RMG00000318 - Intouch Management Communication Systems Limited report re: Service Agreement - concerning Services, Promotion, Caller Anonymity and more

Evidence on official site

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INTOUCH MANAGEMENT COMMUNICATION SYSTEMS LIMITED
SERVICE AGREEMENT

InTouch Management Communication Systems Limited of Blythe Valley
Innovation Centre, Blythe Valley Park, Shirley, Solihull B90 8AJ, United
Kingdom (“InTouch”) and Royal Mail Group Limited, 100 Victoria
Embankment, London EC4Y OHQ United Kingdom (the “Client”), hereby
agree as follows:

Definitions

Client’s Personnel means the employees, staff, agents, sub-contractors
and advisors of the Client and its direct and indirect subsidiaries including
General Logistics Systems B.V. For the avoidance of doubt, Client’s
Personnel shall include Post Office Limited sub-postmasters.

Effective Date means 02™ August 2010
1. Services

1.1 InTouch will provide the Client with the following services (“The
Services”):

(a) InTouch will provide access 24 hours a day, 365 day a year
access to all of the Client’s Personnel (the “Client’s Personnel”)
in the United Kingdom as set out in Schedule A to (i) call
handlers (ii) its secure web reporting facility and (iii) its
automated ‘SpeakUp’ IVR system. Telephone access is via a free
phone number. The service is intended to be used for the
recording of the Client’s Personnel’s concerns of a
“whistleblowing” nature and other malpractice issues, including
fraud, financial irregularities and HR concerns.

(b) InTouch will agree with the Client a script that callers will hear
when they contact the IVR system. InTouch will agree with the
Client the text that will be shown on the web reporting pages.
InTouch will further agree with the Client the framework of

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_ questions to be used by the call handlers. The Client can amend
the script, text on the web reporting Page and framework of
questions at any point during the term at no additional cost.

(c) InTouch will forward as appropriate the call handlers’ notes or
verbatim transcripts of the concerns raised by its Client's
ial Personnel to the Client’s nominated contacts usually by the next
working day after receipt. Messages will normally be forwarded
by e-mail and will always be encrypted through PGP encryption.
7 (d) The Client wil! receive all messages left by employees. InTouch
does not filter messages on behalf of the Client.
(e) The Client is able to respond to anonymous messages as
designated by Unique case numbers via the InTouch systems to

Provide feedback or ask follow-up questions of the Eligible
i Employee.

(f) A monthly summary of the type and number of messages

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(g) InTouch will Provide a named point of contact to account
7 manage the service and Provide ad hoc information as and when
requested by the Client.

fo I (h) The parties will meet on a three monthly basis at a location of
I the Clients choice, to discuss the Services.

(i) Intouch will meet the service levels as further detailed in
Schedule B.

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(i) InTouch will comply with Royal Mail Policies and best practice as
detailed in Schedule C.

1.2. InTouch shall Perform the Services with such care, skill and diligence
and to such high standard of quality as it is reasonable for the Client to
expect in all the circumstances,

—l

—l

1.3. The Services shall accord with the terms of any statute, act, instrument,
regulation, directive, decision and code of practice or other measure at
any time in force and affecting such Services.

—l

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1.4 InTouch represents and warrants that the assurances given in Schedule
B under ‘Agreed Service Level’ will remain true and accurate during the
term of the Agreement.

2, Promotion

InTouch will provide the Client with generic information taking into
account local legal requirements to help the Client develop materials
necessary to promote access by the Client’s Personnel. The Client is
responsible for any personalisation of such materials and can choose
to promote the service under the Fame ‘InTouch’, ‘SpeakUp’ or any
other name of their choice.

3. Caller Anonymit

this clause does not apply and InTouch will Provide a Client with all
information in its possession

4, Confidentiality

4.1 InTouch will keep confidential and will not disclose to any other
Person, firm or corporation other than the Client, any information it
receives by virtue of its provision of the Services (including, without
limitation, any information concerning the Client and the content of
any messages InTouch receives Concerning the Client) (the
“Information”). InTouch shall use the Information solely for the
Purpose of providing the Services to the Client and not for any other
Purpose.. InTouch may create compilations and reports to the Client
of generic information in formats which will not allow matching of calls
with particular Client’s Personnel,

4.2 InTouch shall not disclose the Information directly or indirectly to any
person except those of its officers, employees and the call handling
Partner Personal Performance Consultants UK Limited, who have a
need to know (and only to the extent that each has a need to know)
for the Purposes of providing the Services and who are aware that all
Information must be kept confidential.

