Data Security Policy THE CTA. Guardian Electrical Solutions Ltd DATA SECURITY POLICY. Reviewed and approved by the Company Secretary Richard Roebuck

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1 THE Data Security Policy CTA Reviewed and approved by the Company Secretary Richard Roebuck Signed 04/01/2013

2 INDEX SECTION DESCRIPTION 1.0 INTRODUCTION 2.0 AND ARRANGEMENTS 3.0 MONITORING THE SECURITY POLICY 4.0 REVIEWING THE SECURITY POLICY 5.0 PUBLICISING THE SECURITY POLICY

3 1.0 INTRODUCTION This Data Security document describes the arrangements in place to ensure the security and continuance of Company and Client data collated held and distributed by Guardian Electrical Solutions Limited (Guardian). 2.0 AND ARRANGEMENTS Security of Data All data is held remotely on our MemSet system which has the following characteristics: Technology We have based our service on OpenStack, which is a collection of open source software developed and supported by a wide range of cloud experts. This gives you complete peace of mind as our Memstore solution is founded on tried, tested and compatible Object Storage software. Combined with seamless integration with our existing infrastructure this enables us to provide the best cloud storage solution around. We have built upon OpenStack to provide a range of additional features too, including: Encrypted on the disk Secure by default (https) SFTP interface FTP interface Serve any public container via HTTP using own domain Resilience Triple redundancy has been built into into our Memstore system so there are always three replicas of data. In the unlikely event of a disk failure the system will automatically fill in the gaps from the other disks. As there will be no disturbance to either Client data or access the event will proceed largely unnoticed. Statistical analysis on the probability of data loss has been carried out and indicates an object durability to be %. This means that any individual object (file) stored in Memstore has a %, or 1 in 100,000,000 chance per year of being lost. By comparison, 6 x 2TB disks in a RAID6 array with a hot spare (generally considered by most IT professionals to be "bullet proof") has a 1 in 75,000 chance per year of significant or total data loss. Security Data is held on our Memstore system with security in mind, in line with its ISO27001 security accreditation. Access to files in Memstore is based on a token system which verifies authorisation and access level, providing a high level of security for Client data without compromising download speed. For added security different permission levels can be assigned to the various people with access to Memstore. They can either have account level access and be able to access all containers (essentially folders), write to them and delete them, or they can have Container Level access whereby permissions for each individual container can be set. This flexibility allows information to be accessed without making any security concessions.

4 Standards & Accreditations External hacking attacks The most common (although not usually the most determined) form of actual data theft is one over the wire; if the server is accessible via the Internet then it is in a known virtual location (its IP address) which can then be targeted. We provide a range of services to help mitigate such attacks, including our Memset -managed SLA, Packet Patrol managed firewall, Perimeter Patrol vulnerability scanning and Penetration Patrol intrusion detection. Physical security The data centres all have the standard set of security measures; 24/7 monitoring, secure perimeters, personal swipe cards for entry, and no one is allowed into the buildings unaccompanied by the cleared staff. Internal staff are not allowed access to data centre locations without supervision and clearance from the head of security either. Data destruction A potential threat to data security is recycling of hardware back into our pool, be it from virtual machines, cloud storage or dedicated servers. Our approach to this is two-fold. First, whenever a server which has contained customer data is deprovisioned, its hard disks are labelled as "DIRTY" in our asset management system. Our automated systems will not allow such a hard drive to be redeployed until it has been "cleaned" which we do by overwriting the entire disk with random data twice. All the hardware remains in our control, in our secure data centres, and accessed only by our authorised personnel. Two wipes is sufficient to prevent data recovery via the hard disks own mechanisms. Second, broken hard disks are brought back to our secure head office location by means of our transport and personnel. Our hard drive destruction supplier comes to our offices and we observe them as they put the hard disk drives into a giant industrial shredder. The disks and their magnetic platters are all reduced to small fragments, from which data recovery would be impossible. Personnel / 'purchase key' attacks We take such threats very seriously, and undertake a number of steps to ensure that our customers are not vulnerable to such attacks: 1. All staff are CRB & background checked. 2. Only our systems administrators have access to customer servers. 3. Access to customer servers is gained via personal keys, and all access is logged. 4. Logs and activity are routinely checked by our head of security. 5. Organisational separation of those who have physical access to servers, and those who know what is on the servers (see above).

5 Denial of service attacks We provide a layer of defence against DOS attacks. Our firewall automatically detects incoming traffic that looks abnormal and starts ignoring traffic from that IP address. This is known in the industry as a "DOS squasher". In the event of an ultra-high level attack (highly unlikely in the case of our client s data), our multi-location architecture provides protection via a network of multiple data centre providers with independent uplinks providing a multi-site clustering approach. 3.0 MONITORING THE SECURITY POLICY The Company carries out monitoring activities to assess whether the Policy is being effectively implemented within the organisation and the extent of its effectiveness. Monitoring takes the form of an assessment of the following: Data access performance, Customer feedback via Customer service calls Incident investigation and analysis Register of downtime and outage (if any occurred in previous 12 months) The results of the monitoring activity enable management to assess the robustness of the arrangements and the success in following the policy and arrangement procedures. The objective of the monitoring process is to assist decision-making as to the allocation of resources and preventive measures most effectively. 4.0 REVIEW OF THE The policy will be reviewed by the Company Secretary every twelve months or as and when there are: Significant changes to the organisation structure, scope or core activities. Changes in client requirements. Changes in applicable legislation. When the policy has been reviewed and updated it will be authorised by the Company Secretary and re-issued. 5.0 PUBLICISING THE A copy of the Policy is available on the Company Intranet and is also made available to relevant stakeholders including Clients for whom data is collated and maintained.