Information Security Policy

Policy Owner: Chief Privacy Officer

Effective Date: May 8, 2024

Overview

This Information Security Policy is intended to protect Caredove Inc.’s employees, partners and the Company from illegal or damaging actions by individuals, either knowingly or unknowingly.

Internet/Intranet/Extranet-related systems, including but not limited to computer equipment, software, operating systems, storage media, network accounts providing electronic mail, web browsing, and file transfers, are the property of Caredove Inc.. These systems are to be used for business purposes in serving the interests of the Company, and of the Company’s clients and customers in the course of normal operations.

Effective security is a team effort involving the participation and support of every Caredove Inc. employee or contractor who deals with information and/or information systems. It is the responsibility of every team member to read and understand this policy, and to conduct their activities accordingly.

Purpose

The purpose of this policy is to communicate Caredove Inc.’s information security policies and outline the acceptable use and protection of Caredove Inc.’s information and assets. These rules are in place to protect customers, employees, and Caredove Inc.. Inappropriate use exposes Caredove Inc. to risks including virus attacks, compromise of network systems and services, financial and reputational risk, and legal and compliance issues.

The Caredove Inc. “Information Security Policy” is comprised of this policy and all Caredove Inc. policies referenced and/or linked within this document.
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Scope

This policy applies to the Platform, use of information, electronic and computing devices, and network resources to conduct Caredove Inc. business or interact with internal networks and business systems, whether owned or leased by Caredove Inc., the employee, or a third party. All employees, contractors, consultants, temporary, and other workers at Caredove Inc. and its subsidiaries are responsible for exercising good judgment regarding appropriate use of information, electronic devices, and network resources in accordance with Caredove Inc. policies and standards, and local laws and regulations.

This policy applies to employees, contractors, consultants, temporaries, and other workers at Caredove Inc., including all personnel affiliated with third parties. This policy applies to all Caredove Inc.-controlled company and customer data as well as all equipment, systems, networks and software owned or leased by Caredove Inc..

Security Incident Reporting

All users are required to report known or suspected security events or incidents, including policy violations and observed security weaknesses. Incidents shall be reported immediately or as soon as possible by contacting the Chief Technology Officer.

In the incident report please describe the incident or observation along with any relevant details, as per the Incident Response Plan.

Whistleblower Fraud Reporting

Caredove Inc.’s Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns internally so that we can address and correct inappropriate conduct and actions. It is the responsibility of all employees to report concerns about violations of the Company’s code of conduct or suspected violations of law or regulations that govern the Company’s operations.

It is contrary to Caredove Inc.’s values for anyone to retaliate against any employee or who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment.

Anonymous reports may be submitted via this form.
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Mobile Device Policy

All end-user devices (e.g., mobile phones, tablets, laptops, desktops) must comply with this policy. Employees must use extreme caution when opening email attachments received from unknown senders, which may contain malware.

System level and user level passwords must comply with the Access Control Policy. Providing access to another individual, either deliberately or through failure to secure a device is prohibited.

Employee-owned end-user devices may be used to access Business Applications and The Platform. Company-owned and BYOD devices shall be configured following the End-User Device Configuration Procedures and End-User Device Configuration Standard. Employee devices that are not centrally controlled shall not access any Caredove Business Application. BYOD devices should be limited to low risk activities and shall not be used to access PHI.

To respect the privacy of employees, the application used to centrally control BYOD devices shall not have the capability to access any personal data on the device.

All end-user, personal (BYOD) or company owned devices used to access Caredove Inc. information systems (i.e. email) must adhere to the following rules and requirements:

Devices must be locked with a password (or equivalent control such as biometric) protected screensaver or screen lock when unattended.
Devices must be locked whenever left unattended
Users must report any suspected misuse or theft of a mobile device immediately to the Chief Privacy Officer.
Confidential information must not be stored on mobile devices or USB drives (this does not apply to business contact information, e.g., names, phone numbers, and email addresses)
Any mobile device used to access company resources (such as file shares and email) must not be shared with any other person
Upon termination users agree to return all company owned devices and delete all company information and accounts from any personal devices
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Clear Screen Clear Desk Policy