4.3. InTouch shall securely return the Information, all copies, notes and
records of the Information to the Client and securely erase and destroy
the Information from any computer or other device within the control
of InTouch immediately upon request and shall confirm to the Client in
writing that InTouch has complied with this clause 4.3 in its entirety.

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4.4

4.5

4.6

4.7

5.1

5.2

5.3

5.4

6.1

6.2

InTouch shall not advertise or otherwise publicise its relationship with
the Client or the Client’s group of companies in any way (except with
the prior written consent of the Client).

All communications between InTouch and Royal Mail will be secure and
encrypted through PGP encryption,

InTouch shall protect the confidentiality of the Information both from
internal and external threats, by Providing the Services with such care,
skill and diligence and to such high standard of quality as it is
reasonable for the Client to expect in all the circumstances,

InTouch shall indemnify and keep the Client and Client Personnel
indemnified against any and all loss incurred or suffered by the Client
howsoever arising as a result of, or in connection with, a breach or
failure by InTouch to comply with its obligations in this clause 4,

Payment Terms

The fees for the Services described in this Agreement are made up of
an initial set-up fee and a recurring annual fee. The set-up fee is
invoiced on the date the Agreement is signed. The annual fee is
invoiced on the Effective Date and annually thereafter. The fees for the
Services and the Effective Date are set out in Schedule A.

Subject to InTouch satisfactorily performing its obligations under this
Agreement, the Effective Date is to be a date not later than 120 days
after the Agreement is signed.

The Client shall pay all undisputed invoices issued in accordance with
this Agreement within 45 days of the date of invoice

The Charges shall be as stated in this Agreement and, unless otherwise
so stated, shall be exclusive of any applicable value added tax (which
shall be payable by the Client subject to receipt of a VAT invoice).

Term and Termination

This agreement will commence on the Effective Date as set out in
Schedule A and will continue until terminated in accordance with this
clause.

Either the Client or InTouch may terminate this agreement
immediately upon:

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6.3

6.4

91

9.2

10.

6.2.1 a material breach by the other upon 7 days’ written notice. The
Parties agree that any breach of clause 4 by InTouch shall be
deemed a material breach; or

6.2.2 the other party ceasing or threatening to cease to carry on
business or is unable to Pay its debts as they fall due for
Payment.

The Client may also terminate this Agreement immediately upon any
breach of clause 4 by InTouch.

Either party may terminate the agreement at any time on giving 90
days’ written notice. Any amounts paid in advance by the Client shall
be pro-rated such that the Client shall be reimbursed upon demand
any amounts paid in respect of a Period falling after the date of
termination.

Liability of InTouch

The Client agrees that the amount of damages due from InTouch shall
not exceed three times any fees paid or payable to InTouch under this
agreement in the twelve month Period immediately preceding any
breach.

Governing Law

This agreement is governed by English law and the parties agree to
submit to the non-exclusive jurisdiction of the English Courts.

Contracts (Rights of Third Parties) Act 1999

InTouch acknowledges that it may provide Services under this
Agreement on behalf of other companies within the Client’s group and
therefore all such companies shall each have the benefit of the Client’s
rights under this Agreement and shall have the right to enforce such
rights in accordance with the Provisions of the Contracts (Rights of
Third Parties) Act 1999, Except as stated in this clause 9, the parties
to this Agreement do not intend that any of its terms will be
enforceable by virtue of the Contracts (Rights of Third Parties) Act
1999 by any person not a Party to it.

The parties reserve the right to rescind or vary this Agreement or vary
any term of it without the consent of any of the Client’s group
companies.

Sub-Contracting

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10.1 InTouch shall not sub-contract, assign or otherwise transfer part or all
of this Agreement or the Services without the Prior written consent of
an authorised representative of the Client.

