This Information Security Policy (“Policy”) sets forth the controls Gruntwork uses to ensure that information collected, stored, managed, or accessed by Gruntwork employees and contractors or through Gruntwork products, applications, or platforms, are adequately protected. By implementing and documenting the controls below, Gruntwork has established a framework to manage risks to the company, ensure compliance with applicable legal and regulatory requirements, and safeguard the company’s information technology, reputation, intellectual property, proprietary information, personal information, and customer data from misuse or compromise.
This serves as a central policy document with which all employees and contractors must be familiar, and defines actions and prohibitions that you must follow. However, no single policy can cover all the possible information security issues you may face. You must seek guidance from your manager or other designated Gruntwork resource before taking any actions that create information security risks or otherwise deviating from this Policy’s requirements. Gruntwork may treat any failure to seek and follow such guidance as a violation of this Policy.
This Policy covers all information and all computing resources used throughout Gruntwork’s operations. This Policy also applies to information assets owned by others, such as Gruntwork customers and sub-processors where Gruntwork has a legal, contractual, or fiduciary duty to protect those resources while they are in Gruntwork’s control or custody. All employees, contractors, or other entities acting on behalf of Gruntwork who use or access non-public information, Gruntwork-provided accounts, or other Gruntwork information systems to conduct Gruntwork business must adhere to this Policy.
“Confidential Information” means all information which Gruntwork has not released to the general public, including Proprietary Information and any information that Gruntwork receives from others under an obligation of confidentiality whether in written, electronic, or other form or media and whether or not marked, designated or otherwise identified as “confidential.”
“Device” means any desktop computer, laptop computer, tablet, handheld or mobile device, telephone or other electronic product or device that has a platform on which to download, install, or run any software program, code, script, or other content and with the capability to capture, access, or transmit Proprietary or other Confidential Information.
“Gruntwork Business” means all activities relating to Gruntwork’s technology, relationships, partnerships, financial affairs, and provision of DevOp services.
“Gruntwork-Provided Account” means any internet-based or other business account provided and controlled by Gruntwork.
“Proprietary Information” means all information of any kind (tangible and intangible, written and oral, and including information contained or transmitted through any electronic medium) owned by Gruntwork or licensed from third parties or that otherwise relates to Gruntwork’s actual or proposed business, which is not publicly available, including, without limitation, (i) research, development, technical data, trade secrets or know-how, drawings, engineering, hardware configuration information, products and product plans, services, marketing, selling and business plans, budgets, unpublished financial statements, licenses, prices, costs, contracts and other agreements, suppliers, customers, and customer lists, and other business information; (ii) information related to Gruntwork’s customers, including needs, preferences, terms, conditions, decision-maker and influencer identities, Gruntwork’s marketing strategies, and Gruntwork’s strategies as to individual customers, products, segments, and industries; (iii) identity, personal data, skills and compensation of employees, contractors, and consultants; (iv) specialized training; (v) information related to inventions owned by Gruntwork or licensed from third parties; and (vi) other non-public information relating to Gruntwork that is not readily ascertainable. Proprietary Information also includes compilations of information that relate to Gruntwork’s actual or proposed business and are not made public, even if underlying information or subsets of the underlying information are public. Proprietary Information may or may not be labeled or marked “proprietary” or “confidential.” In the event of a conflict or inconsistency with any provision or definition in any offer letter, employment contract, non-disclosure agreement, or proprietary invention and assignment agreement between you and Gruntwork, the terms of that agreement shall govern.
Gruntwork’s objectives for this Policy are the following:
At Gruntwork, all aspects of our operations, governance, and product development, are guided by the following principles.
Secure by Default. Security needs to be built-in by default and not treated as something that can be added on later. It should take effort to do something insecure. Security should be an inherent part of your process and it should always take conscious, deliberate effort to bypass that security.
Just as importantly, the secure option should be the easy option. If you try to make something super secure, but that makes it very hard to use, people will work around it, and make the system less secure overall. Usability counts for security, so you always need to strive for a good balance between secure and usable.
Defense-in-Depth. Humans make mistakes. Frequently. Even the most algorithmically perfect security system is not of much value if a single person making a mistake (and someone will make a mistake) leads to catastrophic failure. Therefore, a good security system is made up of many layers that back each other up, much like multiple walls in a castle, and of many isolated areas that limit the scope of any damage that happens, much like bulkheads in a ship.
