Information Lifecycle Management (ILM) Policy

1. Purpose

The purpose of this Information Lifecycle Management (ILM) Policy is to establish procedures for managing information throughout its lifecycle—from creation and usage to archiving and disposal. This policy ensures that all information is classified and handled based on legal requirements, its value to the business, criticality, and sensitivity to unauthorized disclosure or modification.

2. Scope

This policy applies to all information assets within Eververse, including customer data, intellectual property, operational data, and communications. It covers data stored or processed on our systems and associated third-party services.

The policy is relevant to all employees, contractors, and third parties who manage or interact with Eververse’s data.

3. Information Lifecycle Stages

Information at Eververse is managed throughout the following stages:

Creation/Acquisition: Information is created or acquired from internal processes or external sources (e.g., customer inputs, vendor data).
Storage: Information is securely stored in our databases or other approved storage systems with appropriate encryption and access controls.
Use: Authorized personnel access and use information for legitimate business operations, adhering to least-privilege principles.
Sharing/Distribution: Information may be shared with third parties or other departments based on the appropriate classification level.
Archiving: Information that is no longer actively used but must be retained for legal or business purposes is securely archived.
Deletion/Disposal: Information that has reached the end of its lifecycle is securely deleted or destroyed to prevent unauthorized access.

4. Information Classification

Information at Eververse is classified into the following categories based on legal requirements, business value, criticality, and sensitivity to unauthorized disclosure or modification:

4.1 Public Information

Description: Information intended for public access, such as marketing materials, product documentation, and blog posts.
Legal Requirements: No specific legal protections required.
Value: Low business value.
Criticality: Not critical to operations.
Sensitivity: No sensitivity to unauthorized disclosure or modification.

4.2 Internal Information

Description: Operational data and internal communications intended for use within the company but not public-facing.
Legal Requirements: Basic data protection requirements, but no regulatory or legal restrictions.
Value: Moderate business value.
Criticality: Moderate impact if unavailable.
Sensitivity: Low sensitivity to unauthorized disclosure; moderate sensitivity to unauthorized modification.

4.3 Confidential Information

Description: Sensitive internal data, including customer account details, internal project information, and operational performance data.
Legal Requirements: May be subject to legal or contractual obligations (e.g., non-disclosure agreements).
Value: High business value.
Criticality: Critical for certain operations.
Sensitivity: High sensitivity to unauthorized disclosure or modification. Must be protected from unauthorized access.

4.4 Restricted Information

Description: Highly sensitive information, including customer personally identifiable information (PII), financial data, and proprietary intellectual property.
Legal Requirements: Subject to strict legal regulations, such as GDPR or CCPA, with severe penalties for non-compliance.
Value: Very high business value.
Criticality: Essential for business operations and service delivery.
Sensitivity: Extremely sensitive to unauthorized disclosure or modification. Requires encryption at rest and in transit and must be accessed only by authorized personnel with a clear business need.

5. Legal and Regulatory Requirements

All information classified as Confidential or Restricted must be handled in accordance with applicable legal and regulatory requirements, including but not limited to:

General Data Protection Regulation (GDPR): For the processing and protection of European customer data.
California Consumer Privacy Act (CCPA): For the protection of consumer data from California residents.
Contractual Obligations: Information governed by specific customer or partner contracts must be handled per the terms of those agreements.

6. Information Access and Control

Access to information at Eververse is based on:

Need-to-Know Principle: Access is granted only to employees or third parties who require the information for legitimate business reasons.
Least Privilege: Users are provided with the minimum level of access necessary to perform their duties.
Role-Based Access Control (RBAC): Access is controlled based on predefined roles, ensuring that employees have appropriate access according to their responsibilities.

7. Retention and Archiving

Information must be retained according to the following guidelines:

Public and Internal Information: Retained as long as it serves a business function, then archived or deleted.
Confidential Information: Retained based on business needs or contractual obligations. Once no longer needed, it should be archived securely.
Restricted Information: Retained only for the period required by law or business requirements. Afterward, it must be archived in encrypted form or securely deleted.

Regular reviews of archived data must be performed to ensure compliance with retention policies and legal requirements.

8. Data Deletion and Disposal

When information reaches the end of its lifecycle, it must be securely deleted or disposed of according to the following processes:

Digital Data: Confidential and Restricted data must be securely erased using industry-standard methods (e.g., cryptographic wiping, degaussing).
Physical Media: Any physical media containing sensitive data must be destroyed (e.g., shredding, incineration) to prevent unauthorized recovery.

9. Roles and Responsibilities

Chief Information Security Officer (CISO): Responsible for overseeing the Information Lifecycle Management process, ensuring data is handled according to its classification and legal requirements.
Engineering Team: Ensures that data is properly classified, stored, and protected in Eververse systems.
Compliance Team: Ensures that information handling processes comply with relevant legal and regulatory requirements.
All Employees: Must follow the ILM policy, handle data according to its classification, and report any potential risks related to data handling.

10. Policy Review and Updates

This policy will be reviewed and updated annually, or whenever there are significant changes to legal requirements, business operations, or information management practices.

11. Contact Information

For any questions or clarifications regarding this Information Lifecycle Management Policy, please contact us.