1. Purpose, Scope, and Organization
What is this document, why does it exist, what does it cover, and who is in charge of it?
This policy defines behavioral, process, technical, and governance controls pertaining to security at FullStory that all personnel are required to implement in order to ensure the confidentiality, integrity, and availability of the FullStory service and data (“Policy”). All personnel must review and be familiar with the rules and actions set forth below.
This Policy defines security requirements for:
- all FullStory employees, contractors, consultants and any other third parties providing services to FullStory (“personnel”),
- management of systems, both hardware and software and regardless of locale, used to create, maintain, store, access, process or transmit information on behalf of FullStory, including all systems owned by FullStory, connected to any network controlled by FullStory, or used in service of FullStory’s business, including systems owned third party service providers, and
- circumstances in which FullStory has a legal, contractual, or fiduciary duty to protect data or resources in its custody.
In the event of a conflict, the more restrictive measures apply.
1.1. Governance and Evolution
This Policy was created in close collaboration with and approved by FullStory executives. At least annually, it is reviewed and modified as needed to ensure clarity, sufficiency of scope, concern for customer and personnel interests, and general responsiveness to the evolving security landscape and industry best practices.
Executive point of contact:
Bruce Johnson, Co-Founder and Chief Operating Officer
1.2. Security Team
The FullStory security team oversees the implementation of this Policy, including
- procurement, provisioning, maintenance, retirement, and reclamation of corporate computing resources,
- all aspects of service development and operation related to security, privacy, access, reliability, and survivability,
- ongoing risk assessment, vulnerability management, incident response, and
- security-related human resources controls and personnel training.
Security point of contact:
1.3. Risk Management Framework
The security team maintains a Risk Management Framework derived from NIST SP 800-39 - “Managing Information Security Risk: Organization, Mission, and System View” and NIST SP 800-30 - “Guide for Conducting Risk Assessments”. Risk assessment exercises inform prioritization for ongoing improvements to FullStory’s security posture, which may include changes to this Policy itself.
Our Risk Management Framework incorporates the following:
- Identification of relevant, potential threats.
- A scheme for assessing the strength of implemented controls.
- A scheme for assessing current risks and evaluating their severity.
- A scheme for responding to risks.
2. Personnel and Office Environment
What are FullStory’s expectations of its personnel and the workplace regarding systems and data?
FullStory is committed to protecting its customers, personnel, partners, and the company from illegal or damaging actions by individuals, either knowingly or unknowingly in the context of its established employment culture of openness, trust, maturity, and integrity.
This section outlines expected personnel behaviors affecting security and the acceptable use of computer systems at FullStory. These rules are in place to protect our personnel and FullStory itself, in that inappropriate use may expose customers and partners to risks including malware, viruses, compromise of networked systems and services, and legal issues.
2.1. Work Behaviors
The first line of defense in data security is the informed behavior of personnel, who play a significant role in ensuring the security of all data, regardless of format. Such behaviors include those listed in this section as well as any additional requirements specified in the employee handbook, specific security processes, and other applicable codes of conduct.
All employees and contractors must attend the FullStory security training program, offered at least twice annually, to inform all users of the requirements of this Policy.
Unrecognized Persons and Visitors
It is the responsibility of all personnel to take positive action to maintain physical security. Challenge any unrecognized person present in a restricted office location. Any challenged person who does not respond appropriately should be immediately reported to supervisory staff and the security team. All visitors to FullStory offices must be registered as such or accompanied by a FullStory employee.
Personnel should maintain workspaces clear of sensitive or confidential material and take care to clear workspaces of such material at the end of each workday.
Unattended devices must be locked. All devices will have an automatic screen lock function set to automatically activate upon no more than fifteen minutes of inactivity.
Use of Corporate Assets
Systems are to be used for business purposes in serving the interests of the company, and of our clients and partners in the course of normal business operations. Personnel are responsible for exercising good judgment regarding the reasonableness of personal use of systems. Only FullStory-managed hardware and software is permitted to be connected to or installed on corporate equipment or networks and used to access FullStory data. FullStory-managed hardware and software includes those either owned by FullStory or owned by FullStory personnel but enrolled in a FullStory device management system. Only software that has been approved for corporate use by FullStory may be installed on corporate equipment. All personnel must read and understand the list of prohibited activities outlined in this Policy. Modifications or configuration changes are not permitted without explicit written consent by the FullStory security team.
No Backups, Use of Cloud Storage
Personnel may not configure work devices to make backups of device data. Instead, personnel are expected to operate primarily “in the cloud” and treat local storage on computing devices as ephemeral. Making a practice of keeping important work artifacts replicated into company-approved secure cloud storage (e.g. Google Docs) ensures that even in the event of a corporate device being lost, stolen, or damaged, such work artifacts will be immediately recoverable on a replacement device.
