Cyber Security Policy

Fresh Bread Investments LLC’s cyber security policy outlines our guidelines for preserving the security of our data and technology infrastructure. Human errors, hacker attacks, and system malfunctions can cause great financial damage and may jeopardize our company’s reputation. For this reason and for the overall protection of our customers, we have implemented several security measures. We have also prepared instructions that may help mitigate security risks. We have outlined both provisions in this policy.

Scope

This policy applies to all our employees, contractors, volunteers, and anyone who has permanent or temporary access to our systems and hardware.

Policy elements

Confidential data

Confidential data is secret and valuable. Common examples are:

Unpublished financial information

Data of customers/partners/vendors

Patents, formulas, or new technologies

Customer lists (existing and prospective)

All employees are obliged to protect this data. In this policy, we will give our employees instructions on how to avoid security breaches.

Devices

When employees use their digital devices to access company emails or accounts, they introduce security risks to our data. We advise our employees to keep both their personal and company-issued computers, tablet, and cell phone secure. They can do this if they:

Keep all devices password protected.

Choose and upgrade a complete antivirus software.

Ensure they do not leave their devices exposed or unattended.

Install security updates of browsers and systems monthly or as soon as updates are available.

Log into company accounts and systems through secure and private networks only.

We also advise our employees to avoid accessing internal systems and accounts from other people’s devices or lending their own devices to others.

When new hires receive company-issued equipment they will receive instructions for:

Disk encryption setup

Password management tool setup

installation of antivirus/ anti-malware software

They should follow instructions to protect their devices and refer to our Compliance Officer if they have any questions.

Keep emails safe

Emails often host scams and malicious software (e.g. worms.) To avoid virus infection or data theft, we instruct employees to:

Avoid opening attachments and clicking on links when the content is not adequately explained (e.g. “watch this video, it’s amazing.”)

Be suspicious of clickbait titles (e.g. offering prizes, advice.)

Check email and names of people they received a message from to ensure they are legitimate.

Look for inconsistencies or giveaways (e.g. grammar mistakes, capital letters, an excessive number of exclamation marks.)

If an employee isn’t sure that an email they received is safe, they can refer to our Compliance Officer.

Password Management

Password leaks are dangerous since they can compromise our entire infrastructure. Not only should passwords be secure so they won’t be easily hacked, but they should also remain secret. For this reason, we advise our employees to:

Choose passwords with at least eight characters (including capital and lower-case letters, numbers and symbols) and avoid information that can be easily guessed (e.g. birthdays.)

Remember passwords instead of writing them down. If employees need to write their passwords, they are obliged to keep the paper or digital document confidential and destroy it when their work is done.

Exchange credentials only when necessary. When exchanging them in-person isn’t possible, employees should prefer the phone instead of email, and only if they personally recognize the person they are talking to.

Change their passwords every two months.

Remembering many passwords can be daunting. We will purchase the services of a password management tool that generates and stores passwords. Employees are obliged to create a secure password for the tool itself, following the abovementioned advice.

Transfer data securely

Transferring data introduces a security risk. Employees must:

Avoid transferring sensitive data (e.g. customer information, employee records) to other devices or accounts unless absolutely necessary. When the mass transfer of such data is needed, we request employees to ask our [Security Specialists] for help.

Share confidential data over the company network/ system and not over public Wi-Fi or private connection.

Ensure that the recipients of the data are properly authorized people or organizations and have adequate security policies.

Report scams, privacy breaches and hacking attempts

Our Compliance Officer needs to know about scams, breaches, and malware so they can better protect our infrastructure. For this reason, we advise our employees to report perceived attacks, suspicious emails, or phishing attempts as soon as possible to our specialists

Additional measures

To reduce the likelihood of security breaches, we also instruct our employees to:

Turn off their screens and lock their devices when leaving their desks.

Report stolen or damaged equipment as soon as possible to Compliance.

Change all account passwords at once when a device is stolen.

Report a perceived threat or possible security weakness in company systems.

Refrain from downloading suspicious, unauthorized, or illegal software on their company equipment.

Avoid accessing suspicious websites.

Remote employees

Remote Employees must follow this policy’s instructions too. Since they will be accessing our company’s accounts and systems from a distance, they are obliged to follow all data encryption, protection standards, and settings, and ensure their private network is secure.

Disciplinary Action

We expect all our employees to always follow this policy and those who cause security breaches may face disciplinary action:

First-time, unintentional, small-scale security breach: We may issue a verbal warning and train the employee on security.

Intentional, repeated or large-scale breaches (which cause severe financial or other damage): We will invoke more severe disciplinary action up to and including termination.
We will examine each incident on a case-by-case basis.

Additionally, employees who are observed to disregard our security instructions will face the possibility of termination, even if their behavior hasn’t resulted in a security breach.

Take security seriously

Everyone, from our customers and partners to our employees and contractors, should feel that their data is safe. The only way to gain their trust is to proactively protect our systems and databases. We can all contribute to this by being vigilant and keeping cyber security top of mind.