Lavanda Information Security
Last updated August, 2022
Lavanda is a cloud based software-as-a-service application used by companies of all sizes to manage property inventory. Our platform is engineered specifically to facilitate the management of all aspects of hospitality services in residential real estate including distribution, reservations, operations, guest and resident communications.
The Lavanda platform is engineered to the highest standards to ensure the protection of our information assets and our clients and partner information assets. The Directors and management of Lavanda are committed to preserving the confidentiality, integrity and availability of all the physical and electronic information assets throughout their organisation in order to preserve its competitive edge, cash-flow, profitability, legal, regulatory and contractual compliance and commercial image.
Lavanda’s data and systems are managed under and information security management system (ISMS) – a set of policies and procedures for systematically managing our sensitive data. Information and information security requirements will continue to be aligned with Lavanda’s goals and the ISMS is intended to be an enabling mechanism for information sharing, for electronic operations and for reducing information-related risks to acceptable levels.
Lavanda’s current strategic business plan and risk management framework provide the context for identifying, assessing, evaluating and controlling information-related risks through the establishment and maintenance of our ISMS. The Risk Assessment, Statement of Applicability and Risk Treatment Plan identify how information-related risks are controlled. The Senior Management Team is responsible for the management and maintenance of the risk treatment plan. Additional risk assessments may, where necessary, be carried out to determine appropriate controls for specific risks.
In particular, business continuity and contingency plans, data backup procedures, avoidance of viruses and hackers, access control to systems and information security incident reporting are fundamental to this policy.
All employees of Lavanda and certain external parties identified in the ISMS are expected to comply with this policy and with the ISMS that implements this policy. All employees, and certain external parties, will receive appropriate training. The consequences of breaching the information security policy are set out in Lavanda’s disciplinary policy and in contracts and agreements with third parties.
The ISMS is subject to continuous, systematic review and improvement.
In this policy, ‘information security’ is defined as:
This means that management, all full time or part time employees, sub-contractors, project consultants and any external parties have, and will be made aware of, their responsibilities (which are defined in their job descriptions or contracts) to preserve information security, to report security breaches (in line with the policy and procedures identified in Section 16 of the Manual) and to act in accordance with the requirements of the ISMS. All employees will receive information security awareness training and more specialised employees will receive appropriately specialised information security training.
This means that information and associated assets should be accessible to authorised users when required and therefore physically secure. The computer network must be resilient and Lavanda must be able to respond rapidly to incidents (such as viruses and other malware) that threaten the continued availability of assets, systems and information.
This involves ensuring that information is only accessible to those authorised to access it and therefore to preventing both deliberate and accidental unauthorised access to Lavanda’s information and proprietary knowledge and its systems.
This involves safeguarding the accuracy and completeness of information and processing methods, and therefore requires preventing deliberate or accidental, partial or complete, destruction or unauthorised modification, of either physical assets or electronic data. There must be appropriate contingency and data backup plans and security incident reporting. Lavanda must comply with all relevant data-related legislation in those jurisdictions within which it operates, including the GDPR.
of the physical (assets)
The physical assets of Lavanda including, but not limited to, computer hardware, data cabling, telephone systems, filing systems and physical data files.
and information assets
The information assets include information printed or written on paper, transmitted by post or shown in films, or spoken in conversation, as well as information stored electronically on servers, website(s), extranet(s), intranet(s), PCs, laptops, mobile phones and any other digital or magnetic media, and information transmitted electronically by any means. In this context, ‘data’ also includes the sets of instructions that tell the system(s) how to manipulate information (i.e. the software: operating systems, applications, utilities, etc).
