FUJ00232604 - Fujitsu Services RMGA Information Security Management System

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FUJITSU

Fujitsu Services RMGA Information Security Management

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FUJ00232604

System (ISMS) Manual
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Document Title:

Document Reference:

Document Type:

Release:

Abstract:

Document Status:

Author & Dept:

External Distribution:

Approval Authorities:

Name Role

Wendy Warham Operations Director

Fujitsu Services RMGA Information Security Management System
(ISMS) Manual

SVM/SEC/MAN/0003

MANUAL

Not Applicable

An approach and framework to implementing, maintaining,
monitoring and improving information security on the RMG Account
APPROVED

Neneh Lowther

Sue Lowther

Signature Date

Howard Pritchard Chief Information Security Officer

Note: See Royal Mail Group Account HNG-X Reviewers/Approvers Role Matrix (PGM/DCM/ION/0001)

for guidance.

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0 Document Control

0.1 Table of Contents

0 DOCUMENT CONTROL.

0.1 Review Detail
0.2 Associated Dox
0.3. Abbreviations.
0.4 Glossary...
0.5 Changes Expecte
0.6 Copyright...

1 INTRODUCTION.......cccssssssssssseseseessessretscssesesecssessssesececessneseasssetecseesesseseseneseneeeses 8
2 ISMS OBJECTIVES. .....scsesessssessssenssssssesssessesesescseesesescasanecseteensatecssensatetasasaeareeneeen 9
3 SCOPE OF THE FUJITSU SERVICES RMGA ISMG..........sssssesesessssseseeeseeeeeeee 10

3.1. Fujitsu Group Security...
3.2 Fujitsu Corporate Inform:
3.3 Infrastructure Services...

4 RISK MANAGEMENT.

4.1 Methodology and Tool
4.2 Risk Assessment..
4.3 Risk Treatment Plai

5 —ISMS STRUCTURE FOR RMG ACCOUNT.........cscssssessssssesesesessenenesseeeseeetaeeeens 12

5.1 Statement of Applicability.............
5.2 Document and Record Management

6 COMPLIANCE AND REPORTING..........cccssssssssssssesesseessesesessenesssssessneesaseseesenens 14

6.1 18027001 Compliance Audits.
6.2 Reporting...
6.3. Supporting Post Office Ltd Compliance.

7 COMMUNICATION AND AWARENESS...

8 OPERATIONAL SECURITY.

8.1 User Administration.........
8.2 Administration of Changes.
8.3 Acceptance into Service..
8.4 Analyse Security Logs.
8.5 Anti-Virus and Malicior ig
8.6 Security Incident Reporting and Problem Manageme!
8.7 __ Cryptographic Key Management...

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8.8 Information Retrieval and Prosecution Support.
8.9 Physical Access Control...
8.10 Subject Information Requests Managemen

9 ORGANISATION

9.1 Internal Fujitsu Responsibilities...
9.2 Fujitsu Services RMG Account Director.
9.3 Fujitsu Services RMGA Programme Directo!
9.3.1 Fujitsu Services Audit Manager...
9.4 Fujitsu Services RMGA Operations Director..
9.5 Chief Information Security Officer (CISO).
9.6 Staff Responsibiliti
9.6.1 Electronic Mai
9.7 External Interfaces.
9.7.1 External Third Partie: :
9.8 RMGA Information Security Management Review (ISMR).

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POST:
OFFICE

0.2 Document Control

Version No. Summary of Changes and Reason for Issue Associated Change -
CP/PEAKIPPRR
Reference

04 Initial Draft

02 19/02/08 Updated with information from service description

02 19/02/08 Issued for Review

1.0 30/04/08 Issued for Approval after updating with review comments

0.3 Review Details

30" March 08

Review Comments by :

Review Comments to : Neneh.Lowther..... GRO. & RMGADocumentManagemen'

Mandatory Review

*Chief information Security Officer (CISO) Howard Pritchard
“RMGA Operational Security Manager Pete Sewell
*RMGA Information Governance Brian Pinder
*Service Delivery Manager Richard Brunskill
Operations Director Wendy Warham
Programme Assurance Manager Jan Holmes
Issued for Information - Please restrict this
distribution list to a minimum
Head of Information Security, POL Sue Lowther
RMGA Operational Security Manager Pete Sewell
RMGA Information Governance Brian Pinder

