Information Technology Policy

1. Purpose

This policy forms a reference for the acceptable use and delivery of Information Technology (IT) Services by the IT team, the correct way to interact with IT, and how IT will operate to provide robust, sustainable, scalable, and user-friendly IT Infrastructure and Services. 

All British Business Bank (the “Bank”) colleagues need to use and maintain our IT systems responsibly.

This policy explains to all Bank colleagues what is deemed acceptable use and what is not. Technical and procedural detail will be maintained in supporting standards.

This policy supports the Bank’s compliance with the following legal and regulatory obligations:

  • UK General Data Protection Regulation. Protection of personal data. Article 5 (1)(f) states it must be “processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).” – this policy and its related standards ensure this. You are responsible for Bank data which must be handled to ensure protection against unlawful or unauthorised processing, access, loss, destruction or damage. e.g. under UK General Data Protection Regulation or Data Protection Act 2018.
  • Intellectual Property Act 2014. Modernises intellectual property (IP) law to help UK businesses better protect their IP rights and underscores the importance of respecting intellectual property rights within an organisation when using, sharing, and creating intellectual property. British Business Bank will usually own the intellectual property created by colleagues during the course of their employment.
  • Copyright, Designs and Patents Act 1988. Protects the rights of creators over their intellectual property and sets out the legal framework for the use of copyrighted materials. This act ensures that employees and users are aware of the importance of respecting copyright laws, prohibiting the unauthorised copying, distribution, or use of copyrighted content.
  • Computer Misuse Act 1990. This Act defines the use of computers for unlawful purposes, the need to report certain cyber incidents to the authorities, collect evidence and chain of custody information, and the need for proactive controls. You could be personally prosecuted for your use of Bank systems for unlawful purposes e.g. under the Computer Misuse Act 1990, Investigatory Powers Act 2016. Abiding by this policy, its related standards and frameworks, and the Information Security Policy ensure the Bank complies with this Act. 
  • Regulation of Investigatory Powers Act 2000 (RIPA). Lawful interception of communications. The Bank may monitor communications and provide information to the authorities or other third parties - such as our cyber insurers - in response to legitimate requests or incident response. Any information you create or transmit using Bank systems should not be considered private.
  • Freedom of Information Act 2000 (FOIA). The Bank is required to create a public right of access to information held by the Bank. This Policy refers to Bank electronic communications that may be monitored and logged as part of a legitimate business purposes. Such activity could be required to fulfil a Freedom of Information request. 
  • Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000. Authorises businesses to lawfully intercept communications on their own networks for specific purposes such as ensuring regulatory compliance, verifying employee performance, and preventing criminal activity. We may also do this to troubleshoot IT or Network issues. 
  • Waste Electrical and Electronic Equipment Directive 2012/19/EU. Aims to reduce the environmental impact of electrical and electronic waste by promoting re-use, recycling and recovery. 
  • Network and Information Systems Regulations 2018 (NIS Regulations). The Bank is required to implement appropriate controls, risk management, report certain incidents and comply with the authorities as required. This is covered by our Incident Response processes.
  • FCA guidance FG 16/5. Guidance for firms outsourcing to the ‘cloud’ and other third-party IT services the requirements on firms which are regulated by the Financial Conduct Authority when outsourcing to the ‘cloud’ and other third-party IT services

In addition to meeting its legal obligations, the Bank as an Arm’s Length Body (ALB) is required to meet the Government Functional Standards where applicable. 

Obligations relating to Government Functional Standard (GFS005) – Digital, Data and Technology and (GFS007) Security activity elements are contained and prescribed through this policy and associated standards. 

The Bank provides cyber resilience assurance to Government via the GovAssure programme.
 

1.2 Alignment to Risk Appetite

Risk appetite is the type and level of risk the Bank’s Board is willing to take to deliver its strategy and public policy objectives. 

This policy forms part of the Bank’s Risk Management Framework (RMF).

This policy sits under the Level One Risk category, Operational and Resilience Risk.

This policy aligns to the Level Two Risk Category, Technology Risk, which is defined as ‘The risk that BBB IT and communication systems, including outsourced services, do not meet business requirements, do not operate as expected or are not resilient.’