Least Privilege. The principle of least privilege states that a principal (e.g. a user or a computer process) should be given the most minimum privileges necessary to do their job, and no more. This concept is closely related to defense-in-depth, as it limits the damage that can happen if something goes wrong (e.g., the user account gets hacked), much like a bulkhead.
While security is a team effort and requires everyone’s participation, Gruntwork leadership has designated one person to serve as the main point of contact for all data privacy and security matters for Gruntwork (“Information Security Manager”). The Information Security Manager, with assistance from Gruntwork leadership is responsible for the proper implementation of the procedures outlined in this Policy and shall act as a key liaison between the Information Security Team (defined below) and Gruntwork leadership. Gruntwork leadership will ensure that the Information Security Manager has the appropriate, knowledge, training, and experience to administer these functions.
In addition to the Information Security Manager, additional Gruntwork personnel shall provide support and technical advice, as needed, including by serving as members of a standing team (“Information Security Team”). These additional members will be chosen by the Information Security Manager. Experts (internal or third-party) may also be included on the Information Security Team on a case-by-case basis. These experts will also be chosen by the Information Security Manager and Gruntwork leadership.
The current information security manager is @Yevgeniy Brikman (as of 5/18/2021).
As appropriate, individual work groups may also conduct threat modeling exercises during the design process and perform security reviews during the development process. Specifically, Gruntwork conducts threat modeling assessments as a team for the following types of development work:
When conducting a threat analysis, employees should consider using the STRIDE threat model (Spoofing Identity, Tampering with Data, Repudiation, Information Disclosure, Denial of Service, Escalation of Privilege) and create data flow diagrams (DFDs), as appropriate.
On at least an annual basis, the Information Security Team will review all company privacy and data security policies to ensure that they continue to accurately reflect Gruntwork’s operations and products and adhere to applicable laws and regulations, Gruntwork’s binding contractual commitments, and relevant industry standards. The Information Security Team may engage stakeholders such as legal counsel and individual work groups, as appropriate, to assist with its review.
Gruntwork tests key controls, systems, and procedures outlined in this Policy at appropriate intervals. The scope, sequence, and frequency of testing is determined based on the risk presented by such controls, systems, and procedures, including as indicated in a risk assessment performed pursuant to Section V, Risk Assessments above. Any internal or external audits or testing, including the methodology used, the results found, and the remediations steps undertaken shall be documented and presented to Gruntwork leadership.
Gruntwork also strives to cooperate with customers in any audit of its controls, systems, policies, and procedures provided it has been afforded reasonable notice.
Recognizing that an astute workforce is the best line of defense, we strive to provide security training opportunities and resources to help our employees and contractors understand and meet their information security obligations. Every employee who handles Proprietary Information or customer data must review the following plans and policies (listed below) upon hiring and every two years thereafter. Required training programs instruct employees on the definitions of data privacy and personal data; their obligations under Gruntwork privacy and security policies; how to recognize risks relating to personal data; how to recognize and respond to phishing emails and other targeted attacks; and how to report suspected misuses of data. Gruntwork’s security training also includes a review of the following core Gruntwork information security documents:
Employees must certify in writing that they have completed the training and have read and agree to comply with documents within the link above.
In addition, Gruntwork promotes security awareness and educates employees through regular newsletters and ad hoc security awareness campaigns.
Gruntwork may provide specialized training, where appropriate, to ensure that personnel are sufficiently knowledgeable to protect non-public information in their role.
Gruntwork also encourages staff to pursue technical certifications and continuing education opportunities, including training in secure coding practices. Gruntwork engineers currently hold a range of certifications including AWS Solutions Architect, AWS Cloud Practitioner, Hashicorp Terraform Associate, and Certified Information Systems Security Professional (CISSP) certifications.
In addition to this Policy, Gruntwork implements and maintains a variety of additional written privacy and data security policies, notices, and standards designed to ensure the integrity, availability, and confidentiality of all non-public information and Gruntwork’s information technology assets. Relevant policies, procedures, and contractual commitments include the following:
Gruntwork Incident Response Plan
Furthermore, Gruntwork may, from time to time, approve and make available more detailed or location or work-group specific plans, policies, procedures, standards, or processes to address specific issues. These additional plans, policies, procedures, standards, and processes, as well as those listed above, are extensions of this Information Security Policy. You must comply with them, where applicable, unless you obtain an exception.
In some cases, Gruntwork may agree to comply with specific customer information security policies or standards. To minimize special cases, Gruntwork has designed this Policy to include the requirements common to most of our customers.
