[Translation]
ISMS Policy
1. Introduction
1.1. Objectives of the ISMS System
To protect and ensure data and information systems security and assure
confidence among stakeholders.
To establish efficient processes for managing information security within the
Company and serve as a crucial foundation for good corporate governance.
To support business growth and Company operations.
To establish a foundation for compliance with laws and regulations related to
information security.
1.2. Scope
Encompasses the information security management system of the Company's Data
Center
1.3. Definition
"Company" refers to Thai Life Insurance Public Company Limited.
"MR (Management Representative)" refers to the representative of the standard
management system, in this case, it could be either ISMR or ISMA.
"ISMS (Information Security Management System)" refers to the system for
managing information security within the Company.
"Internal Context" refers to internal factors that are considered when determining
the scope of the ISMS system.
"External Context" refers to external factors that are considered when
determining the scope of the ISMS system.
2. Context of the Organization
The Company has defined the context of the organization, which covers the internal
context, external context, and the needs and expectations of interested parties, as follows:
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2.1. Internal Context
To ensure compliance with Company policies.
To align with the Company's strategic objectives, ensuring reliability, efficiency,
responsiveness to management's needs and expectations.
Efficient management of existing resources within the Company.
Establishing effective processes for managing information security within the
Company and laying the foundation for the implementation of information
security management processes in other areas of the Company.
To establish an information security management system for the Company in
accordance with international standards (ISO/IEC 27001).
2.2. External Context
To protect against threats and risks to information security.
Compliance with regulations from the Office of Insurance Commission (OIC).
Compliance with laws and regulations issued by relevant regulatory bodies.
To build confidence in customers and users of the Company that the information
system is secure.
To prepare for emergencies and various incidents to minimize damage and
enable continuous operation, such as system downtime and cyber-attacks.
2.3. Needs and expectations of interested parties:
The expectations of management are to ensure effective governance, efficient
operations, reliability, support for company growth, and customer/user
confidence.
Customers and users expect their data to be secure, confidential, not accessed,
and/or changed without permission.
Compliance with relevant laws, regulations, and agreements, such as the
Computer Crime Act (No. 2) B.E. 2560, is necessary.
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3. Scope of the ISMS:
Scope of the ISMS:
"The Information Security Management System applies to Data Center including
Support Infrastructure, Network, and Facilities operated by Thai Life Insurance Public Company
Limited. This is in accordance with the Statement of Applicability (SOA)."
Location:
Thai Life Insurance Public Company Limited.
123 Ratchadaphisek Road, Dindaeng District, Bangkok 10400 Thailand
Detailed information about the assets under the scope of the ISMS of Thai Life
Insurance Public Company Limited can be found in ISMS-FM-40 Inventory of Assets Data
Center.
4. Documents of the ISMS:
4.1. Types of Documents:
The ISMS documents of the Company are categorized into 4 types:
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4.2. Control of Documents:
Documents of the ISMS must be adequately protected and controlled as follows:
Documents must be appropriately approved before issuance.
Documents must be reviewed and updated regularly, with a process in place for
approving new documents whenever there are changes or revisions.
Changes to documents and the latest version must be appropriately identified in
writing.
The latest version of documents must be accessible to relevant users when
needed.
Documents must be protected against unauthorized access and use by
individuals who do not have permission to use them.
Documents must be complete and in a state ready for use.
Documents must be managed for storage, transmission, usage, and disposal
according to their confidentiality level.
External documents used within the Company must be registered and controlled.
Outdated versions of documents must be controlled and stored to prevent
unintentional use, and if they need to be used, they must be clearly identified.
Refer to ISMS-PC-08 Document Control Procedure.
4.3. Control of Records:
Records of the ISMS serve as evidence of ISMS operations and must be adequately
protected and controlled to ensure they are complete and can be retrieved for review
when needed. Furthermore, compliance with relevant laws, regulations, or regulatory
requirements related to the storage, usage, and disposal of records must be adhering to
the ISMS-PC-09 Record Control Procedure.
The document must be approved before it can be published for use.