( * ) = Reviewers that returned comments

0.4 Associated Documents (Internal & External)

Reference Version _Date Title Source
PGM/DCM/TEM/0001 2.0 16-Apr- I RMGA HNG-X Generic Master I Dimensions
07 Document Template
(DO NOT REMOVE) “ P
SVM/SDM/POL/0035 02 RMGA INFORMATION SECURITY I Dimensions
MANAGEMENT REVIEW (ISMR)
PGMPASMAN0004 BMS Implementation Approach Dimensions
SVMISEC/MAN/0003 0.2 ISMS Manual Dimensions
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SVMISEC/MAN/0002 02 Information Security Management I Dimensions
System (ISMS) Scope

SVMISEC/STD/0006 1.0 Information Risk Management I Dimensions
Approach

SVM/SEC/PLA/0001 4 02/04/08 I information Security Risk Treatment I Dimensions
Plan

SVMISEC/STD/0007 Security Control Framework Dimensions

SVMISEC/MAN/0001 Statement of Applicability Dimensions

SVMISEC/STD/0027 FS RMGA ISMR Terms of Reference I Dimensions

SVMISEC/STG/0001 Information Security Communications I Dimensions
Strategy

SVM/SEC/POL/0003 04 RMGA Information Security Policy Dimensions

ITS/8 Electronic Mail Dimensions

RS/PROIO48 Horizon Patch Management Process I Dimensions

for Operational Security

RS/PROIO49 Horizon Event Logging Process for I Dimensions
Operational Security

SCM Process for Handling AV I Dimensions

Process
\A/PRO/004 3.0 Audit Data Extraction Pvcs
NB/PRO/OO3 2.0 Network Banking Management of I PVCS
Prosecution Support
RS/PROIO13 6.0 Horizon Security Pass PVCs

Security Management — Service I PVCS
Description. (Current).

CS/SER/016
Commencement of HNG-X Project,
Workstream X4 (HNG-X Application
Rollout), this document will be
replaced by Security Management
Service: Service Description
(SVM/SDM/SD/0017)
CSPRO179 Moneygram Password Procedure Dimensions
SVMSDMPRO0018 Incident Management Process Dimensions
CSPRO109 Subject Access Requests Dimensions
CSPROO4O Live Access Request Dimensions
CSPLA102 Disaster Recovery Plan Dimensions
DSMANOO2 Signing Server User Guide Dimensions
RSPROOO2 Horizon Vetting Process Dimensions
RSMANOO6 KMS User Guide Dimensions
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SVMSDMPRP0018 RMGA Customer Service Incident I Dimensions
Management Process

‘SVMSDMPRO0025 RMGA Customer Service Problem I Dimensions
Management Process

SVMISEC/PLA/004 1 16/04/08 I Risk Treatment Matrix Dimensions

SVMISEC/PLA/005 1 16/04/08 I Security Improvement Matrix Dimensions

RS/PROIO16 3 12/12/05 _I Physical Access to Post Office Sites I PVCS

Qu/Doci002 3 03/06/05 I Security Awareness Leaflet PVCs

SVMISEC/STD/0026 cISO TOR Dimensions

0.5 Abbreviations

Unless a specific version is referred to above, reference should be made to the current approved versions of the documents.

Definition
IG Information Governance
ISMR Information Security Management Review
isMS Information Security Management System
NCN Non-Contormity Notice
RMGA Royal Mail Group Account
ToR Terms of Reference
Fujitsu Fujitsu Services RMG Account,
ciso Chief information Security Officer
RTP Risk Treatment Plan
Isp Information Security Policy
SOA Statement of Applicability
ARQ Audit Request Query
SLA Service Level Agreement
Ola Operational Level Agreement

0.6 Glossary

Term Definition

0.7 Changes Expected

Changes
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0.8 Copyright

© Copyright Fujitsu Services Limited 2008. All rights reserved. No part of this document may be
reproduced, stored or transmitted in any form without the prior written permission of Fujitsu Services.

