30(a) Security Policy: Summary of the security policy for the proposed registry

Prototypical answer:

gTLDFull Legal NameE-mail suffixDetail
.tubeBoss Castle, LLCdonuts.coView

Q30A Standard CHAR: 19646


Our Information Security (IS) Program and associated IS Policy, Standards and Procedures apply to all Company entities, employees, contractors, temps, systems, data, and processes. The Security Program is managed and maintained by the IS Team, supported by Executive Management and the Board of Directors.

Data and systems vary in sensitivity and criticality and do not unilaterally require the same control requirements. Our security policy classifies data and systems types and their applicable control requirements. All registry systems have the same data classification and are all managed to common security control framework. The data classification applied to all registry systems is our highest classification for confidentiality, availability and integrity, and the supporting control framework is consistent with the technical and operational requirements of a registry, and any supporting gTLD string, regardless of its nature or size. We have the experienced staff, robust system architecture and managed security controls to operate a registry and TLD of any size while providing reasonable assurance over the security, availability, and confidentiality of the systems supporting critical registry functions (i.e., registration services, registry databases, zone administration, and provision of domain name resolution services).

This document describes the governance of our IS Program and the control frameworks our security program aligns to (section 1.0), Security Policy requirements (section 2.0); security assessments conducted (see section 3.0), our process for executive oversight and visibility of risks to ensure continuous improvement (section 4.0), and security commitments to registrants (section 5). Details regarding how these control requirements are implemented, security roles and responsibilities and resources supporting these efforts are included in Security Policy B response.


The IS Program for our registry is governed by an IS Policy aligned to the general clauses of ISO 27001 requirements for an Information Security Management System (ISMS) and follows the control objectives where appropriate, given the data type and resulting security requirements. (ISO 27001 certification for the registry is not planned, however, our DNS⁄DNSSEC solution is 27001 certified). The IS Program follows a Plan-Do-Check-Act (PDCA) model of continuous improvement to ensure that the security program grows in maturity and that we provide reasonable assurance to our shareholders and Board of Directors that our systems and data are secure.

The High Security Top Level Domain (HSTLD) control framework incorporates ISO 27002, the code of practice for implementing an ISO 27001 ISMS. Therefore, our security program is already closely aligned HSTLD control framework. Furthermore, we agree to abide by the HSTLD Principle 1 and criteria 1.1 - 1.3. (See specifics in Security Policy B response):

Registry systems will be in-scope for Sarbanes-Oxley (SOX) compliance and will follow the SOX control framework governing access control, account management, change management, software development life cycle (SDLC), and job monitoring of all systems. Registry systems will be tested frequently by the IS team for compliance and audited by our internal audit firm, Protiviti, and external audit firm, Price Waterhouse Coopers (PWC), for compliance.


Our Information Security Program is governed by IS Policy, supported by standards, and guided by procedures to ensure uniformed compliance to the program. Standards and associated procedures in support of the policy are shown in Attachment A, Figure 1. Security Program documents are updated annually or upon any system or environment change, new legal or regulatory requirements, and⁄or findings from risk assessments. Any updates to security program are reviewed and approved by the Executive Vice President (EVP) of Information Technology (IT), EVP of Legal & General Counsel, and the EVP of People Operations before dissemination to all employees.

All employees are required to sign the IS Policy upon hire, upon any major changes, and⁄or annually. By signing the IS Policy, employees agree to abide by the supporting Standards and Procedures applicable to their job roles. To enable signing of the IS Policy, employees must pass a test to ensure competent understanding of the IS Policy and its key requirements.



The following data classification is applied to registry systems: High Business Impact (HBI): Business Confidential in accordance with the integrity, availability and confidentiality requirements of registry operations. All registry systems will follow Security Policy requirements for HBI systems regardless of the nature of the TLD string, financial materiality or size. HBI data if not properly secured, poses a high degree of risk to the Company and includes data pertaining to the Company’s adherence to legal, regulatory and compliance requirements, mergers and acquisitions (M&A), and confidential data inclusive of, but is not limited to: Personally Identifiable Information (PII) (credit card data, Social Security Numbers (SSN) and account numbers); materially important financial information (before public disclosure), and information which the Board of Directors⁄Executive team deems to be a trade secret, which, if compromised, would cause grave harm to the execution of our business model.

HBI safeguards are designed, implemented and measured in alignment with confidentiality, integrity, availability and privacy requirements characterized by legal, regulatory and compliance obligations, or through directives issued by the Board of Directors (BOD) and Executive team. Where guidance is provided, such as the Payment Card Industry (PCI) Data Security Standard (DSS) Internal Audit Risk Control Matrices (RCMs), local, state and federal laws, and other applicable regulations, we put forth the appropriate level of effort and resources to meet those obligations. Where there is a lack of guidance or recommended safeguards, Risk Treatment Plans (RTP’s) are designed in alignment with our standard risk management practices.

