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GDPR > Acceptable Use Policy

Last updated: 21 November 2023 at 11:10:33 UTC by Russell Briggs

  1. Introduction

 

The Acceptable Use Policy sets out the policies and procedures of Recycly Ltd (the "company") regarding a set of rules applied by the owner, creator or administrator of a network, website, or service that restrict the ways in which the network, website or system may be used and sets guidelines as to how it should be used. The company’s intentions for publishing an Acceptable Use Policy are not to impose restrictions that are contrary to the company’s established culture of openness, trust and integrity. The company is committed to protecting Recycly Ltd'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, WWW browsing, and FTP, are the property of the company. These systems are to be used for business purposes in serving the interests of the company and 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 employee and affiliate who deals with information and/or information systems. It is the responsibility of every employee and contractor to know these guidelines and to conduct their activities accordingly.

 

The purpose of the policy is to ensure that users understand their responsibility for the appropriate use of the company’s information technology resources. Understanding this will help users to protect themselves and the company’s equipment, information and reputation. Inappropriate use exposes the company to risks including virus attacks, compromise of network systems and services and legal issues.

 

  1. Scope

 

This policy applies to the use of information, electronic and computing devices, and network resources to conduct the company’s business or interact with internal networks and business systems, whether owned or leased by the company, the employee, or a third party. All employees, contractors, consultants, temporary, and other workers at Recycly Ltd and its subsidiaries are responsible for exercising good judgment regarding appropriate use of information, electronic devices, and network resources in accordance with the company policies and standards, and local laws and regulation. Exceptions to this policy are documented in section 5.2

 

This policy applies to employees, contractors, consultants, temporaries, and other workers at Recycly Ltd, including all personnel affiliated with third parties. This policy applies to all equipment that is owned or leased by the company.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

  1. Policy

 

    1. General Principles

 

      • The company’s proprietary information stored on electronic and computing devices whether owned or leased by the company, the employee or a third party, remains the sole property of the company.  You must ensure through legal or technical means that proprietary information is protected in accordance with GDPR.

 

      • All employee has a responsibility to promptly report the theft, loss or unauthorized disclosure of the company’s proprietary information.

 

      • Employees may access, use or share the company’s proprietary information only to the extent it is authorized and necessary to fulfil their assigned job duties.

 

      • Employees are responsible for exercising good judgment regarding the reasonableness of personal use and should be guided by company policies on personal use, and if there is any uncertainty, employees should consult their supervisor or manager.

 

      • For security and network maintenance purposes, authorized individuals within the company may monitor equipment, systems and network traffic at any time, both business and personal use will be monitored as appropriate.

 

      • The company reserves the right to audit networks and systems on a periodic basis to ensure compliance with this policy.

 

      • All employees should immediately report any breach of this Acceptable Use Policy to their line manager and comply with official procedures when a breach of the policy is suspected or reported.

 

    1. Security and Proprietary Information

 

      • All mobile and computing devices that connect to the internal network must comply with the Information Security Policy.
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      • System-level and user-level passwords must comply with the Password Policy. Providing access to another individual, either deliberately or through failure to secure its access is strictly prohibited.
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      • All devices must be secured with a password or switched off when the device is unattended.
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      • Postings on any online platform by employees or contractors from a company’s email address is strictly forbidden.
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      • Employees and contractors must use extreme caution when opening email attachments received from unknown senders, which may contain malware.

 

 

 

 

 

 

  1. Unacceptable Use

 

The following activities are in general prohibited. Employees and contractors may be exempted from these restrictions during the course of their legitimate job responsibilities (e.g., systems administration staff may have a need to disable the network access of a host if that host is disrupting production services).

 

Under no circumstances is an employee or contractor of the company authorized to engage in any activity that is illegal under local or international law while utilizing the company-owned resources.

 

The lists below are by no means exhaustive but attempt to provide a framework for activities which fall into the category of unacceptable use.

 

  1. System and Network Activities

 

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 the company.

 

  • 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 the company or the end-user does not have an active license is strictly prohibited.