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1. ‘Introduction

Best practice, as defined in ISO/IEC 27001:2005, BS 7799-2:2005 requires an approach and framework
to implementing, maintaining, monitoring and improving information security. This document provides a
high level overview of the approach and framework, known as the Information Security Management
System, used within the Fujitsu Services RMGA and will be independently reviewed on at least an
annual basis. The document is structured to explain the Security Management framework and is
supported by the following key documents:

Key Information Governance Documents I Key Operational Security Documents

SVM/SEC/MAN/0003 ISMS Manual (this I RS/PRO/048 Horizon Patch Management
document) Process for Operational Security

SVM/SEC/MAN/0002 RS/PRO/049 Horizon Event Logging Process for

Information Security Management System Operational Security
(ISMS) Scope

SVM/SEC/STD/0006 SCM Process for Handling AV Process
Information Risk Management Approach

SVM/SEC/PLA/0001 Information Security I [A/PRO/004 - Audit Data Extraction
Risk Treatment Plan

Security Control Framework NB/PRO/003 - Network Banking Management of
Prosecution Support

SVM/SEC/MAN/0001 Statement of I RS/PRO/013 - Horizon Security Pass Procedure

Applicability
SVM/SEC/STD/0027_ FS RMGA_ ISMR I Security Management Service Description.
Terms of Reference (Current).

Commencement of HNG-X Project, Workstream
X4 (HNG-X Application Rollout), this document
will be replaced by Security Management
Service: Service Description
(SVM/SDM/SD/0017)

SVM/SEC/STG/0001 Information Security I CSPRO179 Moneygram Password Procedure
Communications Strategy

SVM/SEC/POL/0003_ RMGA Information I SVYMSDMPROO018 Incident Management

Security Policy Process
ITS/8 Electronic Mail
SVM/SEC/STD/0026 CISO TOR CSPRO109 = Subject Access Requests

CSPROO40 Live Access Request
CSPLA102 Disaster Recovery Plan

DSMANO02 _ Signing Server User Guide

RSPROOO2 Horizon Vetting Process

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SVM/SDM/SD/0017 Security Service Description

2 _ISMS Objectives

The objectives of the ISMS are to:

e Provide a security framework within which the Service is developed, implemented and delivered
by Fujitsu in all areas of its business and responsibilities as required under Schedules A4:4.1.2
of the Agreement which states that ‘Fujitsu services shall be in compliant with ISO 27001’.

e Provide an organisational and responsibility framework for security activities within Fujitsu and
allocate security roles and responsibilities

e Identify risks associated with the provision of the Service, through formal risk assessment
techniques, and prioritise and implement appropriate controls and security measures

e Ensure appropriate security and business continuity procedures and controls are in place to
support Services provided by Fujitsu

e Provide a basis for review, governance, assessment and improvement of the ISMS

e Ensure that information security controls are appropriate to the sensitivity of the information
processed and stored

e Identify the security awareness and education requirements for all Fujitsu RMGA employees and
subcontractors

e Describe the compliance, audit and management arrangements

3 Scope of the Fujitsu Services RMGA ISMS

The Fujitsu Services RMGA ISMS encompasses all aspects of the Fujitsu Services RMGA business and
operations in support of discharging Service obligations as defined in the Agreement.

This ISMS is a subset of the RMGA Business Management System (BMS) as described in the BMS
Implementation Approach (PGMPASMANO004)

This includes the design, development, testing, deployment, operation, maintenance, decommissioning
and Services transfer of all aspects of the Services provided to Post Office Limited as well as the
associated supporting Fujitsu Services RMGA business processes.

A distinct part of the scope of this ISMS is subject to ISO27001 registration, specifically the design,
development, test and deployment processes including the delivery, operation and maintenance of the
HNGxX Service. The document “ISMS Scope” (SVM/SEC/MAN/0002) describes the full scope of the
ISMS subject to registration, in terms of technology, people and process.

3.1 Fujitsu Group Security

The Physical Security of Fujitsu Services sites are provided by Fujitsu Group Security. Any requirements
that RMGA has for additional security is requested by the CISO or Operational Security Manager from
the Head of Group Security.