The following activities are prohibited. Under certain conditions and with the explicit written consent of the security team, personnel may be exempted from certain of these restrictions during the course of their legitimate job responsibilities (e.g. planned penetration testing, systems administration staff may have a need to disable the network access of a host if that host is disrupting production services).
The list below is by no means exhaustive, but attempts to provide a framework for activities which fall into the category of unacceptable use.
- Under no circumstances are personnel of FullStory authorized to engage in any activity that is illegal under local, state, federal or international law while utilizing FullStory-owned resources.
- Violations of the rights of any person or company protected by copyright, trade secret, patent or other intellectual property, or similar laws or regulations including, but not limited to, the installation or distribution of "pirated" or other software products that are not appropriately licensed for use by FullStory.
- Unauthorized copying of copyrighted material including, but not limited to, digitization and distribution of photographs from magazines, books or other copyrighted sources, copyrighted music, and the installation of any copyrighted software for which FullStory or the end user does not have an active license is strictly prohibited.
- Exporting software, technical information, encryption software or technology may result in a violation of international or regional export control laws. The appropriate management should be consulted prior to export of any material that is in question.
- Revealing your account password to others or allowing use of your account by others. This includes colleagues, as well as family and other household members when work is being done at home.
- Making fraudulent offers of products, items, or services originating from any FullStory account.
- Making statements about warranty, expressly or implied, unless it is a part of normal job duties and then only to the extent the warranties are consistent with FullStory’s authorized warranties.
- Introduction of malicious programs into the network or server (e.g., viruses, worms, Trojan horses, e-mail bombs, etc.).
- Effecting security breaches or disruptions of network communication. Security breaches include, but are not limited to, accessing data of which the employee is not an intended recipient or logging into a server or account that the employee is not expressly authorized to access. For purposes of this section, "disruption" includes, but is not limited to, network sniffing, ping floods, packet spoofing, denial of service, and forged routing information for malicious or unlawful purposes.
- Except by or under the direct supervision of the security team, port scanning or security scanning, or other such software designed to exploit or find computer, software, or network vulnerabilities.
- Executing any form of network monitoring which will intercept data not intended for the employee’s host, unless this activity is a part of the employee’s normal job/duty.
- Circumventing user authentication or security of any host, network or account or attempting to break into an information resource or to bypass a security feature. This includes running password-cracking programs or sniffer programs, and attempting to circumvent file or other resource permissions.
- Attempting to interfere with or deny service to any other user.
- Providing information about, or lists of, FullStory personnel to parties outside FullStory.
- Installation of software which installs or includes any form of malware, spyware, or adware as defined by the security team.
- Crashing an information system. Deliberately crashing an information system is strictly prohibited. Users may not realize that they caused a system crash, but if it is shown that the crash occurred as a result of user action, a repetition of the action by that user may be viewed as a deliberate act.
- Attempts to subvert technologies used to effect system configuration of company-managed devices (e.g. MDM) or personal devices voluntarily used for company purposes (e.g. mobile Work Profiles).
2.2. Personnel Systems Configuration, Ownership, and Privacy
Centralized System Configuration
Personnel devices and their software configuration may be managed remotely by members of the security team via configuration-enforcement technology. Such technology may be used for purposes including auditing/installing/removing software applications or system services, managing network configuration, enforcing password policy, encrypting disks, copying data files to/from employee devices, and any other allowed interaction to ensure that employee devices comply with this Policy.
Retention of Ownership
All software programs, data, and documentation generated or provided by personnel while providing services to FullStory or for the benefit of FullStory are the property of FullStory unless otherwise covered by a contractual agreement.
While FullStory’s network administration desires to provide a reasonable level of privacy, users should be aware that the data they create on the corporate systems remains the property of FullStory. Due to the need to protect FullStory’s network, management does not intend to guarantee the privacy of personnel’s personal information stored on any network device belonging to FullStory. Personnel are responsible for exercising good judgment regarding the reasonableness of personal use such as general web browsing or personal email. If there is any uncertainty, personnel should consult the security team or their manager.
Personnel should structure all electronic communication with recognition of the fact that the content could be monitored and that any electronic communication could be forwarded, intercepted, printed, or stored by others.
FullStory reserves the right, at its discretion, to review personnel’s files or electronic communications to the extent necessary to ensure all electronic media and services are used in compliance with all applicable laws and regulations as well as corporate policies.
FullStory reserves the right to audit networks and systems on a periodic basis to ensure compliance with this policy. For security and network maintenance purposes, authorized individuals within FullStory may monitor equipment, systems and network traffic at any time.
2.3. Human Resources Practices
Background checks are conducted on all employees prior to their start date. The consequences of problematic background check results may range from a limitation of security privileges, to revocation of employment offer, to termination.
