Information Security Policy
Effective Date: August 08, 2023
1. Statement of Policy
Executive Coaching Group (“Employer”) is committed to the highest standard of information security. In doing so, Employer implements this Information Security Policy (“Policy”) to effectively communicate to its employee base the proper way to properly identify, categorize, and handle different levels of secured information.
This Policy applies to all employees and contractors of Executive Coaching Group. This Policy also applies to all individuals and entities who use Employer’s resources including but not limited to, contractors, temporary employees, and volunteers. This Policy is not intended to restrict communications or actions protected or required by applicable law.
As such, everyone listed above is expected to:
• Read, understand, and follow this Policy. You must seek guidance from your manager or other designated Employer resource before taking any actions that create information security risks or otherwise deviate from this Policy’s requirements. Employer may treat any failure to seek and follow such guidance as a violation of this Policy.
• Keep this Policy Confidential. Do not share this Policy with any person or entity within or outside of Executive Coaching Group unless authorized by the Information Security Coordinator. The Information Security Coordinator maintains a set list of approved persons and entities to whom this Policy can be shown. It is the Information Security Coordinator’s responsibility to oversee, evaluate, and assess person and entity risks before granting permission for the Policy to be shared.
Strong information security requires diligence by all workforce members, including employees, contractors, volunteers, authorized partners and any others accessing or using our information assets.
For the purpose of this Policy:
“Publicly Available” shall mean information that Employer has made available to the general
public. Information received from another party including customers that is covered under a
current, signed non-disclosure agreement must not be classified or treated as Public Information
“Confidential Information” shall mean information that may cause harm to Employer, its
customers, employees, or other entities or individuals if improperly disclosed, or that is not
otherwise publicly available.
“Restricted Information” shall mean information that may cause serious and potentially
irreparable harm to Employer, its customers, employees, or other entities or individuals if disclosed
or used in an unauthorized manner.
This Policy provides detailed information security guidance that you must follow in addition to any
other relevant documentation, including an Employee Code of Conduct and Employee Handbook.
This Policy covers all written, verbal and digital information held, used or transmitted by or on
behalf of the Employer, irrespective of media. This includes, but is not limited to:
a. paper records;
b. hand-held devices;
d. information stored on computer systems; and
e. information passed on verbally.
The information covered in this Policy may include:
a. personal data relating to, but not limited to, staff, customers, clients or suppliers;
b. other business information; and
c. confidential, classified, restricted and publicly available information.
4. Guiding Principles
Employer follows these guiding principles when developing and implementing information security
a. Executive Coaching Group strives to protect the confidentiality, integrity, and availability of
its information assets and those of its clients/customers.
b. We will comply with applicable information security, privacy, and data protection laws.
c. We will balance the need for business efficiency with the need to protect sensitive,
proprietary, or other confidential information from undue risk.
d. We will grant access to sensitive, proprietary, or other confidential information only to
those with a need to know and at the least level of privilege necessary to perform their
The Employer and its leadership recognize the need for a strong information security program.
The below will be implemented to ensure this goal is met:
a. Understand the information classification levels defined in the Information Security Policy.
b. As appropriate, classify the information for which one is responsible accordingly.
c. Access information only as needed to meet legitimate business needs.
d. Not divulge, copy, release, sell, loan, alter or destroy any information without a valid business purpose and/or authorization.
e. Protect the confidentiality, integrity and availability of Employer Information in a manner
consistent with the information’s classification level and type.
6. Classification Levels
Maintenance of this Policy is the responsibility of Employer’s Information Security Coordinator.
The use of this Policy has been approved by Executive Coaching Group’s executives/board
members. It is the responsibility of the Information Security Coordinator to ensure that the Policy is
reviewed at least annually and remains consistent. This Policy is enforced by the Information
Security Coordinator and the appropriate team within Executive Coaching Group.
a. Classification Levels
The Employer has established a classification scheme to protect information according to risk
levels. The information classification scheme allows the Employer to select appropriate
security controls and balance protection needs with costs and business efficiencies.
The classifications levels are:
i. Restricted Information
The following Classified Information is classified as Restricted:
• Social security number
• Bank account number
• Driver’s license number
• State identity card number
• Credit card number
• Protected health information (as defined by HIPAA)
Sharing of Restricted Information within the Employer may be permissible if necessary to meet the
Employer’s legitimate business needs. Except as otherwise required by law (or for purposes of
sharing between law enforcement entities), no Restricted Information may be disclosed to parties
outside the Employer, including contractors, without the proposed recipient’s prior written
agreement (i) to take appropriate measures to safeguard the confidentiality of the Restricted
Information; (ii) not to disclose the Restricted Information to any other party for any purpose
absent the Employer’s prior written consent or a valid court order or subpoena; and (iii) to notify
the Employer in advance of any disclosure pursuant to a court order or subpoena unless the order
or subpoena explicitly prohibits such notification. In addition, the proposed recipient must abide by
the requirements of this policy.
ii. Confidential Information
Employer Information is classified as Confidential if it falls outside the Restricted
classification, but is not intended to be shared freely within or outside the company due
to its sensitive nature and/or contractual or legal obligations. Examples of Confidential
Information include all non-Restricted Information contained in personnel files,
misconduct and law enforcement investigation records, internal financial data, donor
records, and education records (as defined by FERPA).