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5. Structure and Responsibilities in the ISMS (Information Security Management System)
5.1. IT Sub-committee (ITSC)
The IT Sub-committee comprises senior management from relevant departments
that support the establishment, implementation, review, and improvement of the
Company's ISMS (Information Security Management System). The IT Sub-committee is
responsible for:
Defining the objectives of the Company's information security.
Approving and disseminating policies for maintaining information security and
related documents within the ISMS.
Communicating to all employees the importance of data security and
compliance with information security policies and related documents within the
ISMS.
Provide education and training to employees and relevant external individuals
to ensure awareness and ability to adhere to information security policies and
related documents within the ISMS, including appropriately monitoring the
compliance of employees and relevant external individuals.
Consider penalties for violations of information security policies and related
documents within the ISMS.
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[Translation]
Establish criteria for risk acceptance and acceptable risk levels, including assessing
the results of risk assessments and important risk mitigation plans of the
Company.
Support resources for the establishment, implementation, review, and
improvement of the ISMS.
Conduct meetings to review the operation of the ISMS to ensure that the
Company's ISMS is adequate, sufficient, and effective, including considering
opportunities for continuous improvement of the ISMS.
5.2. Information Security Management Representative (ISMR) / Information Security
Management Assistance (ISMA)
The ISMR and ISMA are representatives of the Company's management who are
responsible for overseeing the establishment, implementation, review, and improvement
of the Company's ISMS. The ISMR and ISMA have the following responsibilities:
Coordinate to establish and develop the ISMS within the Company, including
maintaining, reviewing, and continuously improving the system to enhance
security in accordance with the information security policy and ISO/IEC 27001
standards.
Oversee the updating of policies and related documents within the ISMS to align
with changes, complying with ISO/IEC 27001 standards and recommendations
received from the IT Sub-committee.
Communicate to all employees their roles and responsibilities in adhering to
policies and related documents within the ISMS.
Monitor the Company's operations to ensure compliance with the documents of
the ISMS.
Provide consultation on information security maintenance and the
implementation of various policies to employees within the Company.
Monitor and ensure that the activities of the ISMS are carried out according to
the plan and that the results align with the Company's information security
objectives.
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[Translation]
Monitor and control changes occurring within the Company, coordinating
assessments, corrections, and appropriate risk management from such changes.
Control and oversee the effectiveness measurement of processes and controls
within the ISMS.
Supervise internal ISMS audits.
Oversee the handling of corrections and preventive actions for ISMS
vulnerabilities, including tracking and reviewing the effectiveness of such actions.
Coordinate on meetings for management reviews of the ISMS operations and
follow up on the decisions made in the meetings.
Report the results of ISMS operations to management.
Coordinate and find solutions for controlling and managing incidents in case of
security breaches occurring within the Company.
5.3. ISMS Core Team (CT)
The ISMS Core Team comprises representatives from various departments within the
scope of the ISMS, responsible for coordinating and executing ISMS-related activities within
their respective departments. The ISMS Core Team has the following responsibilities:
Communicate, advise, and oversee employees in each department to ensure
proper compliance with ISMS policies and related documents.
Establish and maintain asset registers within each department.
Coordinate with ISMR/ISMA to conduct risk assessments and manage risks for
each department.
Coordinate with ISMR/ISMA to implement the Security Plan as outlined.
Coordinate with ISMR/ISMA to measure the effectiveness of processes and
controls within the ISMS relevant to each department.
Maintain a record list and control records for each department.
Coordinate with ISMR in the event of any security breaches or emergencies within
the Company to control and manage the arising issues.
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[Translation]
Listen to complaints or suggestions related to the ISMS from employees and
relevant external individuals and report to ISMR/ISMA before taking corrective
and preventive actions to improve the effectiveness of ISMS operations.
5.4. Document Controller
The Document Controller is responsible for overseeing and controlling the usage of
documents and records within the ISMS to comply with the requirements of ISO/IEC 27001
standards. The Document Controller's responsibilities include:
Controlling and overseeing the process of creating new documents, modifying
existing documents, and discontinuing documents.
Assigning document number and dates to documents.