 

  • Accessing data, a server or an account for any purpose other than conducting the company’s business, even if the employee or contractor have authorized access is prohibited.

 

  • Trade or canvass support for any organisation on official premises, whether it is for personal gain from any type of transaction or on behalf of external bodies.

 

  • Trade or canvass support for any organisation on official premises, whether it is for personal gain from any type of transaction or on behalf of external bodies.

 

  • Send messages or material that solicit or promote religious, political or other non-business related causes.

 

  • Provide unauthorised views or commitments that could appear to be on behalf of the company.

 

  • Undertake any form of gaming, lottery or betting.

 

  • Use any type of applications and/or devices to circumvent management or security controls.

 

  • Download music, video or other media-related files for non-business purposes or store such files on network drives.

 

  • Exporting software, technical information, encryption software or technology, in violation of international or regional export control laws is illegal. The appropriate management should be consulted prior to the export of any material that is in question.

 

  • Introduction of malicious programs into the network or server (e.g., viruses, worms, Trojan horses, e-mail bombs, etc.).

 

  • Revealing any employee account password to others or allowing the use of their account by others. This includes family and other household members when work is being done at home.

 

  • Using the company’s devices to actively engage in procuring or transmitting material that is in violation of sexual harassment or hostile workplace laws in the user's local jurisdiction.

 

  • Making fraudulent offers of products, items or services originating from any company 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 or contractor is not an intended recipient or logging into a server or account that the employee or contractor 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 company 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 company’s 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 terminal session, via any means, locally or via the Internet/Intranet/Extranet.

 

  • Providing information about or lists of the company’s employees to parties outside the company.

 

  1. Email and Communication Activities

 

When using company resources to access and use the Internet, users must represent the company responsibly. Whenever employees state affiliation with the company, they must also clearly indicate that "the opinions expressed are my own and not necessarily those of the company". Questions may be addressed to the management of the company.

 

 

 

 

 

 

 

 

 

 

Employees and contractors should follow the following guidelines:

 

  • Comply with the company’s email policy

 

  • Prohibited to send unsolicited email messages, including the sending of "junk mail" or other advertising material to individuals who did not specifically request such material (email spam).

 

  • Only use appropriate language in messages, emails, voicemails and recordings. Threatening, derogatory, abusive, indecent, obscene, racist, sexist or otherwise offensive content will not be tolerated.

 

  • Unauthorized use or forging of email header information is not accepted.

 

  • 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 is prohibited

 

  • Employees and contractors should not alter the content of a third party’s message when forwarding it unless authorised.

 

  • Creating or forwarding "chain letters", "Ponzi" or other "pyramid" schemes of any are not allowed.

 

  • Employees and contractors are not permitted to send unsolicited email originating from within the company's networks of other Internet/Intranet/Extranet service providers on behalf of or to advertise any service hosted by the company or connected via the company's network.

 

  • Employees and contractors should be vigilant to phishing emails and know how to spot and report suspicious emails.

 

  • Posting the same or similar non-business-related messages to large numbers of newsgroups (newsgroup spam) is not accepted as it is not in line with the company’s policy.

 

  1. Blogging, Social Media and Websites

 

  • Blogging by employees and contractors, whether using the company’s devices and systems or personal devices is also subject to the terms and restrictions set forth in this Policy. Use of the company’s devices to engage in blogging is not acceptable unless it is for the company’s marketing activity and provided that it is done in a professional and responsible manner, does not otherwise violate the company’s policy, is not detrimental to the company’s best interests. Blogging from the company’s devices is also subject to monitoring.

 

  • The company’s Information Security Policy also applies to blogging. As such employees and contractors are prohibited from revealing any confidential or proprietary information, trade secrets.

 

  • Employees and contractors shall not engage in any blogging that may harm or tarnish the image, reputation and/or goodwill of the company and/or any of its employees. Employees and contractors are also prohibited from making any discriminatory, disparaging, defamatory or harassing comments when blogging or otherwise engaging in any conduct.

