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RETAIL AND OFFSITE SECURITY [DP221]
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        Scope: Retail and offsite locations
        Distribution: All retail and offsite employees; GESM Leadership team, Directors and Managers
        Purpose: To limit access to physical and electronic information and systems, to authorized employees.
        External Regulation or Standard: 45 CFR 164.310(a)(2)(ii);45 CFR 164.310(a)(2)(iii) ‐ Facility Access Controls, PCI DSS 4.3.1.2, 4.3.1.3
        – Network Access Points

         Who is Responsible    Statement     Policy, Standard, or Procedure Statement
                                Number
         Director of Asset       DP221.1     The Director of Assets Protection and off‐site Directors and Managers are responsible
         Protection and off‐site             for the physical security of the organization’s Retail and offsite locations.
         Directors and
         Managers
         Director of Asset       DP221.2     Entrances to rooms or facilities where privacy‐restricted data is stored or processed
         Protection, and off‐site            must be locked or monitored and accessed by authorized personnel only. If facilities
         Directors and                       or rooms themselves cannot be locked individually when unattended, all unencrypted
         Managers                            privacy‐restricted data will be stored in a cabinet in a secured area or moved to
                                             another secure area when unattended.
         Director of IT and Chief   DP221.3   Point‐of‐sale systems must not retain credit‐card information.
         Financial Officer

         Employees with access   DP221.4     Paper documents containing privacy‐restricted information must be locked away
         to Privacy‐Restricted               when unattended and shredded when no longer needed.
         Data
         Employees with access   DP221.5     Computers containing privacy‐restricted information must be maintained in a secure
         to Privacy‐Restricted               GESM location or encrypted using a GESM approved method.
         Data
         Employees with access    DP221.6    Rooms containing file cabinets with PFIU must be in a secure location.
         to Privacy‐Restricted
         Data



































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