Information security policy

Company policy template, built out as an information security policy

A company policy template needs a document control block, a purpose and scope, numbered rules people can be held to, a table of who does what, and the consequences of a breach. This example shows that structure filled in as one complete policy: Talbot & Vance, a professional services firm, publishes its information security policy as version 3.1, owned and approved by the Chief Operating Officer and due for review in August 2027. Twelve numbered clauses run from acceptable use to compliance across 15 pages, with a four level classification table, a 30 minute incident reporting rule and a responsibilities table by role.

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Policy document

Information security policy

Talbot & Vance

Version 3.1 | Effective 5 August 2026
Talbot & Vance · Information security policy
Talbot & Vance · Information security policy
Talbot & Vance · Information security policy
Talbot & Vance · Information security policy
Talbot & Vance · Information security policy
Talbot & Vance · Information security policy
Talbot & Vance · Information security policy
Talbot & Vance · Information security policy
Talbot & Vance · Information security policy
Talbot & Vance · Information security policy
Talbot & Vance · Information security policy
Talbot & Vance · Information security policy
Talbot & Vance · Information security policy
Talbot & Vance · Information security policy
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Contents
Introduction
2
Acceptable use
3
Access control and passwords
4
Multi-factor authentication
5
Device and endpoint security
6
Email and phishing
7
Data classification and handling
8
Remote and home working
9
Third party and supplier access
10
Incident reporting
11
Breach notification
12
Roles and responsibilities
14
Compliance and consequences
14
Related documents
15
Introduction
Version
3.1
Owner
Chief Operating Officer
Approver
Chief Operating Officer
Approval date
5 August 2026
Next review
August 2027
Classification
Internal

Purpose. This policy establishes the framework for protecting the confidentiality, integrity, and availability of information assets owned by or entrusted to Talbot & Vance. Its objective is to mitigate security risks, prevent data breaches, and ensure compliance with legal, regulatory, and contractual obligations, including the Australian Privacy Act 1988.

Scope. This policy applies to all Talbot & Vance personnel, including permanent, part-time, and temporary employees, as well as contractors, consultants, and any third parties granted access to the firm's information systems and data. All individuals and entities within this scope are required to comply with this policy.