10.2 Where callers choose to speak to a Service Representative this part of
the service is Provided by Personal Performance Consultants UK
Limited (“PPC”) whose address is set out in Schedule A.

10.3. InTouch shall remain at all times liable to Royal Mail for the acts
and/or omissions of PPC or any other sub-contractor.

11 Audit

11.1 The Client or any third party appointed by the Client or any regulator
with authority over the Client (“Inspector”) may enter upon InTouch’s
Premises and any property used by InTouch to provide the Services to

The Inspector shall be entitled to have access to all files, records,
Personnel and data relevant to the operation of this Agreement by
InTouch.

11.2 InTouch shall Procure that satisfactory facilities (including copying
facilities) are made available to the Inspector and that reasonable
assistance (including access to relevant Personnel) is given.

12. Severance

12.1 If at any time any one or more of the provisions hereof is or becomes
invalid, illegal or unenforceable in any respect under any law, the
validity, legality and enforceability of the remaining provisions hereof
shall not be in any way affected or impaired thereby.

12.2 If any such provisions shall be found to be invalid or unenforceable but
would be valid if some Part thereof were deleted or the period or area
of application reduced, such provisions will apply with such
modification or modifications as may be necessary to make them valid
and effective,

13. Reputation

InTouch shall not do or omit to do anything which might damage the
reputation and/or goodwill of the Client (or any member of the Client’s
group of companies).

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14. __ Provision of Information
+4.___Provision of Information

InTouch shall provide such Management information as the Client may
require from time to time in respect of the Services,

15. Amendments

No alteration, waiver or Modification of this Agreement shall be
binding on the Client unless made in writing and signed by an
authorised representative of the Client.

16. Notices
Any notice or other communication required to be given by InTouch
under this Agreement shall be addressed to (insert Client’s

address) and may be Personally delivered (such term for the
Purposes of this clause to include delivery by courier)

IN WITNESS WHEREOF the duly authorised representatives of the parties
hereto have signed this Agreement the day and year first above written.

INTOUCH MANAGEMENT COMMUNICATION SYSTEMS LIMITED
(Duly authorised signatory)

NAME: Town NL Seay

TITLE: Direcbeor

Royal Mail Group Limited

(Duly authorised signatory) {
NAME: i I

TITLE: TT. Buetocm.
ACAD OF FACTICAK S00 Rc 2g—

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The Charges will be reviewed on an annual basis.

1. Fee Structure (exclusive of VAT)

SCHEDULE A

Fees are based on approximately 180,000 employees nationwide

across the UK

Initial System Configuration:

(a) Programming of the telephone and web platform, scripting
customised web intake and telephone prompts; translation work;
Personalisation of web and telephone intake for each country /
language/ regulatory combination

(b)

Project management: orientation of call handlers; advice on suitable
Promotional campaigns; supplying generic artwork if required

For (a) and (b) a one off set fee of £1,650 will be paid

(i) Annual Service Fee

Fully inclusive of freephone charges and ongoing account management;
translation of employees’ messages as required; regular management
information; legal and best Practice updates

A fixed fee of £32,400 will a

pply for up to 400 calls. For any additional

calls the following cost per call will apply.
[ Total number of Cost per

calls per year call

401-500 £45

501-1000 £36

1001-1500 £27

1501-2000 £21

2001+ Free of

charge

Any original design, print and

extra cost

Subject to VAT at the standard rate

Production costs of promotional items is at

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Page

1

Countries and languages

Access to the InTouch call handling, web and IVR Services is from the
following countries and in the following languages:

Country Language
United Kingdom English

PBC

Personal Performance Consultants UK Limited

4200 Nash Court
Oxford Business Park
Oxford

OX4 2RU

SCHEDULE B

Service Level Agreement

Required Service Description of risk and
issue to be addressed
Overarching question
about the data.

Do you store anywhere
the name of the
company?

Do the paper and
computer records contain
the name of the company
or just an anonymous
reference to it?