 

 

 

 

  • Employees and contractors may also not attribute personal statements, opinions or beliefs to the company when engaged in blogging. If an employee is expressing his or her beliefs and/or opinions in blogs, the employee or contractor may not, expressly or implicitly, represent themselves as an employee or representative of the company. Employees and contractors assume any and all risk associated with blogging.
  • Apart from following all laws pertaining to the handling and disclosure of copyrighted or export controlled materials the company’s trademarks, logos and any other intellectual property belongs to the company may also not be used in connection with any blogging activity.

 

  • Employees and contractors should not share information including anything that is sensitive/personal information on online forums, blogs or social networking sites and only use approved company social media accounts for official business and where appropriate. Employees and contractors should be aware that their social media content may be available for anyone to see, indexed by Google and archived for posterity.

 

  • Employees and contractors are not allowed to use their social media accounts on any of the company’s devices.

 

  • Employees and contractors are not allowed to post reviews about the company or discuss their salary on employment/salary review sites i.e Glassdoor, Indeed, etc.

 

  1. Devices, systems and networks

 

  • Employees and contractors are only allowed to use systems, applications, software and devices which are approved, procured and configuration managed by the company when undertaking official business, and apply the company’s standards and guidance in their use. Also only use approved devices connected to the company’s network(s), including approved USBs, when undertaking official business.

 

  • Employees and contractors are not allowed to connect personal mobile devices by USB cable to the company’s devices connected to the company’s infrastructure, for the purpose of uploading/ downloading files or charging.

 

  • The company permits connecting the company’s devices by Wi-Fi (or Ethernet) to the internet to connect back to the department from anywhere e.g. home or a hotel. However, the devices must not be connected to the internet via VPN connection, for security reasons. 

 

  • The company permits wirelessly connecting a company device to a company, or personal, mobile phone via a personal hotspot for the purpose of acquiring an internet connection (tethering) for work purposes. Tethering a personal mobile phone is permissible, but the company cannot be held liable for this use of a personal mobile phone including any data charges, and so any use of a personal phone for this purpose is the individual’s choice.

 

  • No official information should be stored on devices without the company’s security controls.

 

  • Any personal wallpapers or screensavers are prohibited.

 

  • Employees and contractors should raise all software requests through the company’s management and seek exceptions to security policies by applying for an Exception.

 

  • Employees and contractors travelling outside their contracted locations on official business and wishing to take the company’s devices with them must request permission to take their devices from the management before they travel. 

 

  • Company’s devices, including smartphones, must only be taken outside the contracted locations when required for official business and approved the management. The company may prohibit the carrying and use of the company’s devices in certain countries.

 

  • Employees and contractors are required to contact the management before travelling to certain countries, whether this is on official business or for a personal visit.

 

  • Employees and contractors are responsible for keeping all portable devices assigned to them safe and secure and immediately report any loss or damage of their equipment to the management. Protect all company equipment appropriately when travelling e.g. laptops must always be carried as hand luggage and never leave a portable device in sight in the parked vehicle.

  1. Policy compliance

The company will verify compliance with this policy through various methods, including but not limited to, business tool reports, internal and external audits and feedback to the policy owner.

 

Any exception to the policy must be approved by the management in advance.

 

The company is responsible for ensuring that the employees and contractors understand their responsibilities and consequences as defined in this policy and continue to meet its requirements for the duration of their employment with the company. The company are also responsible for monitoring employees’ ability to perform assigned security responsibilities. However, this does not remove responsibility from employees, they are responsible for ensuring that they too understand their responsibilities as defined in this policy and continue to meet the requirements. It is the company’s responsibility to take appropriate action if individuals fail to comply with this policy.

 

 If an employee or contractor found to have violated this policy may be subject to disciplinary procedures (including criminal prosecution) which could lead to dismissal or the termination of the contract.

 

  1. Approval and review details

 

This policy must be reviewed and updated annually.

 

The following matters must be considered as pan of each review of this policy:

 

  • changes to the legal and regulatory environment;

 

  • changes to any codes of conduct to which the company subscribes;

 

  • developments in industry best practice;

 

  • any new data collected by the company;

 

  • any new data processing activities are undertaken by the company, and

 

  • any security incidents affecting the company.