Facility Access and Physical Security

It is the goal of CloudCore to provide a safe and secure environment for all employees.

Title	Facility Access and Physical Security
Doc#	POL-SECU-003
Version	1.0
Date	03-08-2023

It is the goal of CloudCore to provide a safe and secure environment for all employees. Access to the CloudCore facilities is limited to authorised individuals only.

CloudCore works with Subcontractors (e.g. property management companies and facilities management) to assure restriction of physical access to systems used as part of the CloudCore Platform.

Physical Access to all of CloudCore facilities is limited to only those authorised in this policy. All workforce members are responsible for reporting an incident of unauthorised visitor and/or unauthorised access to CloudCore’s facility.

CloudCore and its Subcontractors control access to the physical buildings/facilities that house these systems/applications, or in which CloudCore workforce members operate, in accordance to the HIPAA Security Rule 164.310 and its implementation specifications. In an effort to safeguard ePHI from unauthorised access, tampering, and theft, access is allowed to areas only to those persons authorised to be in them and with escorts for unauthorised persons.

Policy Statements

CloudCore policy requires that

1. Physical access to CloudCore facilities is restricted.

2. All employees are required to wear employee badges at secure facilities (such as server rooms, data centers, labs).

3. All employees must follow physical security requirements and procedures documented by facility management.

4. On-site visitors and vendors must be escorted by a CloudCore employee at all times while on premise.

5. All workforce members are responsible for reporting an incident of unauthorised visitor and/or unauthorised access to CloudCore’s facility.

6. Retain a record for each physical access, including visits, maintenance and repairs to CloudCore production environments and secure facilities.

• Details must be captured for all maintenance and repairs performed to physical security equipment such as locks, walls, doors, surveillance cameras; and
• All records must be retained for a minimum of seven years.

7. Building security, such as fire extinguishers and detectors, escape routes, floor warden responsibilities, shall be maintained according to applicable laws and regulations.

Controls and Procedures

Physical Security

Access Requirements Overview

• Physical access is restricted using badge readers and/or smart locks that track all access.

  • Restricted areas and facilities are locked when unattended (where feasible).
  • Only authorised workforce members receive access to restricted areas (as determined by the Security Officer).
  • Access and keys are revoked upon termination of workforce members.
  • Workforce members must report a lost and/or stolen key(s) or badge(s) to his/her manager, local Site Lead, or the Facility Manager.
  • The Facility Manager or designee is responsible to revoke access to the lost/stolen badge(s) or access key(s), and re-provision access as needed.
  • The Facility Manager or designee facilitates the changing of the lock(s) within 7 days of a physical key being reported lost/stolen.

• Enforcement of Facility Access Policies

  • Report violations of this policy to the restricted area’s department team leader, supervisor, manager, or director, or the Privacy Officer.
  • Workforce members in violation of this policy are subject to disciplinary action, up to and including termination.
  • Visitors in violation of this policy are subject to loss of vendor privileges and/or termination of services from CloudCore.

• Workstation Security

  • Workstations may only be accessed and utilised by authorised workforce members to complete assigned job/contract responsibilities.
  • All workforce members are required to monitor workstations and report unauthorised users and/or unauthorised attempts to access systems/applications as per the System Access Policy.
  • All workstations purchased by CloudCore are the property of CloudCore and are distributed to users by the company.

Building Standards per Location

All entry points are secured by card readers and have cameras for additional monitoring as needed.

• Indianapolis, IN Office

  • The building is unlocked Monday-Friday from 9am-4pm
  • After hours the building is secured and requires an access card for entry
  • The main entry to our office suite is open during normal business hours (M-F 8am-5pm)
  • CloudCore office space is secured and requires an access card for entry for after hours access
  • All server rooms are secured 24/7 and require an access card for entry

• Morrisville, NC Office

  • The building is unlocked with free access Monday–Friday 7am-7pm and Saturdays from 9am-1pm
  • After hours the building is secured and requires an access card for entry
  • CloudCore office suite is secured 24/7 and requires an access card for entry

Facility Access Data Storage

The security server that houses our security configuration for our electronic key card system is securely located in the server room of the prospective office that it manages; Indianapolis, IN and Morrisville, NC.

dnaFusion (Indianapolis office) stores all access control logs indefinitely.

mySonitrol (Morrisville office) stores all access control logs for 90 days.

Camera footage is stored on cameras and footage is accessed through Meraki. Footage is stored for a minimum of 30 days.

Facility Access Control Process

Access cards are stored in a locked cabinet until they are activated and issued.

New Hires

New Hire access cards are assigned based on new hire notice issued through .

• New Hire access is typically activated the day prior to start date
• Once activated the access card is stored in a locked cabinet until issued to new hire.

Separations

Separation notices are issued through .

• Immediate separation notices are processed when issued
• Future separation notices are pre-scheduled for deactivation prior to termination date

Special Access Requests

Special access areas require additional approvals for access. If documented approver is unavailable, COO may act as approver.

Maintenance & Repairs

All maintenance, repairs and modifications to our access control system will be handled by the local vendor that supports our system.

All documents regarding maintenance, repair or modification will be stored in the physical security folder located on the CloudCore SharePoint site.

Reporting and Auditing

All access control records are audited on an annual basis.

Special access is audited and reviewed with approver quarterly.

Records are owned and maintained by the Facility Manager. Records are kept in the Physical Security folder on SharePoint and will be retained for a minimum of 7 years.

Data Center Security

Physical security of data centers is ensured by the cloud infrastructure service provided, AWS.

Clean Desk Policy and Procedures

Employees must secure all sensitive/confidential information in their workspace at the conclusion of the work day and when away from their workspace. This includes both electronic and physical information such as:

• computer workstations, laptops, and tablets
• removable storage devices including CDs, DVDs, USB drives, and external hard drives
• printed materials

Computer workstations/laptops must be locked (password protected) when physically unattended. Portable devices such as laptops and tablets should be taken home at the conclusion of the work day.

Removable storage devices and printed documents must be treated as sensitive material and locked in a drawer or similar when not in use. Printed materials must be immediately removed from printers or fax machines. Passwords must not be written down or stored physically.

Keys and access cards used for access to sensitive or restricted information/areas must not be left unattended anywhere in the office.