If Gruntwork agrees to comply with additional customer-specific information security policies or standards, we will notify affected personnel and make those policies or standards available. You must comply with any such policies or standards, including any related training or additional background screening requirements.
Gruntwork recognizes that specific business needs and local situations may occasionally call for an exception to this Policy. Exception must be granted, in writing, in advance by Gruntwork leadership.
You should not assume that Gruntwork leadership will approve an exception simply because he or she has previously approved a similar exception. Each non-compliant situation requires a review of the specific facts and risks to Gruntwork’s information assets and those of our customers.
Gruntwork leadership will periodically review all granted exceptions to confirm that a business need for the exception still exists.
Any confirmed violation of this Policy may result in disciplinary action or other sanctions. Sanctions may include suspension, access restrictions, work assignment limitations, or more severe penalties up to and including termination, in accordance with applicable law. If Gruntwork suspects illegal activities, it may report its concerns to the applicable authorities and aid in any investigation or prosecution of the individuals involved.
Like most companies, Gruntwork is subject to a collection of laws, regulations, industry standards, frameworks, and contractual commitments, some of which vary or overlap. This section highlights the obligations that you are most likely to encounter.
Privacy and Security Laws
There are a variety of laws at the state, federal, and international level designed to protect individuals’ personal information. Personal information includes details that alone or in combination with other information may identify a specific individual. This includes details such as names, email addresses, unique device identifiers, internet browsing history, and information about a person’s interactions with a website, mobile app, email, or advertisement. It can also include financial account information, government identification numbers, and other sensitive data.
Privacy and security laws generally fall into three categories:
Among other things these laws may:
Many jurisdictions have also enacted breach notification laws that require organizations to notify affected individuals if personal information is lost or accessed by unauthorized parties.
Information Gruntwork collects from and about its employees, web visitors, customers, service providers, and users may qualify as personal information and should be treated with care. When collecting, creating, or using new or different types of information, always consult with your manager and, as appropriate, the Information Security Manager to understand your obligations.
Other Applicable Laws, Regulations, Standards, or Contractual Commitments
Do not assume that these are the only laws or requirements that may apply. To identify specific obligations, seek guidance from your manager and, where appropriate, the Information Security Manager.
Gruntwork recognizes that the first step in establishing an effective information security program is identifying all data it collects, stores, manages, and accesses. Accordingly, the Information Security Manager shall ensure that all data is inventoried and classified to assist in designating proper security controls and to enable compliance with laws, regulations, policies, standards, and other appropriate criteria, including customer contracts. Everyone is responsible for data classification and inventory in their respective roles. It is the direct responsibility of all data handlers and data stakeholders to ensure that their data inventories are reported to the Information Security Manager, who shall maintain a comprehensive inventory.
At a minimum, the following information should be included in any data inventory: data type, data classification, source of data, location of data storage, ways in which data may be transmitted, identify of any third-parties with whom data may be shared, categories of Gruntwork employees who may have access to such data.
Inventories of data may be used for the following:
Data Access, Use and Storage Inventory
Gruntwork has established a three-tier classification scheme to protect information according to risk level. The information classification scheme allows Gruntwork to select appropriate security controls and balance protection needs with costs and business efficiencies.
All Gruntwork information is classified as (from least to most sensitive): (1) Public Information, (2) Confidential Information, or (3) Highly Confidential Information.
Unless it is marked otherwise or clearly intended to be Public Information, treat all Gruntwork and customer information as if it is at least Confidential Information, regardless of its source or form, including electronic, paper, verbal, or other information.
You must apply security controls appropriate for the assigned information classification level to all information you store, transmit, or otherwise handle. Use classification level markings, where feasible.
Public Information
Public Information is information that Gruntwork has made available to the general public. Information received from another party including a customer that is covered under a current, signed non-disclosure agreement must not be classified or treated as Public Information.
Some Public Information examples include, but are not limited to the following:
Do not assume that any information you obtain from Gruntwork’s internal network or systems is publicly available. For example, draft marketing materials are typically Confidential Information until their release. Consider all information to be at least Confidential Information, and not available for public disclosure without authorization, until you verify it is Public Information.
Confidential Information
Confidential Information is information that may cause harm to Gruntwork, its customers, employees, or other entities or individuals if improperly disclosed, or that is not otherwise publicly available. Harms may relate to an individual's privacy, Gruntwork’s marketplace position or that of its customers, or legal or regulatory liabilities.