Sharing of Confidential Information may be permissible if necessary to meet the
Employer’s legitimate business needs. Unless disclosure is required by law (or for
purposes of sharing between law enforcement entities), when disclosing Confidential
Information to parties outside the Employer, the proposed recipient must agree (i) to
take appropriate measures to safeguard the confidentiality of the information; (ii) not to
disclose the information to any other party for any purpose absent the Employer’s prior
written consent or a valid court order or subpoena; and (iii) to notify the Employer in
advance of any disclosure pursuant to a court order or subpoena unless the order or
subpoena explicitly prohibits such notification. In addition, the proposed recipient must
abide by the requirements of this Policy.
iii. Publicly Available
Employer Information is classified as Publicly Available if it is intended to be made
available to anyone inside and outside of Executive Coaching Group.
7. Acceptable Use Policy
Employer provides employees and others with network resources and systems to support its
business requirements and functions. This section limits how you may use Employer’s information
assets and explains the steps you must take to protect them.
If you have any questions regarding acceptable use of resources, please discuss them with your
manager or contact the Information Security Coordinator for additional guidance.
a. General Use of Information Technology Resources. Employer provides network resources
and systems for business purposes. Any incidental non-business use of Employer’s
resources must be for personal purposes only. Do not use Employer’s resources for
commercial purposes, personal gain, or any purpose that may create a real or perceived
conflict of interest with Executive Coaching Group.
Do not use Employer’s resources in a manner that negatively impacts your job performance
or impairs others’ abilities to do their jobs. Employer’s network and systems are subject to
Do not use Employer’s network or systems for activities that may be deemed illegal under
applicable law. If Employer suspects illegal activities, it may report them to the appropriate
authorities and aid in any investigation or prosecution of the individuals involved.
b. Prohibited Activities. Employer prohibits using its resources to engage in activities such as
(but not limited to) the following:
i. hacking, spoofing, or launching denial of service attacks;
ii. gaining or attempting to gain unauthorized access to others’ networks or systems;
iii. sending fraudulent email messages;
iii. distributing or attempting to distribute malicious software (malware);
iv. distributing or attempting to distribute malicious software (malware);
v. spying or attempting to install spyware or other unauthorized monitoring or
vi. committing criminal acts such as terrorism, fraud, or identity theft;
vii.downloading, storing, or distributing materials in violation of another’s copyright;
viii. uploading, downloading, or disseminating defamatory, discriminatory, vilifying, sexist,
racist, abusive, rude, annoying, insulting, threatening, obscene, or otherwise
inappropriate or offensive messages or media;
ix. distributing joke, chain letter, commercial solicitations, or hoax emails or other
x. using encryption or other technologies in an attempt to hide illegal, unethical, or
otherwise inappropriate activities; and
xi. installing or distributing unlicensed or pirated software.
The Employer may block or limit access to particular services, websites, or other internetbased
functions according to risks and business value. Recognize that inappropriate or
offensive websites may still be reachable and do not access them using Employer resources.
c. General Internet Use. Limit your web browsing and access to streaming media (such as
videos, audio streams or recordings, and webcasts) to business purposes or as otherwise
permitted by this Policy. Internet use must comply with this Policy.
Never use internet peer-to-peer file sharing services, given the risks to Employer ‘s
information assets they create.
d. Email and Social Media. Do not disclose Confidential or Restricted Information to
unauthorized parties on blogs or social media or transmit it in unsecured emails or instant
Use good professional judgment when drafting and sending any communications. Remember
that messages may be forwarded or distributed outside your control, and your professional
reputation is at stake. Email signatures should be professional, appropriate for your business
role, and not long or complex.
Never open an email attachment that you did not expect to receive, click on links, or
otherwise interact with unexpected email content. Attackers frequently use these methods to
transport viruses and other malware. Be cautious, even if messages appear to come from
someone you know because attackers can easily falsify (spoof) email senders. Employer may
block some attachments or emails based on risk.
Do not respond to an email or other message that requests Confidential or Restricted
Information unless you have separately verified and are certain of its origin and purpose. Even
then, always protect Confidential or Restricted Information as described in this Policy.