Other data classifications for Medium Business Impact (MBI): Business Sensitive and Low Business Impact (LBI): Public do not apply to registry systems.


All registry systems have a designated owner and⁄or custodian who ensures appropriate security classifications are implemented and maintained throughout the lifecycle of the asset and that a periodic review of that classification is conducted. The system owner is also responsible for approving access and the type of access granted. The IS team, in conjunction with Legal, is responsible for defining the legal, regulatory and compliance requirements for registry system and data.


Media and documents containing HBI data must adhere to their respective legal, regulatory and compliance requirements and follow the HBI Handling Standard and the retention requirements within the Document Retention Policy.


User authentication is required to access our network and system resources. We follow a least-privileged role based access model. Users are only provided access to the systems, services or information they have specifically been authorized to use by the system owner based on their job role. Each user is uniquely identified by an ID associated only with that user. User IDs must be disabled promptly upon a user’s termination, or job role change.

Visitors must sign-in at the front desk of any company office upon arrival and escorted by an employee at all times. Visitors must wear a badge while on-site and return the badge when signing out at the front desk. Dates and times of all visitors as well as the name of the employee escorting them must be tracked for audit purposes.

Individuals permitted to access registry systems and HBI information must follow the HBI Identity & Access Management Standard. Details of our access controls are described in Part B of Question 30 response including; technical specifications of access management through Active Directory, our ticketing system, physical access controls to systems and environmental conditions at the datacenter.



Controls shall be implemented to protect against malicious code including but not limited to:
- Identification of vulnerabilities and applicable remediation activities, such as patching, operating system & software upgrades and⁄or remediation of web application code vulnerabilities.
- File-integrity monitoring shall be used, maintained and updated appropriately.
- An Intrusion Detection Solution (IDS) must be implemented on all HBI systems, maintained & updated continuously.
- Anti-virus (AV) software must be installed on HBI classified web & application systems and systems that provide access to HBI systems. AV software and virus definitions are updated on a regular basis and logs are retained for no less than one year.


On a regular basis, IS personnel must review newly identified vulnerability advisories from trusted organizations such as the Center for Internet Security, Microsoft, SANS Institute, SecurityFocus, and the CERT at Carnegie-Mellon University. Exposure to such vulnerabilities must be evaluated in a timely manner and appropriate measures taken to communicate vulnerabilities to the system owners, and remediate as required by the Vulnerability Management Standard. Internal and external network vulnerability scans, application & network layer penetration testing must be performed by qualified internal resource or an external third party at least quarterly or upon any significant network change. Web application vulnerability scanning is to be performed on a continual basis for our primary web properties applicable to their release cycles.


Changes to HBI systems including operating system upgrades, computing hardware, networks and applications must follow the Change Control Standard and procedures described in Security Policy question 30b.


Data critical to our operations shall be backed up according to our Backup and Restoration Standard. Specifics regarding Backup and Restoration requirements for registry systems are included in questions 37 & 38.


- Appropriate controls must be established for ensuring the network is operated consistently and as planned over its entire lifecycle.
- Network systems must be synchronized with an agreed upon time source to ensure that all logs correctly reflect the same accurate time.
- Networked services will be managed in a manner that ensures connected users or services do not compromise the security of the other applications or services as required in the HBI Network Configuration Standard. Additional details are included in Question 32: Architecture response.


The SVP of IT has responsibility for the management of disaster recovery and business continuity. Redundancy and fault-tolerance shall be built into systems whenever possible to minimize outages caused by hardware failures. Risk assessments shall be completed to identify events that may cause an interruption and the probability that an event may occur. Details regarding our registry continuity plan are included in our Question 39 response.


Advance planning and preparation is required to ensure new or modified systems have adequate security, capacity and resources to meet present and future requirements. Criteria for new information systems or upgrades must be established and acceptance testing carried out to ensure that the system performs as expected. Registry systems must follow the HBI Software Development Lifecycle (SDLC) Standard.


Audit logs that record user activities, system errors or faults, exceptions and security events shall be produced and retained according to legal, regulatory, and compliance requirements. Log files must be protected from unauthorized access or manipulation. IS is responsible for monitoring activity and access to HBI systems through regular log reviews.


Potential security incidents must be immediately reported to the IS Team, EVP of IT, the Legal Department and⁄or the Incident Response. The Incident Response Team (IRT) is required to investigate: any real or suspected event that could impact the security of our network or computer systems; impose significant legal liabilities or financial loss, loss of proprietary data⁄trade secret, and⁄or harm to our goodwill. The Director of IS is responsible for the organization and maintenance of the IRT that provides accelerated problem notification, damage control, investigation and incident response services in the event of security incidents. Investigation and response processes follow the requirements of the Investigation and Incident Management Standard and supporting Incident Response Procedure (see Question 30b for details).