Mark Confidential Information to denote its status when technically feasible. Applications or databases that contain Confidential Information may be marked with an initial banner shown upon system access.
You must have authorization to disclose Confidential Information to an external party. Seek guidance from your manager or the Information Security Manager before disclosing Confidential Information and verify that an appropriate non-disclosure or other agreement is in effect.
Some Confidential Information examples include, but are not limited to the following:
You must protect Confidential Information with specific administrative, physical, and technical safeguards implemented according to risks, including (but not necessarily limited to) the following:
Highly Confidential Information
Highly Confidential Information is information that may cause serious and potentially irreparable harm to Gruntwork, its customers, employees, or other entities or individuals if disclosed or used in an unauthorized manner. Highly Confidential Information is a subset of Confidential Information that requires additional protection.
Mark Highly Confidential Information to denote its status when technically feasible. Applications or databases that contain Highly Confidential Information may be marked with an initial banner shown upon system access.
You may not remove Highly Confidential Information from Gruntwork's environment without authorization.
You must have authorization to disclose Highly Confidential Information to an external party. Seek guidance from your manager and, if appropriate, the Information Security Manager prior to disclosing Highly Confidential Information externally to ensure Gruntwork meets its legal obligations.
Some Highly Confidential Information examples include, but are not limited to the following:
You must protect Highly Confidential Information with specific administrative, physical, and technical safeguards implemented according to risks and as prescribed by applicable laws, regulations, and standards, including (but not necessarily limited to) the following:
Good security requires directing attention to three areas: people, process, and technology. Of these, people remain the weakest link. Humans make mistakes. Frequently. They can also act carelessly or maliciously.
This section describes controls Gruntwork has developed to protect against the risks posed by its staff and external parties with whom it works You must support these controls to the extent they apply to you.
Gruntwork requires employees to undergo background check before they are allowed access to Proprietary Information or customer data. In the United States, Gruntwork uses an external screening agency to perform pre-employment background checks for prospective hires. Personnel screening in other countries varies according to local laws, employment regulations, and local Gruntwork policy. Gruntwork may require employees who handle Highly Confidential Information to undergo additional background screening and testing where permitted by applicable laws. All information obtained as a result of a background check will be used solely for employment purposes and will be kept confidential. You are entitled to request copies of any background check information to the extent permitted by state and federal law.
Supervising managers may request access for their employees only to those Gruntwork systems and data required to meet business needs.
Service Providers and Business Partners
Gruntwork grants systems access to approved external parties, such as contractors, vendors, service providers, business partners, or others with a demonstrated business need that cannot be reasonably met through other means (see Section XI, Service Providers: Risks and Governance). Gruntwork may support different access levels for different business situations.
A sponsoring employee must be designated for any external party before Gruntwork grants access to its systems, accounts, or data. The sponsoring employee is responsible for supervising the external party, including overseeing the external party’s compliance with this Policy.
The sponsoring employee may request access only to those Gruntwork resources necessary to meet business needs. The sponsoring employee must also request that any access granted be terminated when the business need ends.
Customers and Users
All organizations (i.e., either a company or a team within a company) are manually vetted prior to granting them access to the Gruntwork subscription. All individuals associated with an organization (“users”) are manually reviewed by a Gruntwork team member and preventative measures are in place prohibiting individuals with @gmail.com or @yahoo.com email addresses from being added as users. If a user tried to gain access with these, Gruntwork will block access and ask the user to send a request from an address associated with their organization.
Gruntwork restricts access to specific resources to those with a business need to know. Responsible managers and sponsoring employees should direct requests to add or change access levels to Gruntwork leadership. The Information Security Team must periodically review access levels to confirm that a legitimate business need for the access still exists.
When an employee leaves the business, Gruntwork will timely deactivate the individual's account(s). For external parties, the sponsoring employee must notify the Information Security Manager and request that access be revoked when there is no longer a business need. Managers should seek guidance from the Information Security Manager regarding access for employees on extended leaves.
Adhering to the principle of least privilege ensures that Gruntwork only grants individuals the privileges they need to perform their assigned activities and no more. Least privilege applies to user and administrative access. Managers must not grant administrative privileges unless there is a specific business need and should limit them to the extent feasible.
Managers should use role-based access control methods whenever feasible to assign authorization levels according to business functions, rather than uniquely for each individual. This method supports the least privilege approach by standardizing access. It also simplifies periodic access reviews.