Users shall not leave confidential materials unsecured on their desk or workspace, and will ensure that screens are locked when not in use.
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Remote Access Policy

Laptops and other computer resources that are used to access the Caredove Inc. network must conform to the security requirements outlined in Caredove Inc.’s Information Security Policies and adhere to the following standards:

To ensure mobile devices provisioned by Caredove Inc. do not connect a compromised device to the company network, Antivirus policies require the use and enforcement of client-side antivirus software
Antivirus software must be configured to detect and prevent or quarantine malicious software, perform periodic system scans, and have automatic updates enabled
Users are prohibited from changing or disabling any organizational security controls such as personal firewalls, antivirus software on systems used to access Caredove Inc. resources
Use of remote access software and/or services (e.g., VPN client) is allowable as long as it is provided or approved by the Company and configured for multifactor authentication (MFA)
Unauthorized remote access technologies may not be used or installed on any Caredove Inc. system
Users shall use a VPN when accessing databases containing protected health information
If employees access company resources from a public computer (e.g., from a business center, hotel, etc.), log out of the session and don’t save anything. Don’t check “remember me”, collect all printed materials and do not download files to a non-Caredove Inc. controlled system
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Acceptable Use Policy

Caredove Inc. proprietary and customer information stored on electronic and computing devices, whether owned or leased by Caredove Inc., the employee or a third party, remains the sole property of Caredove Inc. for the purposes of this policy. Employees and contractors must ensure through legal or technical means that proprietary information is protected in accordance with the Data Management Policy. The use of Google Drive for business file storage is required for users of laptops or company issued devices. Storing important documents on the file share is how employees “backup” their laptop.

Employees have a responsibility to promptly report the theft, loss, or unauthorized disclosure of Caredove Inc. proprietary information or equipment. Employees may access, use or share Caredove Inc. proprietary information only to the extent it is authorized and necessary to fulfill the employee’s assigned job duties. Employees are responsible for exercising good judgment regarding the reasonableness of personal use of company-provided devices.

For security and network maintenance purposes, authorized individuals within Caredove Inc. may monitor equipment, systems and network traffic at any time.

Caredove Inc. reserves the right to audit networks and systems on a periodic basis to ensure compliance with this policy.
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Unacceptable Use

The following activities are, in general, prohibited. Employees may be exempted from these restrictions during the course of their legitimate job responsibilities with properly documented Management approval. Under no circumstances is an employee of Caredove Inc. authorized to engage in any activity that is illegal under local, state/provincial, federal or international law while utilizing Caredove Inc.-owned resources or while representing Caredove Inc. in any capacity. The list below is not exhaustive, but attempts to provide a framework for activities which fall into the category of unacceptable use.

The following activities are strictly prohibited, with no exceptions:

Violations of the rights of any person or company protected by copyright, trade secret, patent, or other intellectual property, or similar laws or regulations, including, but not limited to, the installation or distribution of "pirated" or other software products that are not appropriately licensed for use by Caredove Inc.
Unauthorized copying of copyrighted material including, but not limited to, digitization and distribution of photographs from magazines, books, or other copyrighted sources, copyrighted music, and the installation of any copyrighted software for which Caredove Inc. or the end user does not have an active license
Accessing data, a server, or an account for any purpose other than conducting Caredove Inc. business, even if the employee has authorized access, is prohibited
Exporting software, technical information, encryption software, or technology, in violation of international or regional export control laws, is illegal. The appropriate management shall be consulted prior to export of any material that is in question
Introduction of malicious programs into the network or systems (e.g., viruses, worms, Trojan horses, email bombs, etc.)
Revealing account passwords to others or allowing use of employee accounts by others. This includes family and other household members when work is being done at home
Using a Caredove Inc. computing asset to actively engage in procuring or transmitting material that is in violation of any federal, provincial or municipal laws
Making fraudulent offers of products, items, or services originating from any Caredove Inc. account
Making statements about warranty, expressly or implied, unless it is a part of normal job duties
Effecting security breaches or disruptions of network communication. Security breaches include, but are not limited to, accessing data of which the employee is not an intended recipient, or logging into a server or account that the employee is not expressly authorized to access, unless these duties are within the scope of regular duties. For purposes of this section, "disruption" includes, but is not limited to, network sniffing, pinged floods, packet spoofing, denial of service, and forged routing information for malicious purposes
Port scanning or security scanning is expressly prohibited unless prior notification to the Caredove Inc. engineering team is made
Executing any form of network monitoring which will intercept data not intended for the employee's host, unless this activity is a part of the employee's normal job/duty
Circumventing user authentication or security of any host, network, or account
Introducing honeypots, honeynets, or similar technology on the Caredove Inc. network.
Interfering with or denying service to any user other than the employee's host (for example, denial of service attack)
Using any program/script/command, or sending messages of any kind, with the intent to interfere with, or disable, a user's session, via any means
Providing information about, or lists of: Caredove Inc. employees, contractors, partners, or customers to parties outside Caredove Inc. without authorization
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Email and Communication Activities