1.
Acceptable use
This section defines the acceptable use of all information technology systems, resources, and data owned or managed by Talbot & Vance, including but not limited to computers, mobile devices, software, networks, and cloud services ("Systems"). All Systems are the property of Talbot & Vance and are provided for business purposes. Use of these Systems is a privilege, and all personnel are expected to act responsibly, ethically, and professionally.
1.1
Prohibited use
The use of Talbot & Vance Systems for any of the following activities is strictly prohibited:
Any activity that is illegal or fraudulent under Australian Commonwealth, state, or territory law.
The creation, transmission, or storage of material that is defamatory, harassing, discriminatory, obscene, or could contribute to a hostile work environment.
The intentional circumvention of security controls, including the use of unauthorised tools to bypass firewalls or access restricted data.
Any activity that degrades the performance of the network, damages equipment, or intentionally introduces malicious software (malware).
Violation of intellectual property rights, including the unauthorised copying, distribution, or use of copyrighted material, trademarks, or licensed software.
Conducting personal commercial business, for-profit activities, or extensive political campaigning.
1.2
Incidental personal use
Limited and occasional personal use of Talbot & Vance Systems is permitted, provided it is brief, occurs during personal time (e.g., lunch breaks), does not interfere with work responsibilities, does not consume significant resources, does not incur additional cost for the firm, and does not violate any other provision of this policy. Personnel should have no expectation of privacy in their use of company Systems, as all activity may be monitored and logged for security and operational purposes.
1.2
Incidental personal use
Limited and occasional personal use of Talbot & Vance Systems is permitted, provided it is brief, occurs during personal time (e.g., lunch breaks), does not interfere with work responsibilities, does not consume significant resources, does not incur additional cost for the firm, and does not violate any other provision of this policy. Personnel should have no expectation of privacy in their use of company Systems, as all activity may be monitored and logged for security and operational purposes.
1.2
Incidental personal use
Limited and occasional personal use of Talbot & Vance Systems is permitted, provided it is brief, occurs during personal time (e.g., lunch breaks), does not interfere with work responsibilities, does not consume significant resources, does not incur additional cost for the firm, and does not violate any other provision of this policy. Personnel should have no expectation of privacy in their use of company Systems, as all activity may be monitored and logged for security and operational purposes.
1.3
Unauthorised software and services
Personnel are prohibited from installing, downloading, or using any software, applications, browser extensions, or cloud-based services on company devices or networks that have not been explicitly approved by the IT department. All software must be centrally managed and deployed to ensure it is properly licensed, configured, and secured. The use of unauthorised 'shadow IT' services poses a significant risk to data security and is strictly forbidden.
2.
Access control and passwords
Access to Talbot & Vance's information systems, applications, and data is managed based on the principle of least privilege. This means personnel are granted only the minimum level of access necessary to perform their job responsibilities. Access rights are reviewed periodically to ensure they remain appropriate.
2.1
User accounts
All personnel, including employees, contractors, and temporary staff, will be issued a unique user account for accessing company systems. This account must not be shared with any other person, internal or external. All actions performed under a user account are deemed to be the actions of the individual to whom the account is assigned.
2.2
Password management
Passwords are a critical component of securing user accounts. All personnel are responsible for creating and maintaining strong, confidential passwords for their accounts. Passwords must never be written down, stored in an unsecured location, or shared via email, instant messaging, or other unencrypted means. All passwords must meet the following minimum requirements:
Have a minimum length of 14 characters.
Contain a mix of character types: uppercase letters, lowercase letters, numbers, and symbols (e.g., !@#$%^&*).
Not be based on personal information (e.g., names, dates of birth), dictionary words, or common patterns.
Be changed immediately if there is any suspicion of compromise.
Not be reused across different systems or services, especially personal services.
2.3
Access lifecycle management
Access rights are managed throughout a user's tenure with the firm. Provisioning. Access is granted to new personnel based on their role and responsibilities, following a formal approval process managed by their line manager and the IT department. Requests for additional access must be justified by a business need and formally approved. De-provisioning. All access rights to Talbot & Vance systems will be revoked promptly upon termination of employment or contract. Access rights will also be reviewed and adjusted when personnel change roles within the firm to ensure alignment with the principle of least privilege.
3.
Multi-factor authentication
Talbot & Vance requires the use of Multi-Factor Authentication (MFA) to provide an additional layer of security for accessing company systems and data. MFA combines two or more independent credentials: what the user knows (password), what the user has (security token), and what the user is (biometric verification). This clause outlines the requirements for its use.
3.1
Mandatory use of MFA
MFA must be enabled and used in the following circumstances:
All remote access to the Talbot & Vance corporate network, including via Virtual Private Network (VPN) services.
All company-managed cloud services, applications, and platforms that store, process, or transmit data classified as 'Confidential' or 'Restricted'.