Information about incidents affecting the physical security of Fujitsu Services RMGA sites are provided
to the Operational Security Manager by Group Security.

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Group Security also has responsibility for the vetting procedures for Fujitsu Services RMGA staff
although local advice and guidance can be obtained from the RMGA operational security team.

3.2 Fujitsu Corporate Information Systems

The information security of Fujitsu Corporate Information Systems is managed by Fujitsu Corporate
Information Services and their use is subject to the Fujitsu Services Security Master Policy (CPM/20).

3.3 Infrastructure Services

Infrastructure Services provide some elements of the Services to RMGA and are bound to comply with
the RMGA Information Security Policy. However, Infrastructure Services operate their own 1SO27001
registered ISMS with which this ISMS interfaces.

4 Risk Management

Fujitsu Services has an approved approach to the management of information security risk for RMGA
which is documented in RMGA Information Risk Management Approach.

Fujitsu Services RMGA is required to conduct a robust programme of risk management (incorporating
risk identification, assessment and mitigation) as a means of determining and confirming the
appropriateness of information related security controls for Programme systems and services. The risk
management programme is, on a day-to-day basis, undertaken by the Fujitsu Services RMGA IG staff.
Although the options for risk management (i.e. acceptance, transfer, mitigation etc) are determined by
the IG staff and the decision taken by the appropriate Programme or Operational management team,
security risk oversight lies with the Information Security Management Review Body (ISMR) , which is the
highest authority within the Fujitsu Services RMGA for the management of information security risks.
Further information about the ISMR is contained later in this document.

4.1 Methodology and Tool
Fujitsu Services RMGA employs a repeatable risk based approach comprising:

the identification of key assets and service components;

the threats they may be subject to;

an assessment of the range of impacts upon the systems and service, and;

the recommendation of proposed controls or countermeasures, aimed at;

allowing management to make appropriate decisions on risk management, by selecting the most
relevant control options

The risk assessment methodology and software tool, FRAMES (Version 0.9) is the preferred approach
for the assessment of information security risks for RMGA. FRAMES is a risk assessment tool based on
the ISF SPRINT Methodology, developed in Microsoft Access. It has been designed to carry out
Assessments of Risks associated with Information Assets, ranging from applications to data centres. It is
intended to be used in a workshop environment where participants can identify impacts, threats, and any
necessary controls.

4.2 Risk Assessment

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Risk assessment and management is not a one-off exercise, with a single set of control
recommendations which remain static in time. In the ongoing processes concerned with Programme
releases, operational delivery and maintenance of the live service, there will be a number of instances
where information risk assessment activity will be necessary:

e Planned risk assessments — these will be part of the normal routine for ensuring that deployed
controls remain relevant to the threat environment in which the systems and service operate, as
the prevailing threats and vulnerabilities may change over time. This refresh would fall within the
‘Check’ phase of the ‘Plan — Do — Check — Act’ control implementation cycle. It may be
necessary therefore to conduct risk assessment activity either at planned intervals (e.g. 6-
monthly or annual) to confirm that controls are still relevant, or to carry out a risk review on
specific components of the service or infrastructure where assurance as to the continued
effectiveness of controls is required.

* Reactive risk assessments — As part of service management, incidents, issues or threat
notifications may indicate a need for a reactive review of the potential impact of particular
threats or new vulnerabilities. This may be as a result of a single serious incident or as an
escalating or cumulative trend. The objective of this review may be to verify if existing controls
are sufficient to deal with the new or escalating threats/vulnerabilities, or require strengthening.

4.3 Risk Treatment Plan

In accordance with the dictates of best practice, RMGA maintains a Risk Treatment Plan (RTP)
(Information Security Risk Treatment Plan)

Information risks are recorded in the Fujitsu Services RMGA RTP. Risks attracting high probability and
impact scores are escalated, as required, through the Fujitsu Services RMGA risk management process
(PGM/PAS/MAN/0002)

In addition to regular risk assessments, RTP sources are:

* ISO/IEC27001 Compliance Rating
Each month Fujitsu Services RMGA reports a compliance status, in terms of all 15027001
control items. Any area with a score of ‘0’ (control not addressed) is recorded in the RTP.