As a fully distributed company, Gruntwork staff work on their own Devices and their own networks. To provide guidance and set expectations about the minimum security requirements required when staff use or access Proprietary Information, customer data, Gruntwork-Provided Accounts, or connect to other information systems owned or controlled by Gruntwork, Gruntwork has prepared and maintains a written Privacy and Security Code of Conduct (“Code of Conduct” or “Code”). Employees are provided a copy of the Code of Conduct upon hire and must certify in writing that they have read and agree to abide by the terms in the Code before they are granted access to any non-public information. For more detail regarding acceptable uses of Gruntwork’s information assets, please see the Gruntwork Privacy and Security Code of Conduct.
This section describes key safeguards that Gruntwork uses to protect and manage its information assets, including cloud accounts. You must support their use to the extent that they apply to you.
Secure Storage
Data - and the assets containing that data - must be stored in a manner commensurate with their sensitivity. Gruntwork uses several categories of control for data “at rest”.
Physical Security
Gruntwork uses physical safeguards to avoid theft, unauthorized use, or other abuses of its information assets. As a fully remote company with no physical offices, Gruntwork focuses on anti-theft and anti-tampering controls that prevent or track unauthorized removal or changes to physical assets. Key physical security requirements and recommendations are outlined in the Code of Conduct. You must comply with them to the extent they apply. Specifically, you must:
Security Features/Configurations
In addition to physical protections, technological protections must be installed or configured on assets containing sensitive data.
Authentication and Authorization
Gruntwork uses the following authentication and authorization controls to restrict access to Confidential and Highly Confidential Information to specific sets of individuals with specific permissions.
Procurement
To avoid unexpected business impacts, Gruntwork leadership, or the Information Security Manager, if authorized by Gruntwork leadership, must approve all information assets, including cloud-based productivity tools, before they may be used in or connected to Gruntwork's operations. This Policy applies whether the software, service, or other asset is purchased, open source, or made available to Gruntwork at no cost.
Before using cloud computing services to access, store, or manage Confidential or Highly Confidential Information, you must obtain authorization from the Information Security Manager who will evaluate the cloud computing service with input from legal counsel (see Section XI, Service Providers: Risks and Governance).
Application and Software Development
Gruntwork uses defensive coding techniques, regular code review, and application-level scanning to identify and remediate any information security issues before releasing software.
Secrets Management in Code
Sometimes, to execute code, secrets are needed. Gruntwork has expertise in secrets management and has produced a blog post that serves as a resource for sharing best practices with Gruntwork employees, as well as customers. You should review this blog post to understand Gruntwork’s expectations with respect to managing secrets in code. Specifically, Gruntwork practices and recommends the following:
Change Management/Version Control
Gruntwork maintains a change management process to minimize business impacts or disruptions when changes are made during software development. Among other things, Gruntwork uses a distributed version control system known as Git and a third-party service provider called GitHub to track changes in source code, provide change control history, and audit Gruntwork’s software. This allows Gruntwork to track identified problems, fixes, and releases during software development and preserves code so that earlier versions can be recovered and rebuilt, if necessary.
Code Reviews
Gruntwork conducts all code changes through pull requests. Every pull request must be reviewed by at least one other person before it can be merged. Gruntwork enforces this requirement through GitHub protected branches, as well as through GitHub’s internal tool, github-audit.
Testing
All of Gruntwork code requires automated tests. Gruntwork uses a mixture of static analysis, unit tests, integration tests, and end-to-end tests, testing both application and infrastructure code. Every repo is configured to run tests after every single commit. Test results are visible in pull requests and are part of what maintainers take into consideration before merging.
Automated testing in the infrastructure code space is still fairly novel. We’ve had to pioneer our own infrastructure test library, called Terratest, which we've open sourced, and has become popular in the community. All of our infrastructure code is tested with Terratest: it supports testing for tools such as Terraform, Packer, Docker, Kubernetes, AWS, Google Cloud, Azure, and more.
If we discover a bug in a public cloud provider or Terraform itself, we codify it explicitly using a test case. Likewise, we use test cases to verify our source code and product features work as intended by creating, modifying and destroying live infrastructure in the public cloud providers we support. You should follow these principles to the extent they apply to you.
Addressing Vulnerabilities
In addition to the scrutiny we apply internally, our code is subjected to numerous third-party audits conducted by our customers and their external vendors. Some of these audits include audits for compliance standards such as PCI and HIPAA, pen testing, and security reviews. We have created and maintain a responsible disclosure channel to enable our customers and users to report vulnerabilities they discover. This ensures that security warnings are promptly brought our attention and that we can act on them quickly. For more information, please see our Vulnerability Disclosure Policy below.