Paper records: Where are the paper

All clients - A paper copy records kept?

of each message is Do you use Safes?
retained for one month to

assist the reporting

process. During the next

month the paper records

are shredded as each

client's monthly report is

produced. Documents

are shredded in a cross

cut shredder in our

office. Paper copies of

regular monthly or

weekly summaries may

also be retained for one

month and then

shredded.

Security of data

Computer records:
Whistleblowing clients -

How are the computer
records deleted?

Agreed Service Level

Intouch to set up their systems so that we do not
use the name Royal Mail and instead usea
pseudonym.

The transcriptions of reports can contain
headers which are similarly anonymised but if
there is specific mention of a location or
individual then it would not seem sensible or
Practical to redact these references.

Paper records are kept in a fire proof safe
overnight.

Files are deleted and erased using a secure
shredder utility. Unused disk Space is securely

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Page

Required Service

Client messages in Word
and sound files of
messages are retained
for 2 months and then
deleted. On a client by
client basis we may
agree to delete sound
files and Word
documents as soon as a
client acknowledges
receipt of a message.

Reports for
whistleblowing clients
will contain anonymised,
brief summaries of
messages received so
that individuals
mentioned in the
summaries cannot be
identified. These
summaries will be
retained for 12 months.
Computer back ups:
These are carried out on
a daily basis and the
tapes are retained off
site in a safe in the home
of one of the Company's
Directors.

Access to office pc's:

All pc's and servers are
Password protected. As
all office based staff
have a need to access
all the files the
Passwords on each pc or
server are known to all
staff.

McAfee VirusScan
Enterprise is in use on all
our systems. The
Firewall has the latest
updates installed on a
daily basis.

Description of risk and
issue to be addressed
How are they removed
from backups?

Do the reports contain
Information about the
company the
whistleblower works for?

Do the computer backups
contain word and sound
files?

Are they encrypted? If so
how?

Access to Office PC’s
How often are the
Passwords changed?
Are the pcs accessible
remotely from staff?
Does each user have a
unique ID and password?
Do you change the
shared
Password/accounts when
a user leaves?

Who manages the
firewalls?

Do you have a dedicated
team?

How do you handle
security incidents?

Agreed Service Level

wiped on a weekly schedule. Backups of files
made prior to deletion are retained for one week
on password protected media with restricted
access to restore files.

Yes, in so far as the information is required to
enable Royal Mail to appropriately investigate
the reported incident

Identifiable word and sound files are backed up
on password protected media.

Passwords for office PCs are changed every
three months and when a member of staff
leaves.

Staff do not have remote access to their PCs or
files stored on shared network drives.

Usernames and passwords are configured and
different for each user. Internal User-IDs of
former staff are deleted or disabled.

Shared passwords permitting remote access to
the web reporting application are changed every
three months or at the time staff leave

Network Firewalls are Netgear “Prosafe” units
with the latest software updates installed.

These are managed by external IT support staff
and no internal staff have access to their
configuration.

There is no UPNP support for firewall
configuration from client PCs.

McAfee Enterprise Anti-Virus is monitored
internally on a weekly basis to ensure systems
are up to date and updated with the latest
Patches as they are released and stable.
Security incidents are minimised by maintaining
good user practices and very restricted personal
use of IT systems, coupled with appropriate

10

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Page Required Service Description of risk and Agreed Service Level
issue to be addressed
business security measures, which are
monitored and updated regularly.

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SCHEDULE C

ies with which InTouch must Comply

1) Third Party Services Policy

Purpose of the policy

To ensure that the Royal Mail Group information security requirements are identified, agreed and
maintained whenever services encompassing Royal Mail Group information or information systems are
entrusted to a third-party.

Risks 22d implications

A failure to comply with this policy could expose the Royal Mail Group to inadequate assessment of the
information risks associated with outsourcing a particular function of the business, incorrect identification
of the controls required to manage these risks and insufficient monitoring and review of controls in the
outsourced function.

Furthermore, a failure could constitute a breach of our legislative, regulatory and/or contractual
requirements, including the Data Protection Act (1998).

Who does this policy apply to?

All Royal Mail Group employees who have the authority and responsibility to prepare and engage the
organisation in third-party service contracts.

Scope of the policy

This policy applies to all Royal Mail Group contracts with third-party and outsourced service providers,
suppliers, vendors and resellers.