* Audit Non-Conformity Notices (NCN), Observations and Improvements

Regular Information Security Policy (ISP) compliance audits are conducted. During the audits,
inappropriate controls, or controls improperly implemented, may be identified and, subsequently,
an ‘NCN’, ‘Observation’ or ‘Improvement Opportunity’ is raised.

An ‘NCN’ is raised where a mandatory control (as defined in the Agreement or ISP) is not
addressed or is ineffectively implemented, and this fact is recorded in the RTP.

An ‘Observation’ is raised when a recommended control (as defined in the Control Framework) is
not effectively implemented

An ‘Improvement Opportunity’ record is raised when a control is implemented but there is an
opportunity for improvement in the management system

* Supplementary

There are information risks identified by, or notified to, the IG staff and subsequently registered,
often as a result of:

o Specific risk workshops, organised for the purpose
o Information risks generated by other teams across the account
o Other compliance and testing activities, which give rise to potential risks requiring

mediation
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o Service incidents which have the potential to cause significant impact, and for which a
review of the risk and control position is required

5 ISMS STRUCTURE FOR RMG ACCOUNT

The ISMS is founded on the basic concepts of: Confidentiality; Integrity; Availability. Information
Governance staff ensure the co-ordination of all physical protective and logical information security
aspects of the premises, facilities, infrastructure and data; and ensure compliance with all Security
Controls, and the Security Policy.

However, the ISMS also outlines the management responsibility for ongoing Operational Security of
operational Services, including ensuring that the security section in SLAs, OLAs are compliant with, and
that Business Continuity plans support the Security Policy and Security Controls. These key operational
responsibilities are outlined in section 8.

5.1 Statement of Applicability

Information security is implemented through an appropriate set of controls, which in practice will be a
combination of policies, procedures, organisational structures, physical and technical measures.

The selected controls are documented in the Fujitsu Services RMGA Statement of Applicability. Most of
the controls are applicable and controls are only excluded where they are outside of the scope or not
identified as a risk to the Service delivered to POL.

5.2 Document and Record Management

The RMGA Dimensions system ensures that all documents are readily available from a single source, to
the relevant audience.

The Statement of Applicability (SOA) lists all documents relevant to the scope of the ISMS. The SOA
can be found in Dimensions.

All documents required by the Fujitsu Services RMGA ISMS are protected and controlled through the
RMGA HNG-X Document Control Process (PGM/DCM/PRO/0001). The document process also contains
details about document branding, protective marking, document retention and quality templates.

Records are established and maintained to provide evidence of conformity to requirements and the
effective operation of the Fujitsu Services RMGA ISMS. The primary records are:

Record Location Retention
Risk Assessment Output Dimensions 7 yrs after termination of the
project
Integrated Audit Plan Dimensions 7 years after termination of the
project
Audit Records Quality Management System 7 years after termination of the
project
Security Incident Dimensions 7 years after termination of the
Reporting project
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System Audit Logs 6 years with a further 1 year of.
P . space after termination of the
HNGX Audit Domain. project
Information Security Dimensions 7 years after termination of the
Management Review project
(ISMR) Minutes
ISP Reviews Dimensions 7 years after termination of the
project
Risk Treatment Plan Dimensions 7 years after termination of the
project
Information Security Dimensions 7 years after termination of the
Monthly Report project
IG Staff Meeting —- Dimensions 7 years after termination of the
Minutes project
Operations Service Service Management 7 years after termination of the
Acceptance Process project
Security Compliance
Matrix
Reports of Security Secure Area of Dimensions 7 years after termination of the
Incidents project

6 Compliance and Reporting

6.1 18027001 Compliance Audits

In support of the IS027001 compliance requirements, and to provide ongoing assurance of compliance,
regular compliance audits will be conducted. As directed by the Chief Information Security Officer, the
scope and terms of reference for each of these audits will be determined in advance and agreed with the
manager of the area(s) to be audited.

