Information Security and Data Protection Policy

The Board of Directors and management of Base Creative, located at Aldgate Tower, London, which operates in the digital marketing space, are committed to preserving the confidentiality, integrity and availability of all the physical and electronic information assets throughout their organisation in order to preserve its competitive edge, cashflow, profitability, legal, regulatory and contractual compliance and commercial image. Information and information security requirements will continue to be aligned with Base Creative’s goals and the information security management system (ISMS) is intended to be an enabling mechanism for information sharing, for electronic operations and for reducing information-related risks to acceptable levels.

Base Creative’s current strategic business plan and risk management framework provide the context for identifying, assessing, evaluating and controlling information-related risks through the establishment and maintenance of an ISMS. The Risk Assessment, Statement of Applicability and Risk Treatment Plan identify how information-related risks are controlled. Head of Risk is responsible for the management and maintenance of the risk treatment plan. Additional risk assessments may, where necessary, be carried out to determine appropriate controls for specific risks. 

In particular, business continuity and contingency plans, data backup procedures, avoidance of viruses and hackers, access control to systems and information security incident reporting are fundamental to this policy. Control objectives for each of these areas are documented and are supported by specific documented policies and procedures. 

Base Creative aims to achieve specific, defined information security objectives, which are developed in accordance with the business objectives, the context of the organisation, the results of risk assessments and the risk treatment plan.

All Employees/Staff of Base Creative and any third party contractors are expected to comply with this policy and with the ISMS that implements this policy. All Employees/Staff, and certain external parties, receive appropriate training. The consequences of breaching the information security policy are set out in the disciplinary policy and in contracts and agreements with third parties.  

The ISMS is subject to continuous, systematic review and improvement. 

Base Creative has appointed a top level data protection officer to support the ISMS framework and to periodically review the security policy.

This policy will be reviewed to respond to any changes in the risk assessment or risk treatment plan and at least annually.  

In this policy, ‘information security’ is defined as:

Preserving

This means that management, all full time or part time Employees/Staff, sub-contractors, project consultants and any external parties have, and will be made aware of, their responsibilities (which are defined in their job descriptions or contracts) to preserve information security, to report security breaches and to act in accordance with the requirements of the ISMS. All Employees/Staff will receive information security awareness training and more specialised Employees/Staff will receive appropriately specialised information security training.

the availability,

This means that information and associated assets should be accessible to authorised users when required and therefore physically secure. The computer network will be resilient and Base Creative will be able to detect and respond rapidly to incidents (such as viruses and other malware) that threaten the continued availability of assets, systems and information. There are appropriate business continuity plans. 

confidentiality,

This involves ensuring that information is only accessible to those authorised to access it and therefore to preventing both deliberate and accidental unauthorised access to Base Creative’s information and proprietary knowledge and its systems, including its networks and websites.

and integrity

This involves safeguarding the accuracy and completeness of information and processing methods, and therefore requires preventing deliberate or accidental, partial or complete, destruction or unauthorised modification, of either physical assets or electronic data. There is an appropriate contingency and data backup plans and security incident reporting. Base Creative complies with all relevant data-related legislation in those jurisdictions within which it operates. 

of the physical (assets)

The physical assets of Base Creative including, but not limited to, computer hardware, data cabling, telephone systems, filing systems and physical data files.  

and information assets

The information assets include information printed or written on paper, transmitted by post or shown in films, or spoken in conversation, as well as information stored electronically on servers, website(s), extranet(s), intranet(s), PCs, laptops, mobile phones and PDAs, as well as on CD ROMs, floppy disks, USB sticks, backup tapes and any other digital or magnetic media, and information transmitted electronically by any means. In this context, ‘data’ also includes the sets of instructions that tell the systems how to manipulate information (i.e. the software: operating systems, applications, utilities, etc).

of Base Creative.

Base Creative and such partners that are part of our integrated network and have signed up to our security policy and have accepted our ISMS.

A SECURITY BREACH is any incident or activity that causes, or may cause, a breakdown in the availability, confidentiality or integrity of the physical or electronic information assets of Base Creative.