Policy statements

Itiis the policy of the Royal Mail Group that:

12a All third-party contracts must be approved by the Royal Mail Legal department and include the
following:

: the determination of acceptable service levels and availability;

* the right for the Royal Mail Group to physically and logically audit the third-party
environment for the appropriateness and effectiveness of the security controls applied to the
Royal Mail Group's information;

* the need for the third-party to implement the Royal Mail Group policies for all services
provided to the Royal Mail Group;
* documentation of physical and logical controls employed by the third-party to protect the

confidentiality, integrity and availability of the Royal Mail Group information and
information systems;

* the determination of all legal and regulatory requirements including privacy and data
protection;

* the need for the third-party to uphold the confidentiality of all Royal Mail Group information
and information systems; and

* agreement that the third-party must maintain and periodically test the agreed security controls
and report the results to the Royal Mail Group.

1.2b Royal Mail Group contract managers must be assigned the responsibility of managing the
relationship with the third-party and ensuring that the third-party is enforcing the requirements
specified in the contract.

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1.2¢ All third-parties must be required to immediately inform the Royal Mail Group contract manager
of any security breaches, including unauthorized access to or compromise of the Royal Mail Group
information or resources,

1.2d The ownership of any software developed by third-parties, on behalf of the Royal Mail Group,
must be defined in the contract agreement.

1.2e Formal exchange agreements must exist between contracted third-parties and the Royal Mail
Group for exchanging information.

1.2f Risk assessments must be performed whenever the third-parties make significant changes to the
Services and products delivered to the Royal Mail Group (e.g. introduce new technologies, new
development environments and tool: 's, new hosting facilities),

12g All physical and logical access to the Royal Mail Group information and information systems must
adhere to the Third-Party Access Policy.

1.2h All third-party agreements must specify the requirements for transitioning information and
information systems back to the Royal Mail Group to ensure that the appropriate level of security
is maintained.

Compliance

Group Information Security will regularly assess for compliance against this policy. Any violation of this
Policy will be investigated and ifthe cause is found due to wilful disregard or negligence, it will be treated
as a disciplinary offence. All disciplinary proceedings are coordinated through the Human Resourses
Department.

The Royal Mail Group reserves the right to amend this policy at any time and will publish updated versions
to all staff.

Associated policies, guidelines and procedures

1.2a-1.2h
12g

ISO 27002 controls addressed

A6.1.5, A6.2.1, A6.2.3, A10.2. 1, A10.2.2, A10.2.3, A10.8.2, A12.5.5

2. Incident Management Policy

Purpose of the policy

To minimise the impact caused by information security incidents and malfunctions on information systems
operated by or on behalf of the Royal Mail Group.

Risks and implications

A failure to comply with this policy could expose the Royal Mail Group to a prolonged impact arising from
unreported or unmanaged information security incidents, an inability to collect and present legally
admissible evidence and a breach of our legislative, regulatory and/or contractual requirements, including
the Data Protection Act (1998) and PCI DSS.

Who does this policy apply to?

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All Royal Mail Group employees and all agents, contractors, consultants and business partners (hereafter
referred to as ‘users’) handling Royal Mail Group information,

Scope of the policy

All information and information systems developed by or on behalf of Royal Mail Group, including joint
venture companies and outsourced units,

Policy statements

Itis the policy of the Royal Mail Group that:

8:1a All users must immediately report all information security incidents and events, or suspected
information security weaknesses, to the appropriate management channels and/or the Royal Mail
Group IT Helpdesk.

8.1b It is prohibited for users to test any information security weaknesses without the cooperation and
involvement of Group Information Security.

8.1c All users must not disclose the details of any information security incidents to non-contracted third
parties without explicit management authorisation.

8.1d Formal information security incident management procedures, including a method of incident
categorisation based upon type, impact and severity levels, must be developed to ensure a timely,
effective, and managed response to information security incidents,

8.le These procedures must explicitly define the roles and responsibilities assigned to manage
information security incidents (e.g. technical response teams, management, business analysts,
Legal, HR and Communications representatives) as well as reporting and escalation procedures.