For each 1S027001 control within the scope of the ISMS the following is reviewed:

e Clear, accepted responsibility for the aspect of Information Security which is subject to that
control;

e Confirmation from the organisation that the relevant control is in place, documented and
effective;

e Documentary evidence (records/logs etc. in either electronic or hardcopy format), which can
be inspected to confirm the controls are in place and functioning as intended. Inspection is
on a sampling basis.

e All findings are logged on the Fujitsu Services Assessment Database and updated as action
is taken.

All audits will be carried out by suitably trained auditors with auditing qualifications e.g.
BS7799/ISO27001 Lead Auditor; TickIT Auditor/Lead Auditor.

Audits are carried out as part of the RMGA Internal Audit Plan (PGM/PAS/PLA/0005). Additional audits
are carried out on a regular basis by the FS Manage Information Security Process Champion and Fujitsu
Services Business Assurance. As part of 1S027001 registration, independent external audits will be
conducted as determined by the audit body.

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6.2 Reporting

Information Governance staff provide a monthly Information Security Reporting Pack which informs the
Management Team, as an input to the Fujitsu Services RMGA ISMR, of progress towards 1SO27001
compliance, results of audits and current risk status. It is intended that the details contained in this
report will expand over time. This includes reports from the Operational Security Team such as a
summary of the types and numbers of incidents that may impact on the confidentiality, integrity or
availability of RMGA systems.

A subset of this monthly report is included in the Service Review Book which is provided monthly to the
customer.

6.3 Supporting Post Office Ltd Compliance
The RMGA CISO is responsible for assisting POL in achieving information security compliance, by:
« Completing security questionnaires from POL and any of its clients.

e Participating, following a formal written request from POL, in routine audits such as those
conducted by POL’s Internal Audit team or as part of an overall audit of POL'’s PCI compliance
as referenced in csser016.

7 Communication and Awareness

A programme of security awareness training, including Information Security overviews, is provided to all
new arrivals, as part of induction training. The service covers the provision of periodic awareness
activities and training including induction training, presentations and briefing notes and input to
magazines, journals and other periodicals.

The Fujitsu Services RMGA Security Communications Strategy details the various communication
channels that are used and the different vehicles and methods available for ensuring that key messages
regarding Information Security are effectively communicated to staff at all levels engaged in the Fujitsu
Services RMG Account.

8 Operational Security

8.1 User Administration

The Operational Security Team will be responsible for the administration, issuing and audit of Two
Factor authentication used by system administrators and support staff accessing the Live Service.

The Operational Security Team is responsible for ensuring that Fujitsu users of POL Services are
validated before being given access to the live Service.

The Operational Security Manager is responsible for ensuring that these tasks are carried out in
accordance with the Security Policy and for authorising physical access rights requiring strong
authentication for secure access.

8.2 Administration of Changes

Operational Change Management is the responsibility of the Change Management Team within Service
Management.

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The Operational Security Team is responsible for reviewing all change requests and assessing the
impact of changes for compliance with Security Policy and Controls and for any impact on the
Confidentiality, Integrity and Availability of Services. They are supported in the technical aspects of
these assessments by the Technical Security Architects.

8.3 Acceptance into Service

Responsibility for accepting new Services rests with the Service Management Team. The Operational
Security team is responsible for ensuring that new services identify their security requirements and that
the security elements of Acceptance into Service have been met.

8.4 Analyse Security Logs

The Operational Security team is responsible for providing a number of security event management and
firewall event analysis activities:

« Managing and operating the audit mechanisms and security event management system (including
firewall events) to monitor, detect, track, record and report events that might threaten the
security of the Service Infrastructure (security weaknesses). This includes the review of security
event filter to optimise performance;

e Regularly analysing audit trails to identify trends and to assist the investigation of security
incidents/breaches;

e Establishing and monitoring adequate firewall policies / rule bases based on the output of risk
assessments as appropriate;

« Where potential attacks, or areas of vulnerability, are identified ensuring prompt investigation and
providing advice for any remedial action (as part of security incident management) to minimise
the impact of any security breach.

« Any successful attacks will be subject to the RMGA Customer Service Incident Management
Process.