Access to privileged or administrative accounts on any company system.
3.2
Approved authentication methods
The following methods are approved for use as a second factor of authentication. Staff must use one of these methods when prompted.
An approved authenticator application installed on a company-issued or personal mobile device (e.g., Microsoft Authenticator).
A company-issued physical hardware security token (e.g., YubiKey), where provided for specific roles.
SMS or voice call codes sent to a registered mobile number, only where other methods are not available.
3.3
User responsibility
Authentication factors are assigned to an individual and must not be shared. Users are responsible for the security of their assigned MFA devices and credentials. Any loss, theft, or suspected compromise of an MFA device or credential must be reported to the IT Security team immediately.
4.
Device and endpoint security
This section applies to all endpoint devices used to access, store, or process Talbot & Vance information or connect to the firm's network. This includes, but is not limited to, company-issued and personal desktops, laptops, tablets, and mobile phones (under the Bring Your Own Device or 'BYOD' model). All such devices must be registered with the IT Department and are subject to the security controls outlined below.
4.1
Anti-malware protection
All computers (desktops and laptops) must have the firm's approved anti-malware software installed and running at all times. The software must be configured to automatically update its definition files and perform regular system scans. Tampering with, disabling, or uninstalling this software is strictly prohibited.
4.2
Full-disk encryption
To protect data in the event of device loss or theft, full-disk encryption must be enabled on all company-issued and personal laptops and mobile devices that store or access company data. Approved encryption technologies include BitLocker for Windows and FileVault for macOS. The recovery key for encrypted devices must be securely stored by the IT Department.
4.3
Screen locking
All devices must be configured to automatically lock the screen after a maximum of 15 minutes of inactivity. Resuming a session must require re-authentication using a password, PIN, or approved biometric identifier (e.g., fingerprint or facial recognition). Staff must manually lock their devices when leaving them unattended.
4.4
Device management
All devices must be enrolled in Talbot & Vance's endpoint management solution (e.g., Mobile Device Management or 'MDM'). This allows the IT Department to enforce security policies, deploy software, and, if necessary, remotely wipe company data from a device that is lost, stolen, or no longer authorised for use.
4.5
Personal devices (BYOD)
Staff using personal devices to access company resources must ensure their device complies with all requirements of this section. By connecting a personal device to company resources, staff consent to the installation of management software and acknowledge that the IT Department has the authority to remotely remove company data from the device, which may in some cases require a full factory reset of the device.
5.
Email and phishing
Company email is a critical business tool and a primary channel for client communication. However, it is also a common vector for cyber-attacks, including phishing and malware distribution. All personnel must adhere to the following rules to protect the firm's information assets and systems.
5.1
Secure use of email
All email activity on Talbot & Vance systems is subject to monitoring. Use of the company email system constitutes consent to this monitoring. Personnel must:
• Use their assigned company email account for all business-related correspondence. Personal email services must not be used to conduct firm business.
• Exercise professional judgment and care in all email communications, as they may constitute official records.
• Not send information classified as 'Confidential' or 'Restricted' to external recipients via unencrypted email. The firm's approved secure file transfer solution must be used for all such transfers.
5.2
Phishing and suspicious emails
Phishing is a fraudulent attempt to obtain sensitive information such as usernames, passwords, and financial details by disguising as a trustworthy entity in an electronic communication. Personnel must be vigilant in identifying potential phishing attempts. Common indicators include:
Unexpected or unusual senders, or emails from known contacts that seem out of character.
Urgent or threatening language demanding immediate action.
Requests for personal information, login credentials, or financial details.
Poor grammar, spelling mistakes, or unprofessional formatting.
Suspicious links that do not match the expected destination, or unexpected attachments.
How to report suspicious emails
If you receive an email you suspect is a phishing attempt or is otherwise malicious, do not click any links, open attachments, or reply. Report it immediately to the IT Security team by using the 'Report Phishing' button in Outlook or by forwarding the email as an attachment to security@talbotvance.com.au.
5.3
Forwarding and external sending
To prevent the unauthorised exfiltration of company data and to maintain the integrity of our information boundaries, the following rules apply:
• Automatic forwarding of emails from a company account to any external email address (e.g., Gmail, Outlook.com, personal ISP accounts) is strictly prohibited.
• Manual forwarding of sensitive information to external parties must be done in accordance with the Data Classification and Handling section of this policy and must use approved, secure methods.
6.
Data classification and handling
All Talbot & Vance information and data assets are classified to ensure they receive a level of protection commensurate with their sensitivity, value, and criticality to the firm and its clients. All personnel are responsible for understanding and correctly applying these classifications to the information they create, handle, and store. The classification level dictates the minimum security controls required for storage, access, transmission, and disposal.
Classification level
Examples
Storage and access rules
Sharing and transmission rules
Public
Marketing materials, press releases, public website content, published articles.
