Information Security Policy

Protecting Your Data with Industry-Leading Security

Last Updated: November 2025

Our Commitment to Security

At ClearLedger, we understand that your financial data is among your most sensitive information. This Information Security Policy outlines our comprehensive approach to protecting your data through robust technical controls, rigorous operational procedures, and ongoing security improvements. We are committed to maintaining the highest standards of information security across all our bookkeeping and financial services.

1. Overview and Purpose

This Information Security Policy establishes Clear Ledger's commitment to protecting the confidentiality, integrity, and availability of all information assets entrusted to us by our clients, partners, and stakeholders.

Policy Objectives

  • Protect Client Data: Safeguard all financial and personal information from unauthorized access, disclosure, or destruction
  • Ensure Compliance: Meet all Australian regulatory requirements including the Privacy Act 1988, Australian Privacy Principles (APPs), and relevant financial services regulations
  • Maintain Trust: Build and maintain client confidence through transparent security practices
  • Business Continuity: Ensure operational resilience and data availability
  • Continuous Improvement: Regularly assess and enhance our security posture

Scope

This policy applies to:

  • All Clear Ledger employees, contractors, and authorized third parties
  • All information systems, networks, and data storage facilities
  • All client data, including financial records, personal information, and business documentation
  • Physical and digital assets used in service delivery
  • Cloud-based services and third-party integrations

2. Core Security Principles

Confidentiality

Information is accessible only to authorized individuals through strict access controls, encryption, and secure authentication protocols.

Integrity

Data accuracy and completeness are maintained through validation checks, audit trails, and protection against unauthorized modification.

Availability

Systems and data are accessible to authorized users when needed through redundancy, backup systems, and disaster recovery planning.

3. Data Protection Measures

3.1 Encryption Standards

We employ industry-standard encryption to protect your data:

  • Data in Transit: All data transmitted between your devices and our servers is encrypted using TLS 1.3 or higher protocols
  • Data at Rest: All stored data is encrypted using AES-256 encryption standards
  • Database Encryption: Database-level encryption for all client financial records
  • Backup Encryption: All backup data is encrypted before storage

3.2 Access Control

Strict access controls ensure only authorized personnel can access client data:

  • Multi-Factor Authentication (MFA): Required for all staff accessing client systems
  • Role-Based Access Control (RBAC): Staff access limited to information necessary for their role
  • Least Privilege Principle: Minimal access rights granted by default
  • Regular Access Reviews: Quarterly audits of user access privileges
  • Immediate Revocation: Access removed within 2 hours of employment termination

3.3 Secure Authentication

  • Strong password requirements (minimum 12 characters, complexity rules)
  • Password rotation policies (changed every 90 days)
  • Account lockout after failed login attempts
  • Session timeout after periods of inactivity
  • Secure password storage using industry-standard hashing algorithms

3.4 Data Classification

We classify data based on sensitivity to apply appropriate security controls:

  • Highly Confidential: Financial records, tax information, bank account details
  • Confidential: Business plans, strategic documents, client communications
  • Internal Use: Internal documentation, operational procedures
  • Public: Marketing materials, publicly available information

4. Network and Infrastructure Security

4.1 Network Protection

  • Firewalls: Next-generation firewalls protecting all network perimeters
  • Intrusion Detection/Prevention: 24/7 monitoring for suspicious network activity
  • Network Segmentation: Logical separation of client data and internal systems
  • VPN Requirements: Mandatory for remote access to internal systems
  • Wireless Security: WPA3 encryption for all wireless networks

4.2 Cloud Security

For cloud-based services and data storage:

  • Australian-based data centers with ISO 27001 certification
  • Geo-redundancy across multiple Australian availability zones
  • Regular security assessments of cloud service providers
  • Contractual data protection requirements for all cloud vendors
  • Data residency compliance ensuring data stays within Australia

4.3 Physical Security

  • Secure office premises with controlled access
  • CCTV surveillance of sensitive areas
  • Visitor logging and escort procedures
  • Secure disposal of physical documents (cross-cut shredding)
  • Clean desk policy for all workstations

Data Residency Commitment: All client data is stored exclusively within Australian data centers, ensuring compliance with Australian data sovereignty requirements and providing enhanced protection under Australian privacy laws.