Managing the original copies of documents or soft copies of documents.
Maintaining the Master List of all ISMS documents and being responsible for
ensuring the accuracy of data updates.
Monitoring and ensuring that documents are reviewed and updated regularly
according to appropriate schedules.
5.5. Internal ISMS Auditor
The Internal ISMS Auditor is responsible for conducting internal assessments within
the Company's ISMS to identify conformity and deficiencies, leading to continuous
improvement of the ISMS. The responsibilities of the Internal ISMS Auditor include:
Planning, coordinating, and conducting internal assessments for the Company's
ISMS.
Reporting assessment results and providing recommendations for improvement
to relevant parties.
Monitoring and reviewing the implementation of corrective or preventive actions
identified during internal assessments.
5.6. Asset Owner
The Asset Owner is responsible for managing asset registers, assigning data
classification levels to assets, and ensuring appropriate protection of assets throughout
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their lifecycle. This includes ensuring the security of assets disposal, sale, transfer, or
cessation of asset use.
5.7. Risk Owner
The Risk Owner is responsible for assessing risks, planning risk mitigation, and ensuring
that risks are addressed according to the plan.
5.8. Document Owner
The document owner is responsible for creating, reviewing, and updating information
security policies and documents related to the ISMS to ensure they are up-to-date and
usable. The document owner must support the implementation and compliance with
documents to ensure that personnel can perform their duties correctly. Their
responsibilities include:
Creating, reviewing, updating, discontinuing, and versioning documents, including
registering documents to the Document Controller.
Assigning classification levels and access rights to documents for relevant parties.
Retrieving and controlling documents that have been discontinued.
Ensuring the correct and appropriate use of documents, including controlling the
issuance of document copies.
5.9. All personnel
All employees, including external personnel such as contractors, consultants,
temporary staff, partners, and service providers, who use the Company's data or
information technology systems have the following responsibilities:
Complying with the guideline 1-2/2565 on information system security.
Protecting and safeguarding the Company's data and assets, preventing
unauthorized access, modification, disclosure, or destruction.
Fulfilling responsibilities related to information security and information
technology systems as assigned.
Reporting any abnormalities or weaknesses in security to the Company
appropriately.
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[Translation]
6. Establishing Objectives and Planning Information Security Maintenance
6.1. Establishing Objectives for Information Security of the Company
Establishing objectives for information security in accordance with the business
objectives, policies, and ISMS system objectives to guide the management of information
security within the Company to align with business objectives, requirements, and
expectations of stakeholders.
6.2. Planning Information Security Maintenance
Developing a plan for maintaining information security within the Company to define
activities necessary to achieve the objectives for maintaining information security as
established.
7. Information Security Management System
The Information Security Management System (ISMS) of the Company has been
established, implemented, monitored, and continuously improved according to the
requirements of ISO/IEC 27001 standard. It applies risk management principles to provide
confidence to stakeholders that the Company's important information and information
systems are adequately protected. Additionally, the ISMS has been designed to align with
the Company's management processes and organizational structure, covering the following
key activities:
- Defining the Company's requirements for information security and communicating
them through the issuance of information security policies, as well as ensuring
awareness among relevant stakeholders.
- Assessing the Company's information security risks.
- Establishing controls that align with the Company's risks.
- Monitoring and measuring the performance of the ISMS.
- Continuously improving the ISMS based on measurement results and pre-defined
objectives.
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[Translation]
The core components of the Company's ISMS system are illustrated in the diagram below.
Figure: Core components of ISMS system
Analysis of the relevant context and determination of the scope of the ISMS system
(Context of the organization)
Conduct an analysis of both internal and external contexts, including the expectations of
stakeholders, to define the objectives of the Company's information security management
system (ISMS) and the scope of the ISMS.
Role and responsibilities of management (Leadership)
Give importance to and support the operations of the ISMS by announcing the information
security management policy, defining employee responsibilities, reviewing ISMS operations,
and allocating resources for the continuous operation and improvement of the ISMS.