No access restrictions. May be stored on public-facing systems.
Approved for public distribution. No restrictions on sharing.
Internal
Internal policies and procedures, staff directory, general business communications, operational documents.
Stored on internal firm systems (e.g., SharePoint, network drives). Access is generally available to all personnel.
May be shared freely within the firm. Must not be shared externally without specific authorisation.
Confidential
Client data not otherwise marked Restricted, financial reports, employee records, contracts, business plans.
Stored on access-controlled systems with logging. Access is granted on a 'need-to-know' basis.
External sharing requires authorisation and a Non-Disclosure Agreement where appropriate. Must be encrypted when transmitted electronically outside the firm's network.
Restricted
Highly sensitive client data (e.g., merger and acquisition details), intellectual property, litigation strategy, system credentials, data subject to specific legal or regulatory protection.
Stored in highly secured, encrypted environments with strict access controls and monitoring. Access is limited to named individuals approved by a Partner or the COO.
Sharing is prohibited without explicit approval from a Partner or the COO. All transmission must use end-to-end encrypted, approved channels.
Classification level
Examples
Storage and access rules
Sharing and transmission rules
Public
Marketing materials, press releases, public website content, published articles.
No access restrictions. May be stored on public-facing systems.
Approved for public distribution. No restrictions on sharing.
Internal
Internal policies and procedures, staff directory, general business communications, operational documents.
Stored on internal firm systems (e.g., SharePoint, network drives). Access is generally available to all personnel.
May be shared freely within the firm. Must not be shared externally without specific authorisation.
Confidential
Client data not otherwise marked Restricted, financial reports, employee records, contracts, business plans.
Stored on access-controlled systems with logging. Access is granted on a 'need-to-know' basis.
External sharing requires authorisation and a Non-Disclosure Agreement where appropriate. Must be encrypted when transmitted electronically outside the firm's network.
Restricted
Highly sensitive client data (e.g., merger and acquisition details), intellectual property, litigation strategy, system credentials, data subject to specific legal or regulatory protection.
Stored in highly secured, encrypted environments with strict access controls and monitoring. Access is limited to named individuals approved by a Partner or the COO.
Sharing is prohibited without explicit approval from a Partner or the COO. All transmission must use end-to-end encrypted, approved channels.
Classification level
Examples
Storage and access rules
Sharing and transmission rules
Public
Marketing materials, press releases, public website content, published articles.
No access restrictions. May be stored on public-facing systems.
Approved for public distribution. No restrictions on sharing.
Internal
Internal policies and procedures, staff directory, general business communications, operational documents.
Stored on internal firm systems (e.g., SharePoint, network drives). Access is generally available to all personnel.
May be shared freely within the firm. Must not be shared externally without specific authorisation.
Confidential
Client data not otherwise marked Restricted, financial reports, employee records, contracts, business plans.
Stored on access-controlled systems with logging. Access is granted on a 'need-to-know' basis.
External sharing requires authorisation and a Non-Disclosure Agreement where appropriate. Must be encrypted when transmitted electronically outside the firm's network.
Restricted
Highly sensitive client data (e.g., merger and acquisition details), intellectual property, litigation strategy, system credentials, data subject to specific legal or regulatory protection.
Stored in highly secured, encrypted environments with strict access controls and monitoring. Access is limited to named individuals approved by a Partner or the COO.
Sharing is prohibited without explicit approval from a Partner or the COO. All transmission must use end-to-end encrypted, approved channels.
6.1
Data handling requirements
Personnel must handle all data in accordance with its classification. This includes, but is not limited to: • Applying appropriate classification labels to documents, emails, and other data assets containing Confidential or Restricted information. • Not leaving sensitive information visible on screens, in unsecured locations, or on shared printers (clear desk and clear screen). • Securely disposing of physical and digital media containing sensitive information using approved methods. • Reporting any suspected misclassification or mishandling of data immediately to the Security Team.
7.
Remote and home working
Personnel who are authorised to work remotely, whether from home or another location outside a Talbot & Vance office, must adhere to security requirements equivalent to those maintained within the firm's physical premises. This clause outlines the minimum standards required to protect the firm's information and systems when working remotely.
7.1
Secure physical environment
Personnel must take reasonable steps to ensure their remote working environment is physically secure. This includes positioning screens to prevent overlooking by unauthorised individuals, securing printed documents, and ensuring conversations involving confidential information cannot be overheard. Company devices must not be left unattended in public or insecure locations.
7.1
Secure physical environment
Personnel must take reasonable steps to ensure their remote working environment is physically secure. This includes positioning screens to prevent overlooking by unauthorised individuals, securing printed documents, and ensuring conversations involving confidential information cannot be overheard. Company devices must not be left unattended in public or insecure locations.
7.1
Secure physical environment