Lavanda’s applications and data are hosted on Heroku’s physical infrastructure which is hosted and managed within Amazon’s secure data centers and utilize the Amazon Web Service (AWS) technology. Amazon continually manages risk and undergoes recurring assessments to ensure compliance with industry standards. Amazon’s data center operations have been accredited under:
- ISO 27001
- SOC 1 and SOC 2/SSAE 16/ISAE 3402 (Previously SAS 70 Type II)
- PCI Level 1
- FISMA Moderate
- Sarbanes-Oxley (SOX)
Lavanda uses PCI compliant payment processing services provided by Stripe and Spreedly for encrypting and processing credit card payments. Lavanda’s infrastructure provider is PCI level 1 compliant. Lavanda ourselves attest PCI compliance under PCI SAQ-A.
Lavanda is committed to achieving certification of its ISMS to ISO27001:2013.
Penetration Testing and Vulnerability Assessments
Security testing of the Lavanda PMS application is performed internally using automated penetration testing techniques. Lavanda is committed to transitioning to a programme of regular third party penetration testing by independent and reputable security consulting firms. Findings from each assessment will be reviewed with the assessors, risk ranked, and assigned to the responsible team.
Lavanda applications and data, including client data are hosted in ISO 27001 and FISMA certified data centers managed by Amazon. Amazon has many years of experience in designing, constructing, and operating large-scale data centers. This experience has been applied to the AWS platform and infrastructure. AWS data centers are housed in nondescript facilities, and critical facilities have extensive setback and military grade perimeter control berms as well as other natural boundary protection. Physical access is strictly controlled both at the perimeter and at building ingress points by professional security staff using video surveillance, state-of-the-art intrusion detection systems, and other electronic means. Authorized staff must pass two-factor authentication no fewer than three times to access data center floors. All visitors and contractors are required to present identification and are signed in and continually escorted by authorized staff.
Amazon only provides data center access and information to employees who have a legitimate business need for such privileges. When an employee no longer has a business need for these privileges, his or her access is immediately revoked, even if they continue to be an employee of Amazon or Amazon Web Services. All physical and electronic access to data centers by Amazon employees is logged and audited routinely.
For additional information see: https://aws.amazon.com/security
Fire Detection and Suppression
Automatic fire detection and suppression equipment has been installed to reduce risk. The fire detection system utilizes smoke detection sensors in all data center environments, mechanical and electrical infrastructure spaces, chiller rooms and generator equipment rooms. These areas are protected by either wet-pipe, double-interlocked pre-action, or gaseous sprinkler systems.
The data center electrical power systems are designed to be fully redundant and maintainable without impact to operations, 24 hours a day, and seven days a week. Uninterruptible Power Supply (UPS) units provide back-up power in the event of an electrical failure for critical and essential loads in the facility. Data centers use generators to provide backup power for the entire facility.
Climate and Temperature Control
Climate control is required to maintain a constant operating temperature for servers and other hardware, which prevents overheating and reduces the possibility of service outages. Data centers are conditioned to maintain atmospheric conditions at optimal levels. Monitoring systems and data center personnel ensure temperature and humidity are at the appropriate levels.
Data center staff monitor electrical, mechanical and life support systems and equipment so issues are immediately identified. Preventative maintenance is performed to maintain the continued operability of equipment.
For additional information see: https://aws.amazon.com/security
Firewalls are used to restrict access to systems from external networks and between systems internally. By default, all access is denied and only explicitly allowed ports and protocols are allowed based on business need. Each system is assigned to a firewall security group based on the system’s function. Security groups restrict access to only the ports and protocols required for a system’s specific function to mitigate risk.
Host-based firewalls restrict customer applications from establishing localhost connections over the loopback network interface to further isolate customer applications. Host-based firewalls also provide the ability to further limit inbound and outbound connections as needed.
Our infrastructure provides DDoS mitigation techniques including TCP Syn cookies and connection rate limiting in addition to maintaining multiple backbone connections and internal bandwidth capacity that exceeds the Internet carrier supplied bandwidth. We work closely with our providers to quickly respond to events and enable advanced DDoS mitigation controls when needed.
Spoofing and Sniffing Protections
Managed firewalls prevent IP, MAC, and ARP spoofing on the network and between virtual hosts to ensure spoofing is not possible. Packet sniffing is prevented by infrastructure including the hypervisor which will not deliver traffic to an interface which it is not addressed to.