All relevant legal, regulatory and contractual requirements are defined, documented and maintained within the IS Policy. Critical records are protected from loss, destruction and falsification, in accordance with legal, contractual and business requirements as described in our Document Retention Policy. Compliance programs implemented that are applicable to Registry Services include:

- Sarbanes Oxley (SOX): All employees managing and accessing SOX systems and⁄or data are required to follow SOX compliance controls.
- Data Privacy and Disclosure of Personally Identifiable Information (PII): data protection and privacy shall be ensured as required by legal and regulatory requirements, which may include state breach and disclosure laws, US and EU Safe Harbor compliance directives.

Other compliance programs implemented but not applicable to Registry systems include the Payment Card Industry (PCI) Data Security Standard (DSS), Office of Foreign Assets Control (OFAC) requirements, Copyright Infringement & DMCA.


Our IS team conducts frequent security assessments to analyze threats, vulnerabilities and risks associated with our systems and data. Additionally, we contract with several third parties to conduct independent security posture assessments as described below. Details of these assessments are provided in our Security Policy B response.


We outsource the following third party security assessments (scope, vendor, frequency and remediation requirements of any issues found are detailed in our Security Policy B response); Web Application Security Vulnerability testing, quarterly PCI ASV scans, Sarbanes-Oxley (SOX) control design and operating effectiveness testing and Network and System Security Analysis.


The IS team conducts routine and continual internal testing (scope, frequency, and remediation requirements of any issues found are detailed in our Security Policy B response) including; web application security vulnerability testing, external and internal vulnerability scanning, system and network infrastructure penetration testing, access control appropriateness reviews, wireless access point discovery, network security device configuration analysis and an annual comprehensive enterprise risk analysis.


In addition to the responsibility for Information Security residing within the IS team and SVP of IT, risk treatment decisions are also the responsibility of the executive of the business unit responsible for the risk. Any risk with potential to impact the business financially or legally in a material way is overseen by the Incident Response Management team and⁄or the Audit Committee. See Figure 2 in Attachment A. The Incident Response Management Team or Audit Committee will provide assistance with management action plans and remediation.


We have deployed RSA’s Archer Enterprise Governance Risk and Compliance (eGRC) Tool to provide an independent benchmarking of risk, compliance and security metrics, assist with executive risk reporting and reduce risk treatment decision making time, enforcing continuous improvement. The eGRC provides automated reporting of registry systems compliance with the security program as a whole, SOX Compliance, and our Vulnerability Management Standard. The eGRC dashboard continuously monitors risks and threats (through automated feeds from our vulnerability testing tools and third party data feeds such as Microsoft, CERT, WhiteHat, etc.) that are actionable. See Attachment A for more details on the GRC solutions deployed.


We operate all registry systems in a highly secured environment with appropriate controls for protecting HBI data and ensuring all systems remain confidential, have integrity, and are highly available. Registrants can assume that:

1. We safeguard the confidentiality, integrity and availability of registrant data through access control and change management:
- Access to data is restricted to personnel based on job role and requires 2 factors of authentication.
- All system changes follow SOX-compliant controls and adequate testing is performed to ensure production pushes are stable and secure.
2. The network and systems are deployed in high availability with a redundant hot datacenter to ensure maximum availability.
3. Systems are continually assessed for threats and vulnerabilities and remediated as required by the Vulnerability Management Standard to ensure protection from external malicious acts.
- We conduct continual testing for web code security vulnerabilities (cross-site scripting, SQL Injection, etc.) during the development cycle and in production.
4. All potential security incidents are investigated and remediated as required by our Incident Investigation & Response Standard, any resulting problems are managed to prevent any recurrence throughout the registry.

We believe the security measures detailed in this application are commensurate with the nature of the TLD string being applied for. In addition to the system⁄ infrastructure security policies and measures described in our response to this Q30, we also provide additional safety and security measures for this string.

These additional measures, which are not required by the applicant guidebookare:

1.Periodic audit of Whois data for accuracy;
2.Remediation of inaccurate Whois data, including takedown, if warranted;
3.A new Domain Protected Marks List (DPML) product for trademark protection;
4.A new Claims Plus product for trademark protection;
5.Terms of use that prohibit illegal or abusive activity;
6.Limitations on domain proxy and privacy service;
7.Published policies and procedures that define abusive activity; and
8.Proper resourcing for all of the functions above.

See Question B Response Section 10.

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