5. Operational Security Procedures

5.1 Secure Development Practices

  • Secure coding standards and guidelines
  • Code review processes before deployment
  • Regular security testing and vulnerability assessments
  • Penetration testing by independent security experts annually
  • Secure software development lifecycle (SDLC)

5.2 Change Management

  • Formal change approval process for all system modifications
  • Security impact assessments for changes
  • Testing in non-production environments
  • Rollback procedures for all changes
  • Documentation of all system changes

5.3 Vulnerability Management

  • Weekly automated vulnerability scans
  • Patch management program with priority-based deployment
  • Critical security patches applied within 48 hours
  • Regular security updates for all systems and applications
  • Third-party security assessments

5.4 Logging and Monitoring

  • Comprehensive logging of system access and activities
  • Real-time security monitoring and alerting
  • Log retention for minimum 12 months
  • Regular log review and analysis
  • Security Information and Event Management (SIEM) system

6. Backup and Business Continuity

6.1 Backup Procedures

  • Daily Backups: Automated daily backups of all client data
  • Incremental Backups: Continuous incremental backups throughout the day
  • Multiple Locations: Backups stored in geographically separate Australian data centers
  • Backup Encryption: All backups encrypted at rest and in transit
  • Backup Testing: Monthly restoration tests to verify backup integrity
  • Retention Period: Minimum 7-year retention for financial records

6.2 Disaster Recovery

  • Documented disaster recovery plan tested annually
  • Recovery Time Objective (RTO): 4 hours for critical systems
  • Recovery Point Objective (RPO): Maximum 1 hour of data loss
  • Failover capabilities to backup systems
  • Alternative work arrangements for staff

6.3 Business Continuity

  • Comprehensive business continuity plan
  • Redundant systems and infrastructure
  • Alternative communication channels
  • Staff training on emergency procedures
  • Regular plan reviews and updates

7. Third-Party and Vendor Management

7.1 Vendor Security Assessment

  • Security due diligence for all new vendors
  • Review of vendor security certifications (ISO 27001, SOC 2)
  • Contractual security requirements
  • Regular vendor security audits
  • Vendor risk assessments and ratings

7.2 Third-Party Access

  • Minimal access principle for third-party vendors
  • Time-limited access credentials
  • Monitoring of third-party activities
  • Non-disclosure agreements (NDAs) required
  • Right to audit third-party security practices

7.3 Software and Tool Security

We carefully select and monitor third-party software:

  • Approved software list for business use
  • Security assessment of all new applications
  • Regular updates and patch management
  • License compliance monitoring
  • Prohibition of unauthorized shadow IT

8. Staff Security and Training

8.1 Security Awareness Training

  • Onboarding Training: Mandatory security training for all new employees
  • Annual Refresher: Yearly security awareness training
  • Phishing Simulations: Regular testing to identify vulnerabilities
  • Security Updates: Monthly security bulletins and updates
  • Incident Response Training: Procedures for reporting security concerns

8.2 Background Checks

  • Police checks for all staff with client data access
  • Reference verification
  • Professional qualification verification
  • Ongoing monitoring where appropriate

8.3 Acceptable Use Policy

  • Clear guidelines on acceptable use of company systems
  • Prohibition of unauthorized software installation
  • Personal device usage policies (BYOD)
  • Social media and communication guidelines
  • Consequences for policy violations

8.4 Confidentiality Obligations

  • Signed confidentiality agreements for all staff
  • Non-disclosure obligations extending beyond employment
  • Clear data handling procedures
  • Prohibition of unauthorized data disclosure

9. Security Incident Management

9.1 Incident Response Plan

We maintain a comprehensive incident response plan covering:

  • Detection: Monitoring systems for security incidents
  • Classification: Severity assessment and categorization
  • Containment: Immediate actions to limit impact
  • Investigation: Root cause analysis
  • Resolution: Remediation and recovery
  • Communication: Notification of affected parties
  • Post-Incident Review: Lessons learned and improvements

9.2 Incident Response Team

  • Designated incident response coordinator
  • 24/7 security incident response capability
  • Escalation procedures for critical incidents
  • Contact information for emergency response

9.3 Data Breach Notification

In the event of a data breach:

  • Immediate assessment of breach scope and impact
  • Notification to affected clients within 72 hours
  • Notification to Office of the Australian Information Commissioner (OAIC) if required
  • Transparent communication about breach details
  • Remediation steps and support for affected clients
  • Post-breach security enhancements

Report Security Concerns: If you suspect a security incident or have concerns about the security of your data, please contact us immediately at [email protected] or call 1300 CLEAR 1 (1300 253 271).

10. Compliance and Regular Auditing

10.1 Regulatory Compliance

We maintain compliance with all relevant Australian regulations:

  • Privacy Act 1988: Australian Privacy Principles (APPs) compliance
  • Notifiable Data Breaches (NDB) Scheme: Breach notification requirements
  • Tax Agent Services Act 2009: Professional standards and obligations
  • Anti-Money Laundering/Counter-Terrorism Financing: AML/CTF compliance
  • Australian Consumer Law: Consumer protection requirements

10.2 Security Audits

  • Internal Audits: Quarterly internal security assessments
  • External Audits: Annual independent security audits
  • Penetration Testing: Annual third-party penetration testing
  • Compliance Audits: Regular privacy and data protection compliance reviews
  • Risk Assessments: Semi-annual comprehensive risk assessments

10.3 Security Certifications

We are committed to achieving and maintaining industry-recognized security certifications:

  • ISO 27001 Information Security Management (in progress)
  • Australian Privacy Principles compliance verification
  • SOC 2 Type II compliance (planned)
  • Regular certification renewals and updates

10.4 Documentation and Records

  • Comprehensive security documentation maintained
  • Security policy version control
  • Audit trail of all security-related activities
  • Incident records and response documentation
  • Training and awareness records

11. Client Security Responsibilities

While we implement robust security measures, effective information security requires partnership with our clients. We ask that you:

11.1 Account Security

  • Keep login credentials confidential and secure
  • Use strong, unique passwords for your ClearLedger account
  • Enable multi-factor authentication when available
  • Never share account access with unauthorized individuals
  • Report suspected unauthorized access immediately
  • Log out when using shared or public computers

11.2 Communication Security

  • Verify the authenticity of emails claiming to be from ClearLedger
  • Do not click on suspicious links or download unexpected attachments
  • Use secure methods when sharing sensitive information
  • Report phishing attempts or suspicious communications

11.3 Document Security

  • Securely store physical documents containing financial information
  • Properly dispose of sensitive documents (shredding)
  • Use encrypted transmission when sending documents electronically
  • Verify recipient details before sending sensitive information

11.4 Device Security

  • Keep devices used to access ClearLedger services updated
  • Install and maintain current antivirus software
  • Secure devices with passwords or biometric authentication
  • Avoid accessing ClearLedger from public Wi-Fi without VPN
  • Report lost or stolen devices that had access to your account

12. Your Privacy Rights

Under the Australian Privacy Principles, you have important rights regarding your personal information:

12.1 Access and Correction

  • Request access to your personal information we hold
  • Request correction of inaccurate or outdated information
  • Receive information in a structured, commonly used format
  • Response to access requests within 30 days

12.2 Data Portability

  • Request export of your data in common formats
  • Transfer data to another service provider
  • Receive copies of documents and records

12.3 Deletion and Retention

  • Request deletion of personal information (subject to legal obligations)
  • Understand our data retention policies
  • 7-year minimum retention for financial records as required by Australian tax law

12.4 Marketing and Communications

  • Opt-out of marketing communications at any time
  • Update communication preferences
  • Receive only essential service communications if preferred

Exercise Your Rights: To exercise any of your privacy rights, please contact our Privacy Officer at [email protected] or use the contact details provided at the end of this policy.

13. Policy Review and Continuous Improvement

13.1 Regular Reviews

This Information Security Policy is reviewed and updated:

  • At least annually as part of our scheduled review cycle
  • Following significant security incidents
  • When regulatory requirements change
  • When business operations or technology significantly change
  • Based on emerging security threats and trends

13.2 Continuous Improvement

We are committed to continuously improving our security posture through:

  • Regular security assessments and risk analyses
  • Monitoring emerging security threats and vulnerabilities
  • Implementing industry best practices
  • Learning from security incidents and near-misses
  • Incorporating feedback from audits and assessments
  • Staying informed about regulatory changes

13.3 Version Control

  • Current Version: 2.1
  • Effective Date: November 1, 2025
  • Last Reviewed: November 2025
  • Next Review Date: November 2026
  • Document Owner: Chief Information Security Officer

13.4 Change Notification

When we make material changes to this policy, we will:

  • Notify clients via email of significant changes
  • Post updates on our website with change highlights
  • Maintain previous versions for reference
  • Allow reasonable time for review before implementation

14. Contact Information

Security and Privacy Contacts

General Security Inquiries

Email: [email protected]
Phone: 1300 CLEAR 1 (1300 253 271)
Response Time: Within 24 hours for non-urgent matters

Privacy Officer

Email: [email protected]
Phone: 1300 CLEAR 1 (1300 253 271)
Response Time: Within 5 business days

Security Incidents (24/7 Emergency)

Email: [email protected]
Emergency Phone: 1300 CLEAR 1 (1300 253 271) - Select Option 9
Response Time: Immediate acknowledgment, investigation within 1 hour

Postal Address

Clear Ledger Pty Ltd
Attention: Security & Privacy Team
[Your Street Address]
[Your Suburb, State, Postcode]
Australia

Office of the Australian Information Commissioner

If you are not satisfied with our handling of your privacy concerns, you may contact:

Office of the Australian Information Commissioner (OAIC)
Website: www.oaic.gov.au
Phone: 1300 363 992
Email: [email protected]

Related Policies and Documents

This Information Security Policy should be read in conjunction with our other policies:

Questions About Our Security Practices?

Our team is here to answer any questions about how we protect your data and maintain the security of your financial information.

Contact Our Security Team

Acknowledgment: By using Clear Ledger's services, you acknowledge that you have read, understood, and agree to be bound by this Information Security Policy. We are committed to protecting your information and maintaining your trust through rigorous security practices and transparent communication.