Personnel must take reasonable steps to ensure their remote working environment is physically secure. This includes positioning screens to prevent overlooking by unauthorised individuals, securing printed documents, and ensuring conversations involving confidential information cannot be overheard. Company devices must not be left unattended in public or insecure locations.
7.2
Secure network configuration
When connecting to the internet from a remote location, personnel must use a secure, password-protected wireless network. The network must be configured to use, at a minimum, WPA2 (Wi-Fi Protected Access 2) or WPA3 encryption. The use of public, untrusted, or unsecured Wi-Fi networks (e.g., in cafes, hotels, or airports) to access company resources is strictly prohibited unless the connection is made exclusively through the corporate VPN.
7.3
Mandatory VPN use
All connections from a remote location to Talbot & Vance's internal network, systems, or data repositories must be made exclusively through the firm's approved corporate Virtual Private Network (VPN). The VPN encrypts traffic and ensures a secure connection. Personnel must not attempt to bypass the VPN or use split-tunnelling configurations that expose company data to unsecured networks.
8.
Third party and supplier access
Talbot & Vance engages various third parties, including suppliers, contractors, and service providers. All access to the firm's information systems and data by third parties must be managed to mitigate associated security risks and ensure compliance with legal and contractual obligations.
8.1
Due diligence
Prior to engaging any third party that will access, process, or store firm or client data classified as 'Confidential' or 'Restricted', a security due diligence assessment must be conducted by the IT Security team. This assessment evaluates the third party's security posture, policies, and controls to ensure they meet the firm's standards. Engagement is conditional on a satisfactory assessment.
8.2
Contractual requirements
All agreements with third parties must include legally enforceable clauses that define their information security responsibilities. These requirements must include, at a minimum, the obligations to:
Protect the confidentiality, integrity, and availability of firm and client information.
Comply with applicable laws, regulations (including the Australian Privacy Act 1988), and the relevant sections of this policy.
Report any security incidents or suspected data breaches involving firm data to Talbot & Vance's Security Team without undue delay.
Grant Talbot & Vance the right to audit their security controls, or provide evidence of such controls through recognised third-party certifications (e.g., ISO 27001, SOC 2).
Protect the confidentiality, integrity, and availability of firm and client information.
Comply with applicable laws, regulations (including the Australian Privacy Act 1988), and the relevant sections of this policy.
Report any security incidents or suspected data breaches involving firm data to Talbot & Vance's Security Team without undue delay.
Grant Talbot & Vance the right to audit their security controls, or provide evidence of such controls through recognised third-party certifications (e.g., ISO 27001, SOC 2).
Protect the confidentiality, integrity, and availability of firm and client information.
Comply with applicable laws, regulations (including the Australian Privacy Act 1988), and the relevant sections of this policy.
Report any security incidents or suspected data breaches involving firm data to Talbot & Vance's Security Team without undue delay.
Grant Talbot & Vance the right to audit their security controls, or provide evidence of such controls through recognised third-party certifications (e.g., ISO 27001, SOC 2).
8.3
Access control and least privilege
All third-party access to Talbot & Vance systems and data must adhere to the principle of least privilege. Access rights granted must be the minimum necessary for the third party to fulfil their contractual obligations. Access must be provided via unique, named accounts, and generic or shared accounts are strictly prohibited. All access must be time-bound and automatically expire upon contract termination or when access is no longer required.
8.4
Access reviews
The access rights of all third parties must be reviewed on a regular basis by the relevant business owner or relationship manager. High-risk or privileged access must be reviewed quarterly. All other third-party access must be reviewed at least annually. Reviews must verify that access is still required and that the level of privilege remains appropriate. Access no longer required must be revoked within 24 hours.
9.
Incident reporting
Prompt reporting of information security incidents is critical to minimise potential harm to Talbot & Vance, its clients, and its personnel. This section outlines the mandatory procedures for reporting all suspected or actual security events.
30 minute reporting rule
All suspected or actual security incidents must be reported to the IT Security team within 30 minutes of discovery. Contact the team via: Email: security@talbotvance.com.au Phone: ext. 789
9.1
What constitutes an incident
An information security incident is any event that has compromised, or has the potential to compromise, the confidentiality, integrity, or availability of Talbot & Vance's information assets. All personnel must report any event they suspect may be a security incident, even if they are unsure. There is no penalty for reporting an event in good faith that is later found not to be an incident.
9.1
What constitutes an incident
An information security incident is any event that has compromised, or has the potential to compromise, the confidentiality, integrity, or availability of Talbot & Vance's information assets. All personnel must report any event they suspect may be a security incident, even if they are unsure. There is no penalty for reporting an event in good faith that is later found not to be an incident.
9.1
What constitutes an incident
An information security incident is any event that has compromised, or has the potential to compromise, the confidentiality, integrity, or availability of Talbot & Vance's information assets. All personnel must report any event they suspect may be a security incident, even if they are unsure. There is no penalty for reporting an event in good faith that is later found not to be an incident.