Planning of the ISMS operations
Planning on the maintaining of the information security of the Company to determine activities
needed to achieve the objectives of the Company's information security management system
(ISMS) as defined. Also, analyze information security risks, including risks that may affect the
operation of the ISMS, and plan to mitigate risks by selecting appropriate control measures.
Support for ISMS Operations
Manage resources, especially human resources, to ensure they have the knowledge, skills, and
awareness to comply with information security policies and ISMS processes.
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[Translation]
ISMS Operation
Oversee the operation of the ISMS and the effectiveness of risk mitigation activities, ensuring
they are in line with the planned activities. This includes monitoring risk assessments and
planning risk mitigation regularly or when significant changes that may affect the Company's
risks occur.
Performance Evaluation of the ISMS
Conduct reviews and evaluations of processes and control measures, comparing them against
information security policies, relevant standards, indicators, and objectives related to the
Company's information security. Report the results to management.
Continuous Improvement of the ISMS
Address identified deficiencies from reviews and evaluations of processes and control
measures. Continuously improve the ISMS through reviewing and updating objectives related
to the Company's information security and associated plans.
8. Supporting ISMS Operations
8.1. Training, Knowledge, and Skills Development
ISMR/ISMA and supervisory personnel must support training initiatives to provide
knowledge to employees involved in ISMS responsibilities adequately and sufficiently for
their job duties. This includes:
Identifying the necessary skills for employees involved in ISMS-related tasks.
Organizing training sessions or sourcing knowledgeable personnel (if necessary).
Evaluating the effectiveness of training and taking appropriate actions.
Maintaining records of training as well as other evidence confirming the
knowledge, skills, and experiences of employees
ISMR/ISMA personnel and their superiors must ensures that employees responsible
for the ISMS are aware of the importance of their roles and responsibilities in maintaining
information security and contribute to the Company's in achieving its objectives.
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[Translation]
8.2. Internal and External Communication
Develop a communication plan (ISMS-FM-38 Security Communication Plan) to
disseminate information related to information security management to both internal and
external stakeholders of the Company.
Internal communication within the Company includes communication between
departments and reporting to management.
External communication involves communication between the Company and
external entities such as partners, external service providers, or relevant
government agencies, as well as communication between the Company and
external individuals such as customers or the general public.
8.3. Oversight of External Service Providers
Oversight external service providers engaged in activities or processes related to
information security management for the Company. This involves controlling activities or
processes in accordance with the Company's information security policy, as well as other
relevant supporting documents. Additionally, conduct evaluations of external service
providers and support continuous improvement efforts.
9. Risk management
Risk Management is a systematic process involving risk identification, assessment, and
control measures to maintain risks at acceptable levels for the Company. It is considered a
crucial aspect that enables a Company's ISMS to uphold information security. Risk
management involves ongoing activities to address and mitigate risks arising from internal and
external changes within the Company. In addition to managing risks, it is also essential to
consider opportunities.
Standard serves as a reference for the Company's risk management practices.
ISO 31000:2009, Risk Management – Principles and guidelines
ISO/IEC 27005:2011, Information technology - Security techniques – Information
security risk management
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[Translation]
NIST SP 800-30, Risk Management Guide for Information Technology Systems
AS/NZS 4360
The criteria for accepting risks and the acceptable levels of risk
The Company categorizes risk levels into four levels: High (H), Significant (S), Moderate
(M), and Low (L). The levels that the Company can accept without the need for corrective
action and risk control are Low (L) and Moderate (M). Any risk exceeding these levels must be
addressed explicitly and must receive approval from relevant management personnel. The
criteria for accepting risks that are deemed feasible include:
Investment required for risk mitigation does not justify the potential maximum
impact.
Risks cannot be mitigated to the Low (L) or Moderate (M) levels.
Management decision not to mitigate the risk. This required to be supported
by appropriate rationale.
The risk management and opportunity management
The risk management and opportunity management process consist of three main
activities:
9.1. Risk Assessment and Opportunity Assessment
Risk assessment involves analyzing potential risk scenarios by considering possible
threats and vulnerabilities. Then, the likelihood of these risk scenarios occurring and the
impact they would have are evaluated, following the ISMS-PC-06 Risk Assessment
Procedure.