8.1f All files collected as evidence in the investigation of a security incident must be collected and
Secured using appropriate forensics procedures, ensuring a chain of custody. Group Information
Security is responsible for performing or coordinating any collection of information for use in an
investigation.

8.1g _Alll reports of security incidents or violations of information security policy must be documented
and include a review process in order to identify root causes, define any required preventative
improvements and coordinate appropriate training and awareness sessions within the Royal Mail
Group.

Compliance

Group Information Security will regularly assess for compliance against this policy. Any violation of this
Policy will be investigated and if the cause is found due to wilful disregard or negligence, it will be treated
asa disciplinary offence. All disciplinary proceedings are coordinated through the Human Resources
Department.

The Royal Mail Group reserves the right to amend this policy at any time and will publish updated versions
to all staff.

Associated policies, guidelines and procedures

Information Security Incidents

ISO 27002 controls addressed
AIB.1.1, AI3.1.2, A.13.2.1, A.13.22, A323

3) User Access Management Policy

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Purpose of the policy

To ensure that the user access control requirements to the Royal Mail Group information and information
systems are appropriately defined.

Risks and implications

A failure to comply with this policy could expose the Royal Mail Group to accidental or deliberate misuse
of information systems, breaches of confidentiality, malicious or accidental corruption of data, theft of
intellectual property and a breach of our legislative, regulatory and/or contractual requirements, including
the Data Protection Act (1998) and PCI DSS.

Who does this policy apply to?

All Royal Mail Group employees and all agents, contractors, consultants and business partners (hereafter
referred to as ‘users’) requiring business access to the Royal Mail Group information and information
systems.

Scope of the policy

All information and information systems developed by or on behalf of Royal Mail Group, including joint
venture companies and outsourced units.

Policy statements

Itis the policy of the Royal Mail Group that:

6.2a All access to the Royal Mail Group information systems must be controlled by an approved
authentication method supporting a minimum of a user ID and password combination that provides
verification of the user’s identity.

6.2b All users must be limited to only one user account for each individual information system for non-
administrative purposes.

6.2c All individual user IDs must be unique for each user and never duplicated,

6.2d Shared user IDs must only be used if there is a clear business case and must be approved by the
Information Owner and Group Technology.

6.2e  Formalised user account management procedures must be implemented for user registration,
modification and de-registration on all Royal Mail Group information systems. These user account
management procedures must also include processes for monitoring redundant and inactive
accounts,

6.2f Information Owners must authorise all user access granted to and revoked from the Royal Mail
Group information systems using the approved user account management procedures.

6.2g All user access rights to the Royal Mail Group information and information systems must be
limited to the minimum access rights necessary for the user to fulfil their business responsibilities
as determined by their role.

6.2h All user access rights to the Royal Mail Group information and information systems must be
reviewed by the Information Owners on a periodic basis.

6.21 All user accounts that have not been accessed for 90 days must be automatically disabled, The
Information Custodians must inform the Information Owner of inactive accounts at regular
intervals.

6.2) All users that have access to privileged accounts must have their own individual accounts for
normal business use. Shared privileged accounts must never be logged into directly if their usage
can not be tracked.

6.2k All administrator and privileged accounts must be based upon job function and authorised by the
Information Owner prior to access being given. Alll changes to privileged accounts must be logged
and periodically reviewed.

6.21 All default system and vendor passwords must be changed immediately following installation,

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6.2m All Royal Mail Group information systems must support strong password management techniques

(cg. length, complexity, aging, history, account lockout) in accordance with the Guidelines for
User Access Management.

6.2n All Royal Mail Group information systems must technically force new user accounts to change the

initial password upon first use to a strong password and thereafter every 90 days in accordance
with the Guidelines for User Access Management.

6.20 Formalised procedures for the secure transmission of new and reset passwords that includes an
acknowledgement of receipt must be established.

62p Passwords must never be shared, written down or stored on information systems in an unprotected
form. User IDs and passwords must not be hard coded in scripts or clear text files such as system

shell scripts and batch jobs.

6.2q All users must sign a statement agreeing to keep their personal passwords confidential and to limit

group passwords to only members of the group.

