Data retention policy
a. Information Retention
i. Retention is defined as the maintenance of information in a production
or live environment which can be accessed by an authorized user in
the ordinary course of business.
ii. Information used in the development, staging, and testing of systems
shall not be retained beyond their active use period nor copied into
production or live environments.
iii. By default, the retention period of information shall be an active use
period of exactly two years from its creation unless an exception is
obtained permitting a longer or shorter retention period. The business
unit responsible for the information must request the exception.
iv. After the active use period of information is over in accordance with
this policy and approved exceptions, information must be archived
for a defined period. Once the defined archive period is over, the
information must be destroyed.
v. Each business unit is responsible for the information it creates, uses,
stores, processes and destroys, according to the requirements of this
policy. The responsible business unit is considered to be the information owner.
vi. The organization’s legal counsel may issue a litigation hold to request
that information relating to potential or actual litigation, arbitration
or other claims, demands, disputes or regulatory action be retained
in accordance with instructions from the legal counsel.
vii. Each employee and contractor affiliated with the organization must
return information in their possession or control to the organization
upon separation and/or retirement.
viii. Information owners must enforce the retention, archiving and destruction of information, and communicate these periods to relevant
parties.
Visit link for more info: https://justdisco.securilycomply.com/JustDisco-RP.pdf Data archiving and removal policy
b. Information Archiving
i. Archiving is defined as secured storage of information such that
the information is rendered inaccessible by authorized users in the
ordinary course of business but can be retrieved by an administrator
designated by company management.
1. Physical (e.g., paper) records must be archived in secured storage
(onsite or offsite) and clearly labeled in archive boxes naming the
information owner.
2. Electronic records must be archived with strict access controls
set by the information owner and appropriate to secure the
confidentiality, integrity and accessibility of the information.
ii. The default archiving period of information shall be 7 years unless an
approved exception permits a longer or shorter period. Exceptions
must be requested by the information owner.
1. As a guideline, an archiving period of more than 7 years may be
granted for information with a vital historical purpose such as
corporate records, contracts, and technical/trade secrets.
2. As a guideline, an archiving period of less than 7 years may be
granted for information with a limited business purpose such as
email, travel itineraries, pre-trip advisories, or to comply with
specific legal, contractual and/or regulatory requirements (e.g.,
PCI DSS, GDPR, etc.)
iii. Information must be destroyed (defined below) at the end of the
elapsed archiving period.
c. Information Destruction
i. Destruction is defined as the physical or technical destruction sufficient
to render the information contained in the document irretrievable by
ordinary commercially-available means.
ii. The organization must maintain and enforce a detailed list of approved
destruction methods appropriate for each type of information archived,
whether in physical storage media such as CD-ROMs, DVDs, backup
tapes, hard drives, mobile devices, portable drives or in database
records or backup files. Physical information in paper form must
be shredded using an authorized shredding device; waste must be
periodically removed by approved personnel.
Visit link for more info: https://justdisco.securilycomply.com/JustDisco-RP.pdf Data storage policy
a. The following locations are classified by the organization as secure areas
and are goverened by this policy:
i. [list all data center locations and secure areas under the organization’s
control]
b. Each data center and secure area must have a manager assigned. The
manager’s name must be documented in the organization’s records. In the
case of any on-prem data centers, the manager’s name must also be posted
in and near the secure area.
c. Each secure area must be clearly marked. Access to the secure area must
be controlled by at least a locked door. A visitor access log must be clearly
marked and easily accessible just inside the door.
d. Persons who are not employed by the organization are considered to be
visitors. Visitors accessing secure areas shall:
i. Obtain access to secure areas in accordance with reference a.
ii. Only enter and remain in secure areas when escorted by a designated
employee. The employee must stay with the visitor during their entire
stay inside the secure area.
iii. Log the precise time of entry and exit in the visitor access log.
e. The following activities are prohibited inside secure areas:
i. Photography, or video or audio recordings of any kind.
ii. Connection of any electrical device to a power supply, unless specifically authorized by the responsible person.
iii. Unauthorized usage of or tampering with any installed equipment.
iv. Connection of any device to the network, unless specifically authorized
by the responsible person.
v. Storage or archival of large amounts of paper materials.
vi. Storage of flammable materials or equipment.
vii. Use of portable heating devices.
viii. Smoking, eating, or drinking.
f. Secure areas must be checked for compliance with security and safety
requirements on at least a quarterly basis.
Visit link for more info: https://justdisco.securilycomply.com/JustDisco-DP.pdf Data center location(s)
United States
Data hosting details
Our infrastructure spans over multiple availability zones in the AWS us-west-2 region, AWS availability zones (AZ) are one or more discrete data centers with redundant power, networking, and connectivity within an AWS Region.
App/service has sub-processors
yes
Guidelines for sub-processors