Opportunity assessment entails analyzing potential opportunity scenarios that could
benefit the Company. Then, the likelihood and impact of these opportunities are
evaluated.
9.2. Risk Treatment
Risk treatment involves finding appropriate methods or tools to mitigate and control
risks to a level that the Company can accept. Possible approaches for risk treatment
include:
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[Translation]
Risk Mitigation
Risk Acceptance
Risk Avoidance
Risk Transfer or sharing with other properties
Accepting increased risk for business opportunities
The selection of risk treatment approaches must consider their suitability and the
resources required. Risk mitigation actions should refer to controls outlined in Annex A of
the ISO/IEC 27001 standard, following the ISMS-PC-05 Risk Treatment Procedure.
9.3. Review of Risk Assessment:
The results of risk assessments must be reviewed at appropriate intervals, at least
once a year or when significant changes occur. This ensures that the methods used and
the results of risk assessments align with the current situation.
10. Performance Evaluation:
Performance evaluation is a crucial process that demonstrates the effectiveness and
continuous improvement of the ISMS. It helps the Company understand the effectiveness of
policies, supporting documents, processes, controls, and risk management strategies
employed. This evaluation covers both ISMS requirements (Clause 4-10) and the controls
selected for implementation (Annex A) of the ISO/IEC 27001 standard.
Measurement indicators used for performance evaluation include both lead indicators
(before an event) and lag indicators (after an event) to provide comprehensive data. The
results of performance evaluations are reported to management and relevant stakeholders
for consideration in implementing corrective actions or improvements to the ISMS. This
process is outlined in the ISMS-PC-10 Effectiveness Measurement Procedure.
11. Internal Audit of the ISMS
The Company ensures that internal audits of the ISMS are conducted at least once a
year to ensure that:
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[Translation]
Operations of the ISMS comply with the requirements of the ISO/IEC 27001
standard and relevant laws and regulations.
Operations align with the requirements and documentation of the Company's
ISMS.
Operations are carried out effectively.
Planning for internal audits considers the importance of processes, departments, or
areas to be audited and the results from previous audits. Auditors must receive appropriate
training and selection, ensuring that they do not audit areas where they have involvement.
Planning, testing, reporting, and monitoring corrective actions follow the IA-ISO-PC-01 Internal
Audit Procedure. Department managers involved in audited areas must cooperate in
identifying causes and implementing corrective actions for identified deficiencies.
12. Review of the ISMS by Management:
The IT Sub-committee must hold meetings to review the operations of the ISMS at
least once a year. This ensures that the Company's ISMS operations are appropriate, sufficient,
and effective. Such reviews should consider opportunities for improving the ISMS and
necessary changes. Additionally, they should involve reviewing and revising the information
security policies and objectives of the Company. The outcomes of these reviews are
adequately documented for reference.
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[Translation]
13. Corrective Action
The Company has established a corrective action process to address issues or non-
conformities identified within the ISMS (Information Security Management System) to prevent
recurrence. All actions must be communicated to relevant personnel, and there must be
follow-up and review of the outcomes to ensure that the objectives of the corrective actions
are achieved. This process is referenced in the ISMS-PC-12 Corrective and Preventive Action
Procedure.
14. Statement of Applicability (SOA)
The Statement of Applicability (SOA) is a document that identifies the application of
controls from all 114 requirements of the ISO/IEC 27001 standard within the Company. It
specifies:
Controls selected for implementation in the ISMS (Information Security
Management System), along with explanations of their application or references
to related documents that can explain the implementation of controls.
Controls that are not applied, along with the reasons for not applying them.
15. Continuous Improvement of ISMS
The Company emphasizes continuous improvement of the ISMS to ensure effective
maintenance of information security. This enables the protection of assets, data, and critical
information systems from constantly evolving threats. Regular internal and external context
reviews, along with input from stakeholders, are conducted to enhance the objectives of
maintaining information security and the Company's information security maintenance plans,
annually.
(The policy shall be effective as of 22 August 2023 onwards.)
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