Database Access and Encryption
Lavanda customer data is stored in an access-controlled Postgres database and segmented by tenant at the row level. Database access requires a unique username and password combination that is only known to a select few staff with privileged access. Database credentials are rotated regularly and also immediately on termination of an employee with privileged access. Connections to Lavanda Postgres databases require SSL encryption to ensure a high level of security and privacy.
Stored data is encrypted by the Lavanda application in order to meet data security requirements.
Customer Applications and Databases
The Lavanda platform automatically restores customer data in the case of an outage. The Lavanda platform is designed to dynamically deploy applications within the Heroku cloud, which automatically monitors for failures, and will recover failed platform components including Lavanda applications and databases.
Our platform is designed for stability, scaling, and inherently mitigates common issues that lead to outages while maintaining recovery capabilities. Our platform maintains redundancy to prevent single points of failure, is able to replace failed components, and utilizes multiple data centers designed for resiliency. In the case of an outage, the platform is deployed across multiple data centers using current system images and data is restored from backups. Heroku reviews platform issues on Lavanda’s behalf to understand the root cause, impact to Lavanda customers, and improve the platform and processes.
Customer Data Retention and Destruction
Customer data will be retained by Lavanda for the duration of our relationship under contract, and for up to 6 months after the termination of a contract, to allow customers time to access and retrieve their data.
Decommissioning hardware is managed by our infrastructure provider using a process designed to prevent customer data exposure. AWS uses techniques outlined in DoD 5220.22-M (“National Industrial Security Program Operating Manual “) or NIST 800-88 (“Guidelines for Media Sanitization”) to destroy data.
For additional information see: https://aws.amazon.com/security
We take steps to protect the privacy of our customers and protect data stored within the platform. Some of the protections inherent to Lavanda’s products include authentication, access controls, data transport encryption, HTTPS, and the ability for customers to encrypt stored data. For additional information see: https://getlavanda.com/privacy.
Access to Customer Data
Certain Lavanda staff may have access or interact with customer data as part of normal operations, particularly in our Ops Support and Fully Managed service offerings. There may be cases where Lavanda staff are requested to interact with customer data or applications at the request of the customer for support purposes or where required by law.
Employee Screening and Policies
As a condition of employment all Lavanda employees undergo pre-employment background checks and agree to company policies including security and acceptable use policies. All employees are to read and comply with this information security policy. Failure to comply will be considered a disciplinary matter which result in dismissal and, in extremis, criminal prosecution.
Our security team is lead by the Chief Product and Technology Officer (CPTO) and includes staff responsible for application and information security. The security team works closely with the entire Lavanda organization and customers to address risk and continue Lavanda’s commitment to trust.
Data Breach Procedure
- Data breaches – particularly those involving PII – must be reported to the Data Controller immediately.
- Immediate action will be taken to remedy the breach and mitigate further breaches
- An entry will be made in the Data Incidents Log detailing the breach
- The Data Controller will make an assessment as to whether the breach constitutes a risk to individuals rights and freedoms
- If it does, a report will be made to the Information Commissioners Office (ICO) and the appropriate determination of risk and notifications will be made
- If it does not, no report will be made to the ICO and the matter will be investigated internally.
Lavanda operates a four tier information classification system. Documents and data are classified and handling procedures followed for any document carrying a classification. The classifications are:
CONFIDENTIAL – The information cannot be shared with any external recipient and sharing permissions are limited to named individuals with a legitimate reason to access the data. Documents and data carrying this classification must be secured, whether in electronic or physical (e.g. printed form). Waste marked CONFIDENTIAL must be shredded or disposed of securely.
RESTRICTED – The information may be shared internally or externally with specific individuals or groups. Documents and data carrying this classification must be secured, whether in electronic or physical (e.g. printed form)
INTERNAL – The information may be generally shared within the company
PUBLIC – The information is shared publicly.