azure.
Messaging Studio and Rich Content/Communications Service (RCS) data is hosted in Microsoft Azure for operational purposes.
For all third party networks that we use, we have conducted a due diligence audit to ensure that each supplier has taken adequate technical and organisational measures required to offer security standards that are materially similar to those described in this document for our own infrastructure.
We have also entered into contracts with all third parties that solidify the data protection obligations of all parties and extend the minimum requirements detailed in any Data Processing Agreement between You and Us to our suppliers.
Data Maps
As part of our privacy framework, Esendex has conducted comprehensive data mapping of our systems to provide “Data Life Cycles” for all of the PID that we process and control. Customer facing versions of our data maps are available upon request to help you meet your obligations under the accountability principle of the GDPR. Requests can be raised with your account manager, who will be able to share data maps specific to Our products and services that You use.
Privacy Impact Assessments (PIA)
We understand that certain types of processing may require our customers to complete a PIA to ensure they take reasonable steps to implement practices, procedures and systems that will ensure compliance with the APP Guideline Provisions and enable them to deal with enquiries or complaints about privacy compliance. Esendex is a service provider for business communications and does not have visibility of the content you are sending through our platform. If you require our input into your PIA, please raise any requests of this nature with your account manager.