Operations, Security & Data privacy
Last updated 4 May 2018
Pearson Global Information Security
- Pearson has implemented a set of global information security policies.
- These policies are based on the ISO-27001 information security norm.
- The list of policies implemented and enforced globally can be found at the end of this document.
- These policies are owned by the Chief Information Security Officer (CISO).
- They are subject to annual review.
- Global implementation of these policies by respective controls are formally defined by a set of Security Standards and Guidelines. These are directly based on the ISO-27002 framework and take into account security best practises as defined in the NIST recommendations.
- Local implementation of our policies and controls in the Netherlands is governed by the local Information Security Management System (ISMS).
- An ISMS review and risk assessment is conducted annually by the local Management Review team. This is under supervision of the Regional Information Security Officer (RISO) for our Core region (which includes Europe).
- Under direct control of the CISO office is the dedicated Security Operations Control group (SOC). This group continuously monitors our infrastructure on security threats and manages incidents as they arise.
Data Privacy & GDPR
- Pearson is engaged in implementing a programme to ensure compliance of its organisation and products with the General Data Protection Regulation ( GDPR).
- Pearson is the data processor for the purposes of the GDPR of all personal data perspective.
- Pearson will fully cooperate with clients to let them fulfill their obligations as the data controller under GDPR.
- Pearson will formally enforce compliance by all of its vendors to these obligations (sub-processors in the definition of GDPR).
- Our Data Privacy Officer is currently based in the UK. By the time GDPR comes into effect we will however have a Data Privacy Officer based in Continental Europe, within the Union.
PAN Platform (Pearson Online) – Subprocessor
- The PAN platform is owned by Performance Assessment Network, Inc.
- In terms of the GDPR, PAN is the subprocessor for the data processing
- Pearson uses a so called ‘White-label’ version of the platform called Pearson Online
- Pearson Online is hosted from Ireland on Microsoft Azure Cloud.
- System administration and database management is operated from the UK by a local PAN office.
- This complies to current and upcoming data privacy regulations throughout Europe
- There is no transfer of personal data to third countries like the US. All personal data is kept in the EU and not accessed from the outside of it
- Management of customer accounts is managed by a central European customer support team.
- Temporary elevated authorisations to access personal information in the platform is only given to a small group of admins within Pearson European team and requires management approval when an incident occurs.
- Daily management over the customer account and authorizations to access personal data is carried out by the customer. Pearson will never access clients personal data without any upfront formal authorizations by the client.
- Compliance to both the Pearson Information Security and Data Privacy policies and controls as well as the obligations under GDPR are enforced via a formal agreement between Pearson and PAN
ISO-27001 based Global Information Security Management Policies
- 5 Information Security Policies
- 6 Organization of Information security
- 7 Human Resources Security
- 8 Asset Management
- 9 Access Control
- 10 Cryptography
- 11 Physical and Environmental Security
- 12 Operations Security
- 13 Communications Security
- 14 System Acquisition, Development and Maintenance
- 15 Supplier Relationships
- 16 Information Security Incident Management
- 17 Information Security Aspects of Business Continuity Management
- 18 Compliance