If you have any doubts regarding the authenticity or risks associated with an email or other
message you receive, contact the Information Security Coordinator immediately and before
interacting with the message. Do not reply to suspicious messages, including clicking links or
making unsubscribe requests. Taking those actions may simply validate your address and lead
to more unwanted or risky messages.
e. Work from Home. Unless required for authorized business purposes, and then only in
accordance with the subsequent paragraph, Staff must not take information home with
Where information is permitted to be taken home, Staff must ensure that appropriate technical
and practical measures are in place within the home to maintain the continued security and
confidentiality of that information. In particular, all Restricted Information, Confidential
Information and other personal data must be:
i. kept in a secure and locked location, where it cannot be accessed by others
(including family members and guests); and
ii. retained and disposed of in accordance with Employer policy.
Staff must not store any Restricted or Confidential Information on their home computers or
other devices (e.g., laptops, PCs or tablets).
f. Communications and transfer of information. Staff must abide by the following when
communicating about work-related matters and when in transfer of work-related data:
i. When speaking in public places (e.g., when speaking on a mobile phone), Staff must
take care in maintaining confidentiality.
ii. Confidential Information must be marked ‘strictly private and confidential’ and
circulated only to those who need to know the information in the course of their
iii. Confidential Information must not be removed from the Employer’s offices (and
systems) unless required for required for authorized business purposes, and then only
in accordance with the subsequent paragraph.
iv. If the removal of Confidential Information from the Employer’s offices is permitted, all
reasonable steps must be taken to maintain the confidentiality and integrity of the
information. This includes, but is not limited to, Staff ensuring that Confidential
1. stored with strong password protection, with devices and files kept locked when
not in use;
2. not transported in see-through or other unsecured bags or cases, when in paper copy;
3. not read in public places when working remotely (e.g., in waiting rooms or on
4. not left unattended or in any place where it is at risk (e.g., in airports or conference
v. Care must be taken to verify all postal and email addresses before any information is
sent concerning work-related matters. Particular care must be taken when checking
and verifying email addresses where auto-complete features may have inserted
incorrect email addresses.
vi. Before sending an email, all sensitive or particularly confidential information should be
g. Office Access. All office doors, office keys and access codes must, at all times, be kept
secure. Office keys and access codes must at no time be given to or communicated to any
8. Reporting Data and Security Breaches
Applicable law may require Employer to report cyber incidents that result in the exposure or loss
of certain kinds of information or that affect certain services or infrastructure to various authorities
or affected individuals or organizations, or both. The Information Security Coordinator’s incident
response plan includes a step to review all incidents for any required notifications. Coordinate all
external notifications with Legal and the Information Security Coordinator. Do not act on your own
or make any external notifications without prior guidance and authorization. All Staff are under an
obligation to report actual or potential data protection compliance breaches to appropriate
personnel so that Employer can:
a. investigate the breach and take any necessary remedial actions;
b. maintain a register of compliance breaches; and
c. make any applicable notifications to applicable authorities
Data breaches vary widely and include physical and technical issues. Some examples of data and
security incidents that you should report include, but are not limited to:
a. loss or suspected compromise of user credentials or physical access devices (including
passwords, tokens, keys, badges, smart cards, or other means of identification and
b. suspected malware infections, including viruses, Trojans, spyware, worms, or any
anomalous reports or messages from anti-virus software or personal firewalls;
c. loss or theft of any device that contains Employer or customer/client information (other
than Public Information), including computers, laptops, tablet computers, smartphones,
USB drives, disks, or other storage media;
d. suspected entry (hacking) into Employer’s network or systems by unauthorized persons;
e. any breach or suspected breach of Confidential or Restricted Information;
f. any attempt by any person to obtain passwords or other Confidential or Restricted
Information in person or by phone, email, or other means (sometimes called social
engineering, or in the case of email, phishing); and
g. awareness of a compromised computer or other device
h. any other any situation that appears to violate this Policy or otherwise create undue risks to
Employer’s information assets.
For all reporting and questions concerning the Employer’s reporting procedure, please contact
Herma Schmitz at email@example.com and 212-245-2871.
9. Disciplinary Action
Any violation of this Policy may result in disciplinary action or other sanctions. Sanctions may
include suspension, access restrictions, work assignment limitations, or more severe penalties up to
and including termination, in accordance with applicable law. If Employer suspects illegal activities,
it may report them to the applicable authorities and aid in any investigation or prosecution of the
Executive Coaching Group
300 Herb Hill Rd
Glen Cove, New York 11542
Information Security Coordinator
Name: Herma Schmitz
Telephone number: 212-245-2871