8.5 Anti-Virus and Malicious Software Management

The Operational Security team provides a number of anti-virus and malicious software management
activities. For HNG-X, the updated version of Sophos cover malware as well as anti-virus.

. Managing the distribution of updated anti-virus software across the live estate to protect
the Services from malicious software, including regular DAT updates to identify and cleanse new
and emerging virus strains;

. Configuring, and maintaining, alerting mechanisms and event filters to provide
automatic notification and prompt virus incident response (in accordance with security incident
response procedures);

. Regular checking of emerging viruses and other malicious software to determine any
required defensive measures;

8.6 Security Incident Reporting and Problem Management

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The Operational Security Team participate in the RMGA Customer Service Incident Management
Process (SVM/SDM/PRO/0018)and RMGA Customer Service Problem Management Process
(SVM/SDM/PRO/0025) with regard to Security related Incidents and Problems.

The Operational Security Manager is the prime point of contact for information security related events,
incidents and breaches and is responsible for communicating relevant security incident details to POL,
as well as attending a joint monthly meeting to review information security incidents.

8.7 Cryptographic Key Management

The Operational Security Team provide a key management service to control the certification and
distribution of cryptographic key material used to protect the confidentiality and integrity of Post Office
business data. This consists of three primary activities:

« Managing cryptographic key suppliers;

e Manual cryptographic key management — creating, distributing, auditing and replenishment of
manual cryptographic keys;

e Managing an automated Key Management System (KMS) - creating, distributing and
replenishment of cryptographic material as well as assisting support teams with error resolution
and problem management related to the KMS.

The KMS is a critical business system and as such is subject to service optimisation and the provision of
business continuity arrangements.

An actual, or suspected, compromise of any keys (including PIN Pads) will be treated as a security
incident and managed accordingly. In particular, key change mechanisms will be invoked. If a key is
identified compromised a corrective action plan will be carried out in accordance to the agreed correct
action response for that key.

An actual, or suspected, compromise of any keys (including PIN Pads) will be treated as a security
incident and managed accordingly. In particular, key change mechanisms will be invoked.

8.8 Information Retrieval and Prosecution Support

The operational security team is responsible for the management of the day-to-day extraction of
transaction and event data from the audit system, the analysis of supporting information and the
provision of associated investigation / prosecution support. This requires close co-operation with Audit
and Investigation staff in Post Office Ltd, the provision of witness statements and reports, and possible
attendance at Court to give evidence.

Data extracted can be in response to either Transaction Record Queries, or Audit Record Queries,
including APOP Voucher Queries (Reference document SVM/SDM/SD/0017).

8.9 Physical Access Control

The Operational Security Team is responsible for the administration, issue and control of the Fujitsu
Services (Royal Mail Group Account) Ltd Horizon Security Passes. All staff who require access to a
Post Office branch to provide support and maintenance will need to be issued with a Horizon Security

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Pass. The Horizon Security Pass allows employees of the Royal Mail Group Account (RMGA) to be
identified as those who have been successfully vetted by Post Office Limited (POL).

8.10 Subject Information Requests Management

The Operational Security Team is responsible for the management and provision of responses in respect
of Subject Information Requests.

9 Organisation

9.1 Internal Fujitsu Responsibilities

Full details of key Fujitsu Services RMGA Security responsibilities are contained within the Information
Security Policy. In summary:

9.2 Fujitsu Services RMG Account Director
The information security-related responsibilities of the Fujitsu Services RMG Account Director include:

« Overall control and management of information security throughout the Fujitsu Services RMG
Account;

« Provision of adequate resources for information security;

e Appointing an experienced security professional responsible for managing and coordinating security
across the complete RMGA domain.

e Approval authority for the Fujitsu Services RMGA Information Security Policy;

e Establishing the information security interface with the customer; and

e Establishing the information security interface with all Fujitsu Services subcontractors

Senior management is supported by the Information Governance staff which consists of experienced
specialists with specific expertise in the areas of IT security and risk management.