Gruntwork Vulnerability Disclosure Policy
Additionally, we have a Security Bug Bounty program. Currently this program is not publicly advertised on our website but we plan to do so in 2021.
Adhering to Industry Security Best Practices
Gruntwork adheres to multiple industry frameworks and standards including the following:
The Gruntwork Incident Response Policy details the processes Gruntwork uses for detecting and responding to unauthorized access or disclosure of Confidential or Highly Confidential Information for which Gruntwork is responsible. It defines the roles and responsibilities of various Gruntwork personnel in reporting, investigating, and remedying a security incident; outlines the timing, direction, and general content of communications with affected stakeholders; and describes the relevant phases of incident response including post-incident review and process improvement.
All Gruntwork employees have a responsibility to remain vigilant and protect the data stored within the systems we support. If you discover a security vulnerability or suspect a breach of Confidential or Highly Confidential Information, follow the notification and response processes described in the Gruntwork Incident Response Plan. Do not act on your own or make any external notifications without prior guidance and authorization.
Treat any information regarding security incidents as Highly Confidential Information and do not share it, internally or externally, without specific authorization.
The Information Security Manager maintains a service provider governance program to oversee service providers that interact with Gruntwork's systems or with Confidential or Highly Confidential Information. The service provider governance program includes processes to track service providers, evaluate service provider capabilities, and periodically assess service provider risks and compliance with this Policy.
Obtain approval from the Information Security Manager before engaging a service provider to perform functions that involve access to Gruntwork's systems or Confidential or Highly Confidential Information. All vendors must be reviewed and approved by Gruntwork management, in consultation with company legal counsel, as appropriate, prior to allowing any third party to collect, access, store, process, transmit, or dispose of any non-public information. Prior to engagement, Gruntwork must conduct a risk-based review of the vendor’s security practice in order to make a fact-based decision about whether or not to enter into a relationship with that vendor.
Service providers that access Gruntwork's systems or Confidential or Highly Confidential Information must agree by contract to comply with applicable law, regulation, and Gruntwork policy or similar information security measures.
Gruntwork may require service providers to demonstrate their compliance with applicable laws and this Policy by submitting to independent audits or other forms of review or certification based on risks.
In certain situations, Gruntwork creates, receives, and manages data on behalf of our customers. With guidance from the Information Security Manager, individual teams may develop, implement, and maintain processes and procedures to manage customer data intake and protection.
Work group-specific customer data intake and protection processes may vary but must include, at minimum, means for (1) identifying customer data and any pertinent requirements prior to data intake or creation; (2) maintaining an inventory of customer data created or received; (3) ensuring Gruntwork processes such data in according with customer instructions and its contractual commitments, and (4) implementing and maintaining appropriate information security measures, including proper data and media disposal when Gruntwork no longer has a business need to retain the customer data (or is no longer permitted to do so by customer agreement).
Identify any pertinent customer data requirements prior to data intake or creation according to your team’s customer data intake and protection process. Requirements may be contractual, the result of applicable law or regulations, or both (see Section VI, Compliance: Legal, Regulatory, and Contractual Obligations).
Work group-specific customer data intake processes and procedures must provide for secure data transfer. Maintain an inventory of customer data that includes, at a minimum:
Treat any customer-provided personal information as Highly Confidential Information (see Section VII, Highly Confidential Information). To minimize risks for customers and Gruntwork, engage customers in an ongoing dialogue to determine whether business objectives can be met without transferring personal information to Gruntwork.
Protect all customer data Gruntwork creates or receives in accordance with this Policy and the data's information classification level, whether Confidential or Highly Confidential Information, in addition to any specific client-identified requirements.
Ensure that any customer data or media containing customer data is securely disposed of when it is no longer required for Gruntwork business purposes, or as required by customer agreement (see Section IX, Information Assets: Protecting and Managing Gruntwork’s Information Technology Environment, Secure Storage - Secure Disposal). Update the applicable work group customer data inventory accordingly.
https://gruntwork.io/terms/#support
All Gruntwork employees are trained on our security best practices which include the review of the following documents:
Once all documents are reviewed, employees sign saying they have implemented the appropriate security measures aligned with company policy and that they have read all the above documents.
https://gruntwork.io/legal/privacy-policy/
https://gruntwork.io/legal/subprocessors
https://gruntwork.io/legal/cookie-policy