Examples of reportable incidents include, but are not limited to:

Loss or theft of a company-issued device (e.g., laptop, mobile phone).
Suspected malware or virus infection on any device used for work.
Responding to a phishing email, clicking a suspicious link, or providing credentials on an untrusted site.
Unauthorised access to systems, applications, physical office spaces, or data.
Accidental or intentional sharing of sensitive or confidential information with an unauthorised party.
Observed suspicious activity on the network or a system.
Any failure or malfunction of a security control (e.g., antivirus, firewall).
9.2
How to report an incident
When reporting an incident, provide as much detail as is immediately available to assist the IT Security team's investigation. Do not delay reporting to gather more information. Key details to include are: - Your name and contact details. - The date and time the incident was discovered. - A description of the incident (what happened). - The systems, data, or devices affected, if known. - Any immediate actions you have taken.
10.
Breach notification
Talbot & Vance is committed to managing data breaches in accordance with its obligations under the Notifiable Data Breaches ("NDB") scheme, as set out in the Australian Privacy Act 1988 (Cth). This section outlines the process for assessing and responding to data breaches, particularly those that may require notification to the Office of the Australian Information Commissioner ("OAIC") and affected individuals.
10.1
Assessment of suspected breaches
Upon receiving a report of a suspected data breach under Section 9 of this policy, the Security Team, in conjunction with the Chief Operating Officer and legal counsel, will undertake a reasonable and expeditious assessment. The purpose of the assessment is to determine whether an 'eligible data breach' has occurred. This assessment must commence immediately and aims to be completed within 30 calendar days of the firm becoming aware of the potential breach.
10.1
Assessment of suspected breaches
Upon receiving a report of a suspected data breach under Section 9 of this policy, the Security Team, in conjunction with the Chief Operating Officer and legal counsel, will undertake a reasonable and expeditious assessment. The purpose of the assessment is to determine whether an 'eligible data breach' has occurred. This assessment must commence immediately and aims to be completed within 30 calendar days of the firm becoming aware of the potential breach.
10.1
Assessment of suspected breaches
Upon receiving a report of a suspected data breach under Section 9 of this policy, the Security Team, in conjunction with the Chief Operating Officer and legal counsel, will undertake a reasonable and expeditious assessment. The purpose of the assessment is to determine whether an 'eligible data breach' has occurred. This assessment must commence immediately and aims to be completed within 30 calendar days of the firm becoming aware of the potential breach.
10.2
Eligible data breach
An 'eligible data breach' under the NDB scheme arises when the following criteria are met:
a) There is unauthorised access to, unauthorised disclosure of, or loss of, personal information held by Talbot & Vance;
b) The access, disclosure, or loss is likely to result in serious harm to one or more individuals to whom the information relates; and
c) The firm has been unable to prevent the likely risk of serious harm through remedial action.
10.3
Determining serious harm
The assessment of whether a breach is 'likely to result in serious harm' is conducted on a case-by-case basis. 'Serious harm' may include physical, psychological, emotional, financial, or reputational harm. Factors considered in the assessment include:
• The type and sensitivity of the personal information involved;
• Whether the information was protected by security measures (e.g., encryption);
• The persons or kinds of persons who have obtained, or could obtain, the information; and
• The nature of the harm that may result from the access, disclosure, or loss.
10.4
Notification procedure
If the assessment concludes that an eligible data breach has occurred, Talbot & Vance will, as soon as practicable:
a) Prepare and provide a statement to the OAIC outlining the details of the breach.
b) Notify the contents of the statement to each individual to whom the information relates, or each individual who is at risk from the eligible data breach.
c) If it is not practicable to notify individuals directly, the firm will publish the statement on its website and take reasonable steps to publicise its contents.
10.5
Record keeping
The Security Team will maintain a comprehensive register of all suspected and actual data breaches, including details of the assessment process and its outcome. This register will be maintained regardless of whether the breach was determined to be notifiable, to ensure a complete compliance record.
11.
Roles and responsibilities
Information security is a collective responsibility. Every individual at Talbot & Vance has a role to play in protecting our information assets and those of our clients. This section outlines the key security responsibilities for different roles within the firm.
Role
Key security responsibilities
All personnel
• Adhere to this Information Security Policy and related procedures. • Complete mandatory security awareness training. • Protect credentials (passwords, MFA tokens) and never share them. • Report any suspected security incidents or weaknesses immediately. • Lock devices when unattended.
Managers
• Ensure their team members understand and comply with this policy. • Approve access requests for their team members based on the principle of least privilege. • Regularly review their team's access rights. • Support security incident response activities within their team.
IT department
• Implement, manage, and monitor technical security controls. • Manage user access control systems. • Respond to security incidents and coordinate remediation efforts. • Maintain secure configurations of systems, networks, and applications. • Conduct regular vulnerability assessments and patching.
Data owners
• Classify the data for which they are responsible in accordance with the Data Classification scheme. • Authorise requests for access to their data assets. • Conduct periodic reviews of access permissions to their data. • Define handling and retention requirements for their data.
Chief operating officer
• Holds ultimate responsibility for the effectiveness of the firm's information security program. • Acts as the sponsor for this policy and ensures adequate resources are allocated for its implementation. • Reviews and approves this policy. • Acts as the final point of escalation for major security incidents.
12.
Compliance and consequences
Adherence to this Information Security Policy is a condition of employment and engagement for all Talbot & Vance personnel, including employees, contractors, and third parties with access to company information systems. All personnel are responsible for understanding and complying with the requirements set out in this policy. Failure to comply may result in disciplinary action as outlined below.
12.1
Monitoring and auditing
Talbot & Vance will monitor compliance with this policy through various means, including but not limited to regular internal and external audits of information systems, review of system logs and access records, and periodic risk assessments. Monitoring activities are conducted to verify the effectiveness of security controls, detect potential vulnerabilities, and identify unauthorised activities.
12.2
Consequences of non-compliance
Any violation of this policy or its supporting standards may result in disciplinary action, proportionate to the severity of the breach and its impact on the firm, its clients, and its data. Disciplinary measures may include, but are not limited to, verbal or written warnings, mandatory retraining, suspension of access privileges, and disciplinary action up to and including termination of employment or contract. Such actions will be taken in accordance with the individual's employment contract, relevant enterprise agreements, and applicable Australian law. In cases involving illegal activities, Talbot & Vance may report the matter to law enforcement authorities and pursue legal action.
Related documents