The security team maintains a company-wide security awareness program delivered to all personnel at least annually. The program covers security awareness, policies, processes, and training to ensure that personnel are sufficiently informed to meet their obligations. Those most responsible for maintaining security at FullStory, including the security team itself as well as key engineering/operations staff, undergo more technical continuing education.
In the case of personnel termination or resignation, the security team coordinates with human resources to implement a standardized separation process to ensure that all accounts, credentials, and access of outgoing employees are reliably disabled.
2.4. Physical Office Environment
Access to FullStory offices is mediated by an electronic control system that provides for identity-aware entrance, programmable control over access time of day, and audits of use. All doors shall remain locked at all times under normal business conditions. The security team may provide approval to unlock doors for short periods of time in order to accommodate extenuating physical access needs.
Internet-based security cameras are positioned to record time-stamped video of ingress/egress, which are stored off-site.
2.5. Office Network
Internet access shall be provided to devices via wired ethernet and WPA2 wifi. Networking switches and routers shall be placed in a locked networking closet with only the security team having access. FullStory executives and the security team may grant access to the networking closet to individuals on a case-by-case and as-needed basis. A network firewall that blocks all WAN-sourced traffic shall be put in place. WAN-accessible network services shall not be hosted within the office environment.
3. Personnel Identity and Access Management
How does FullStory define, control, and maintain user identity and permissions for personnel?
3.1. User Accounts and Authentication
Each individual having access to any FullStory-controlled system does so via a G Suite user account denoting their system identity. Such user accounts are required to have a unique username, strong password of at least 8 characters, and two-factor authentication (2FA) mechanism.
Logging into FullStory Systems
Logins by personnel may originate only from FullStory-managed devices. Authentication is performed by Google’s account management system, details of which can be found at https://gsuite.google.com/security. FullStory leverages G Suite’s facilities of detecting malicious authentication attempts. Repeated failed attempts to authenticate may result in the offending user account being locked or revoked.
Logging into Third Party Systems
Whenever available, third-party systems must be configured to delegate authentication to FullStory’s G Suite account authentication system (described above) thereby consolidating authentication controls into a single user account system that is centrally managed by the security team.
Revocation and Auditing of User Accounts
User accounts are revoked (that is, disabled but not deleted) immediately upon personnel separation. As a further precaution, all user accounts are audited at least quarterly, and any inactive user accounts are revoked.
3.2. Access Management
FullStory adheres to the principle of least privilege, and every action attempted by a user account is subject to access control checks.
Role-based Access Control
FullStory employs a role-based access control (RBAC) model utilizing Google-supplied facilities such as organizational units, user accounts, user groups, and sharing controls.
Web Browsers and Extensions
FullStory may require use of a specified web browser(s) for normal business use and for access to corporate data such as email. For certain specified roles such as software development and web design, job activities beyond those mentioned above necessitate the use of a variety of browsers, and these roles may do so as needed for those activities.
Any browser that is allowed to access corporate data such as email is subject to a whitelist-based restriction on the which browser extensions can be installed.
Access to administrative operations is strictly limited to security team members and further restricted still as a function of tenure and the principle of least privilege.
Access control policies are reviewed regularly with the goal of reducing or refining access whenever possible. Changes in job function by personnel trigger an access review as well.
Upon termination of personnel, whether voluntary or involuntary, the security team will follow FullStory’s personnel exit procedure, which includes revocation of the associated user account and reclamation of company-owned devices, office keys or access cards, and all other corporate equipment and property prior to the final day of employment.
4. Provenance of Technology
How does FullStory build, adopt, configure, and maintain technology to fulfill its security intentions?
4.1. Software Development
FullStory stores source code and configuration files in private GitHub repositories. The security and development teams conduct code reviews and execute a static code analysis tools on every code commit. Reviewers shall check for compliance with FullStory’s conventions and style, potential bugs, potential performance issues, and that the commit is bounded to only its intended purpose.
Security reviews shall be conducted on every code commit to security-sensitive modules. Such modules include those that pertain directly to authentication, authorization, access control, auditing, and encryption.
All major pieces of incorporated open source software libraries and tools shall be reviewed for robustness, stability, performance, security, and maintainability.
The security and development teams shall establish and adhere to a formal software release process.
4.2. Configuration and Change Management
The FullStory security and development teams shall document the configuration of all adopted systems and services, whether hosted by FullStory or are third party hosted. Industry best practices and vendor-specific guidance shall be identified and incorporated into system configurations. All configurations shall be reviewed on at least an annual basis. Any changes to configurations must be approved by appointed individuals and documented in a timely fashion.