When using company resources to access and use the Internet, users must realize they represent the Company and act accordingly.

The following activities are strictly prohibited, with no exceptions:

Sending unsolicited email messages, including the sending of "junk mail", or other advertising material to individuals who did not specifically request such material (email spam)
Any form of harassment via email, telephone, or texting, whether through language, frequency, or size of messages
Unauthorized use, or forging, of email header information
Solicitation of email for any other email address, other than that of the poster's account, with the intent to harass or to collect replies
Creating or forwarding "chain letters", "Ponzi", or other "pyramid" schemes of any type
Use of unsolicited email originating from within Caredove Inc. networks or other service providers on behalf of, or to advertise, any service hosted by Caredove Inc. or connected via Caredove Inc.’s network

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Security Training

Personnel are required to complete an annual General Awareness Security Training, which includes training on malware and phishing. Completion of the training is tracked and enforced.

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Additional Policies and Procedures Incorporated by Reference

Personnel are responsible for reading and complying with all policies relevant to their roles and responsibilities. Current or prospective customers may request access to these policies and other security-related information through Caredove's Trust Report at https://trust.caredove.com
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Role	Purpose
Access Control Policy	To limit access to information and information processing systems, networks, and facilities to authorized parties in accordance with business objectives.
Asset Management Policy	To identify organizational assets and define appropriate protection responsibilities.
Business Continuity & Disaster Recovery Plan	To prepare Caredove Inc. in the event of extended service outages caused by factors beyond the Company’s control (e.g., natural disasters, man-made events), and to restore services to the widest extent possible in a minimum time frame.
Data Management Policy	To ensure that information is classified and protected in accordance with its importance to the organization.
Human Resources Policy	To ensure that employees and contractors meet security requirements, understand their responsibilities, and are suitable for their roles.
Incident Response Plan	Policy and procedures for suspected or confirmed information security incidents.
Operations Security Policy	To ensure the correct and secure operation of information processing systems and facilities.
Physical Security Policy	To prevent unauthorized physical access or damage to the organization’s information and information processing facilities.
Risk Management Policy	To define the process for assessing and managing Caredove Inc.’s information security risks in order to achieve the Company’s business and information security objectives.
Secure Development Policy	To ensure that information security is designed and implemented within the development lifecycle for applications and information systems.
Third-Party Management Policy	To ensure protection of the organization's data and assets that are shared with, accessible to, or managed by suppliers, including external parties or third-party organizations such as service providers, vendors, and customers, and to maintain an agreed level of information security and service delivery in line with supplier agreements.

Policy Compliance

Caredove Inc. will measure and verify compliance to this policy through various methods, including but not limited to ongoing monitoring, and both internal and external audits.

Exceptions

Requests for an exception to this policy must be submitted to the Chief Technology Officer for approval.

Violations & Enforcement

Any known violations of this policy should be reported to the Chief Technology Officer. Violations of this policy can result in immediate withdrawal or suspension of system and network privileges and/or disciplinary action in accordance with company procedures up to and including termination of employment.
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Version	Date	Description	Author	Approved by
1	Nov 1, 2022	First version	Matt Habermehl	Tim Berezny
1.1	May 8, 2024	Minor Update	Jeff Doleweerd	Tim Berezny