This policy should be read in conjunction with the following related internal documents, which provide further detail on specific areas:

Privacy Policy
Acceptable Use Standard
BYOD (Bring Your Own Device) Policy
Incident Response Plan
Data Retention and Disposal Schedule

Section by section

What each section is for, so you can keep the ones you need and drop the rest.

Document control and introduction
Version, owner, approver, dates and classification, then purpose and scope covering staff, contractors and third parties.
Acceptable use
Six prohibited uses, the limits on incidental personal use, and a ban on unapproved software.
Access control and passwords
Least privilege, one account per person, 14 character passwords and how access is granted and removed.
Multi factor authentication
Where MFA is mandatory, the three approved methods and the duty to report a lost token.
Device and endpoint security
Anti malware, full disk encryption, a 15 minute screen lock, device management and the BYOD consent.
Email and phishing
Monitoring, five signs of a phishing email, how to report one and a ban on automatic forwarding.
Data classification and handling
Four levels from Public to Restricted with examples, storage rules and sharing rules in one table.
Remote working and third party access
Secure home setups, mandatory VPN, supplier due diligence, contract clauses and access reviews.
Incident reporting and breach notification
The 30 minute reporting rule, what counts as an incident, and the assessment and OAIC notification process under the NDB scheme.
Roles, compliance and related documents
Duties for staff, managers, IT, data owners and the COO, the consequences of a breach, and five related policies.