System configurations must address the following controls in a risk-based fashion and in accordance with the remainder of this policy:
- data-at-rest protection encryption
- data-in-transit protection of confidentiality, authenticity, and integrity for incoming and outgoing data
- data and file integrity
- malware detection and resolution
- capturing event logs
- authentication of administrative users
- access control enforcement
- removal or disabling of unnecessary software and configurations
- allocation of sufficient hardware resources to support loads that are expected at least twelve months into the future.
4.3. Third Party Services
For every third-party service that FullStory adopts, the security team shall review the service and vendor, on an annual basis, to gain assurance that their security posture is consistent with FullStory’s for the type and sensitivity of data the service will store.
5. Data Classification and Processing
How does FullStory manage data classifications and data processing?
5.1. Data Classification
FullStory maintains the following classes and processing rules of customer data. For each data class, the FullStory security and development teams must provision and dedicate specific information systems in Google Cloud Platform to store and process data of that class, and only data of that class, unless otherwise explicitly stated throughout Section 5. For all classes of customer data, the corresponding systems may store and process data items needed to keep each customer’s data properly segmented, such as FullStory customer identifiers.
Customer User Account Data - This is data pertaining to login accounts for the www.fullstory.com customer web interface, used by FullStory customer agents. This data shall be encrypted-at-rest so as to protect the data in the event of unauthorized access attempts. User account credentials shall be hashed in such a manner that the plaintext passwords cannot be recovered.
Customer Contact Data - This is contact data about FullStory customers and customer agents.
Customer Preferences Data - This is data pertaining to the customer-specific preferences and configurations of the FullStory service made by customer agents.
Customer Recorded Data - This is data that the FullStory service collects during session recording. The FullStory security and development teams must provision specific systems within Google Cloud Platform to store and process this class of data. This data shall be encrypted-at-rest so as to protect the data in the event of unauthorized access attempts.
Customer Event Transaction Metadata - This is metadata about transactions conducted on all other classes of customer data. This includes customer organization and user identifiers, standard syslog data pertaining to customer users, and instances of Customer Contact Data and Customer Preferences Data. This class does not include Customer Recorded Data.
Customer Contact Data, Customer Preferences Data, and Customer Event Transaction Metadata may be stored and processed in systems hosted in environments other than Google Cloud Platform, as approved by the security team.
5.2. FullStory Employee Access to Customer Data
FullStory employees may access Customer Data only under the following conditions.
- From managed devices.
- For the purpose of incident response, customer support, or feature testing.
- For the no longer than is needed to fulfill the purpose of access.
- In an auditable manner.
5.3. Customer Access
FullStory provides web user interfaces (UIs), application programming interfaces (APIs), and data export facilities to provide customers access to their data.
5.4. Exceptional Cases
The security team in conjunction with executive management may approve emergency exceptions to any of the above rules, in response to security incidents, service outages, or significant changes to the FullStory operating environment, when it is deemed that such exceptions will benefit and protect the security and mission of FullStory, FullStory customers, and visitors of FullStory customers’ websites.
6. Vulnerability and Incident Management
How does FullStory detect, and respond to vulnerabilities and security incidents?
6.1. Vulnerability Detection and Response
The FullStory security and development teams shall use all of the following measures to detect vulnerabilities that may arise in FullStory’s information systems.
- Cross-checking vulnerability databases with all systems and software packages that support critical FullStory services.
- Automated source code scanners on every code commit.
- Code reviews on every security-sensitive code commit.
- Vulnerability scanning on FullStory services.
- Maintain a bug bounty program.
- Annual penetration testing with an independent provider.
The FullStory security team shall evaluate the severity of every detected vulnerability in terms of the likelihood and potential impact of an exploit, and shall develop mitigation strategies and schedules accordingly. Suitable mitigations include complete remediation or implementing compensating controls.
6.2. Incident Detection and Response
The FullStory security team shall use all of the following measures to detect security incidents.
- Monitor logs to detect potentially malicious or unauthorized activity.
- Conduct reviews on the causes of any service outages.
- Respond to notices of potential incidents from employees, contractors, or external parties.
The FullStory security team shall make a determination of whether every indicator is representative of an actual security incident. The severity, scope, and root cause of every incident shall be evaluated, and every incident shall be resolved in a manner and timeframe commensurate with the severity and scope.
In the event that a data breach affecting a customer has been detected, FullStory will maintain communication with the customer about the severity, scope, root cause, and resolution of the breach.
7. Business Continuity and Disaster Recovery
How will FullStory prevent and recover from events that could interfere with expected operations?
FullStory services hosted in Google Cloud Platform (GCP) shall be configured in such a manner so as to withstand long-term outages to a GCP Availability Zone. Controls such as automated replication or automated data recovery processes may be used to achieve this desired level of availability.