Compliance

Group Information Security will regularly assess for compliance against this policy. Any violation of this

policy will be investigated and if the cause is found due to wilful disregard or negligence, it will be treated

as a disciplinary offence. All disciplinary proceedings are coordinated through the Human Resources
Department.

The Royal Mail Group reserves the right to amend this policy at any time and will publish updated versions

to all staff.

Associated policies, guidelines and procedures

Guidelines for User Access Management

ISO 27002 controls addressed

A8.3.3, A11.2. 1, A11.2.2, A11.2.3, A11.2.4, AI1.3.1, A11.5.2, A11.4.1, A11.6.1

4) Access Control Policy
Purpose of the policy

To ensure that the access control requirements to the Royal Mail Group information and information
systems are appropriately defined.

Risks and implications

A failure to comply with this policy could expose the Royal Mail Group to accidental or deliberate misuse

of information systems, breaches of. confidentiality, malicious or accidental corruption of data, theft of

intellectual property and a breach of our legislative, regulatory and/or contractual requirements, including

the Data Protection Act (1998) and PCI DSS.

Who does this policy apply to?

All Royal Mail Group employees and all agents, contractors, consultants and business partners (hereafter
referred to as ‘users”) requiring business access to the Royal Mail Group information and information
systems.

Scope of the policy

All information and information systems developed by or on behalf of Royal Mail Group, including joint
venture companies and outsourced units.

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Policy statements

It is the policy of the Royal Mail Group that:

6.2r

6.2s

6.2u

6.2v

6.2W

6.2x

6.2y

6.2z

6.2aa

6.2bb

6.2ce

Appropriate physical and logical access controls, in line with the business, security, legislative and
regulatory requirements and as determined by a risk assessment, must be established and
documented for all Royal Mail Group information and information systems.

Information systems processing or storing strictly confidential information must be segregated
from other information systems. The requirements and controls for the additional segregation of
networks and information systems must be determined following a risk assessment.

All access originating from untrusted networks (e.g. the Internet) into the Royal Mail Group
network and all internal access to information systems processing or storing information classified
as strictly confidential must use an approved two-factor authentication mechanism.

All third-party access to the Royal Mail Group network and information systems must adhere to
the same access restrictions as internal users in accordance with the Third-Party Access Policy.

All critical information systems and applications must limit and enforce access times. The
‘operating times for both batch jobs and interactive sessions must be limited to only the times
identified as necessary for completion of Royal Mail Group business processes. All access to these
systems and applications at all other times must be disabled or suspended.

All user, system and application sessions that are inactive for a pre-determined amount of time
must be automatically terminated. The amount of time permitted before session termination must
be aligned with the criticality of the information. Approved compensating controls, e.g. password
protected screensavers or terminal locks, must be activated for information systems and
applications that cannot automatically terminate sessions.

All critical information systems and applications must not allow users to have multiple concurrent
sessions on the same system.

All information systems must have, or support, password management systems that are interactive
and can ensure strong passwords to meet the requirements of the User Access Management Policy.
All information systems must not transmit passwords in clear text and passwords must not be
visibly displayed on the system when being entered.

Users given the opportunity to login to information systems must be presented with a login banner.
This must include a special notice which informs the user that the system is to be used only by
authorised users and that the use of this system constitutes consent to monitoring. Any additional
information that identifies the Royal Mail Group, network, location or host name must not appear.
All information systems, databases and applications that store user ID and password information
must be encrypted with access restricted to only authorised personnel.

Utilities that are capable of overriding information system and application controls or performing
low-level system maintenance must be approved with additional controls implemented in order to
restrict their use.

Compliance

Group Information Security will regularly assess for compliance against this policy. Any violation of this
policy will be investigated and if the cause is found due to wilful disregard or negligence, it will be treated
as a disciplinary offence. All disciplinary proceedings are coordinated through the Human Resources
Department.

The Royal Mail Group reserves the right to amend this policy at any time and will publish updated versions
to all staff.

Associated policies, guidelines and procedures

User Access Management Policy

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RMG00000318
RMG00000318

ISO 27002 controls addressed

A111, A.JLS5, A.11.6

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