9.3 Fujitsu Services RMGA Programme Director

The information security-related responsibilities of the Fujitsu Services RMGA Programme Director
include:

e Ensuring that responsibilities and procedures for the management and operation of all information
processing facilities are established, documented and maintained; and

e Ensuring that changes to information processing facilities and systems are controlled.

e Overall control of risk management and audit functions, including deciding the criteria for accepting
risks and the acceptable levels of risk;

9.3.1 Fujitsu Services Audit Manager

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The information security-related responsibilities of the Fujitsu Services RMGA Programme Assurance
Manager include:

Overall control of risk management and audit functions;
Co-ordinating all audit related activities;

Providing a point of contact for external audit personnel;

Planning and carrying out audits of RMGA’s business functions; and
Maintaining an integrated audit plan

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9.4 Fujitsu Services RMGA Operations Director

The information security-related responsibilities of the Fujitsu Services RMGA Operations Director
include:

Sponsorship of the Chief Information Security Officer; (CISO);

Ownership and overall control and management of operational security throughout RMGA;
Day to day management of security related risks;

Chairing the RMGA Information Security Management Review Board; and

Acting as the approval authority for Royal Mail Group Account’s Security Procedures,

9.5 Chief Information Security Officer (CISO)

The CISO is responsible for the overall design of RMGA's security control framework. The CISO will
lead the engagement with customer stakeholders with an interest in governance, control and security
matters. The CISO will ensure the responsibilities of the Information Governance and Operational
Security Teams are met. Full details are contained within the “RMGA CISO Terms of Reference” (Ref
SVM/SEC/STD/0026) and include:

« Developing and publishing all security-related policies and guidelines applicable at RMGA level;

e Reviewing and approving information security policies and procedures owned and implemented at
business level;

Providing a point of contact for POL Head of Information Security

Ensuring that security incidents are recorded and investigated;

Monitoring for compliance with the RMGA Information Security Policy;

Ensuring all RMGA Staff are screened in line with contractual requirements, FS Group Policy and
this policy;

Ensuring that security relevant events are recorded

Ensuring that system audit trails are analysed on a regular basis;

Defining the information security risk assessment approach of RMGA:

Analysis and evaluation of information security risks and evaluating options for the treatment of
risks; and

* Co-ordinating the implementation and operation of the Information Security Management System.

cece

9.6 Staff Responsibilities

All RMGA Staff have an Information Security related objective to ensure awareness of their security
responsibilities and security procedures. Security Induction Training ensures all staff know where to find
security procedures, are familiar with their contents, and understand their own responsibilities for
compliance.

The information about which staff should be aware includes:

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Physical security controls and visitor procedures

Clear desk policy, careful communications and storage

Protecting Fujitsu documents and media and protecting RMGA information
Reporting security incidents

Responsibilities for the protection of personal data

Acceptable use of Fujitsu equipment, Internet and email

Working at home and out of the office

9.6.1 Electronic Mail

Information classified as COMPANY RESTRICTED may be transmitted unencrypted by electronic mail
within the Company, providing such mail is flagged as sensitive (e.g. ‘Confidential’ if sent by Microsoft
Exchange/ Outlook). Where transmissions are outside of the company secure approved encryption
methods must be used as referenced in (ITS/8 — Electronic Mail).

9.7 External Interfaces

9.7.1. External Third Parties

In accordance with section 6.2.1 of the RMGA Information Security Policy, all services provided by
external third parties require a clear contract between Fujitsu Services and the external organisation,
detailing all the key aspects of Information Security that are part of the defined service to be delivered,
including the right of Fujitsu to audit the security of the service provided.

As with internal support functions, audits will be carried out periodically by Fujitsu to confirm that the
various contractual clauses are being adhered to.

In addition Section 10.8 of the RMGA Information Security Policy provides the guidance and controls on
the security requirements for exchange of information between third parties.

9.8 RMGA Information Security Management Review (ISMR)

To ensure that areas of security risk or concern are assessed, appropriate controls are defined and
effectively implemented and to manage levels of security risk to an appropriate level there is a
Management forum, the RMGA Information Security Management Review meeting. Objectives and
responsibilities of the meeting are documented in “Fujitsu Services RMGA ISMR Terms of Reference
(SVM/SEC/STD/0027)’. Also included in the document is a membership list, mode of operation and
deliverables.

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