The parts every company policy shares

Whatever the subject, a company policy has the same skeleton, and this example shows each part in place. Document control records the version, owner, approver, approval date, next review and classification. A purpose paragraph says why the policy exists and a scope paragraph says who it binds, here employees, contractors, consultants and any third party with system access. Numbered clauses carry the rules, each specific enough to test: 14 character passwords, a screen lock after 15 minutes, incidents reported within 30 minutes, privileged supplier access reviewed quarterly. A roles table gives each duty an owner. A compliance clause says what happens when the policy is broken, and a related documents list points to the policies that sit beside it, so the same rule is not written twice.

Using this as a template for other policies

Keep the document control block, the purpose and scope paragraphs, the roles table and the compliance clause exactly as they are, and replace the numbered clauses with the rules for your subject. A leave policy swaps passwords and devices for notice periods, evidence and how leave is approved. A remote work policy keeps the home security and VPN clauses from this one and adds office days, equipment and safety at home. Separate finished examples of a leave policy, a remote work policy and a code of conduct show those subjects written out in full. Whatever the subject, set the review date when the policy is approved rather than leaving it blank, and give every rule a number so a warning letter or an audit finding can cite it.

What to check before adopting this policy

The breach notification clause follows the Notifiable Data Breaches scheme in the Privacy Act 1988, which applies to most organisations with turnover above $3 million and to some smaller ones, such as health service providers. Under that scheme a suspected eligible breach must be assessed within 30 days, and the OAIC and affected individuals are told as soon as practicable once it is confirmed. Keep the classification labels consistent: the table uses four levels from Public to Restricted, and the email and supplier clauses use the same labels, because a label that appears only once is the kind of gap an auditor notes. Replace the example tools named in brackets with the systems you actually run.

What makes this document work

Document control comes before anything else

Version, owner, approver, approval date, next review and classification sit in one block before the purpose statement. That is what makes the policy auditable: anyone can tell which version applied on a given date and when it is next due for review.

It can be navigated

A contents page and numbered clauses, because a 15 page policy nobody can find their way around is a policy nobody follows. A manager handling an incident can go straight to clause 9 without reading the acceptable use rules first.

Rules are specific

Passwords need 14 characters, screens lock after 15 minutes, incidents are reported within 30 minutes and privileged third party access is reviewed quarterly. Each one is a clause somebody can be held to.

Questions people ask

What should an information security policy cover?

Acceptable use, access control and passwords, multi factor authentication, devices, email and phishing, data classification, remote work, supplier access, incident reporting and breach notification, then roles and consequences. This example gives each its own numbered clause, so a rule can be cited by number in training, in an audit or in a disciplinary letter.

Who should approve a company policy?

An accountable executive with authority over the area it governs, recorded on the document itself with the approval date and the next review date. Here the Chief Operating Officer is both owner and approver. In a larger organisation the owner is often a manager who maintains the policy and the approver a board or executive committee that signs it off.

How often should a security policy be reviewed?

At least once a year, and again after a significant incident, a new system or a change in the law. This example was approved on 5 August 2026 with the next review set for August 2027. Write the review date into the document control block, because a policy with no review date quietly becomes one nobody owns.

Does a security policy need a data classification scheme?

Yes. Without one, handling rules have nothing to attach to, and staff guess whether a spreadsheet can go by email. This example uses four levels, Public, Internal, Confidential and Restricted, each with examples, storage rules and sharing rules in one table. Four levels is enough for most firms; more than that and people stop telling them apart.

What is the document control block at the top for?

It carries the version, the owner, the approval date and the review date. This policy opens with it, before the introduction. Without those four facts nobody can tell whether they are reading the current policy, and an auditor asking which version applied on a given date has no way to answer.

Why does the policy list related documents?

Because a policy is one of a set, and a reader who needs the acceptable use rules should not be guessing. This one closes with the related documents alongside roles and compliance. It also stops the same rule being written twice in two policies that then drift apart at different review dates.

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Sources

Written and checked by the OneCraft team. Last checked .