The Bank’s risk appetite in relation to Technology Risk is set at Medium.

IT Acceptable use aligns to the Level Two Risk Category, Information Management, which is defined as ‘The risk of failing to treat information as a strategic asset, appropriately manage and maintain the organisation’s information across its lifecycle to support its necessary use, resilience, integrity and availability.’

The Bank’s risk appetite in relation to Information Management is set at Medium
 

2. Scope

This policy applies to all Bank entities, operations, subsidiaries and Colleagues (see Appendix 2: Scope Definitions).

This IT Policy outlines the responsibilities of Colleagues regarding the Bank’s IT systems and devices. 

It details the acceptable use of these systems. It also covers IT governance, including asset and service continuity management, and service and project delivery. 

This policy applies to both users and administrators of these systems and services.

This policy does not include technical detail but references relevant standards and procedures.
 

3. IT Service and Technology Change Delivery

 This section lists key high-level aspects of IT service provision for the Bank.

  • Enterprise Technology: IT will provide and maintain the underlying enterprise technology and infrastructure that enables colleagues to deliver the Bank's mission. IT will review critical configurations and architecture annually to ensure alignment with standards and best practices.
  • Governance and Standards: IT will define and adhere to governance, processes, and standards for Technology, Technology Change Delivery, Service Delivery, and Change Enablement.
  • Due Diligence: IT will provide technology and information security due diligence in line with procurement processes, supporting contract owners in making informed decisions and mitigating risks. 
  • Documentation: IT will maintain clear documentation for all standards, processes, and governance to ensure colleagues understand expectations.
  • Continuous Improvement: IT will continuously improve its governance, processes, and standards to fit the Bank’s needs, with formal reviews conducted annually.
  • Gap Analysis: Annual policy reviews will include a standards gap analysis against critical services.
  • Service Lifecycle Support: IT will support non-enterprise, bespoke, and local IT needs, provided a nominated Service Owner is agreed upon and aligns with Bank governance.
  • Guidance for Service Owners: IT will provide clear guidance for Service Owners and support effective delivery of federated services.
  • Service Management: IT will manage services as agreed with the business, in compliance with governance, processes, and standards.
  • Vendor Management: IT follows our procurement and supplier relationship management processes to ensure that our requirements are adequately addressed by our providers.
  • Feedback Mechanism: IT will seek and act on feedback from the business through regular surveys, improving what works and changing what doesn’t.
  • Technology requests: IT will regularly assess non-standard requests and provide technical expertise for colleagues who want to make technology changes. IT will either deliver them, add them to the IT Programme of Work backlog, or reject them. The requester will be informed of the outcome.
     

4. Key Requirements - IT Acceptable Use

Use of IT Devices and Systems

The Bank provides colleagues with IT devices and access to IT systems for business purposes. 

The Bank will monitor the use of and access to its systems, including personal use and internet access.

This includes the use of Bank email and messaging platforms. Some personal use is acceptable.

Monitoring and Privacy

All Bank electronic documentation and communication, including deleted messages and documents, are subject to the Freedom of Information Act 2000 and the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000. 

Colleagues should assume no right to privacy when using the Bank’s systems, subject to proportionate and justified actions.

4.1    Protecting Systems and Data

Colleagues are expected to take all reasonable steps to protect the confidentiality, availability, and integrity of our systems and data. 

This includes the following behaviours:

Do: 

  • Keep Authentication Data Confidential: Keep passwords, tokens, PINs, and other authentication data confidential. Ensure they meet our requirements as defined in the Access and Authentication standard. These do not imply any right of privacy; they prevent unauthorised access.
  • Lock Your Screen: Lock your screen when your device is unattended.
  • Manage Encryption Keys: Ensure the right people have access to encryption keys for encrypted documents. Make sure access will continue if you leave the Bank.
  • Support IT Maintenance: Support the IT Service Desk by responding to reboot requests and reporting unusual activity promptly.

Don’t:

  • Use IT Inappropriately: Do not use the Bank’s property to transmit, receive, or store any information that is discriminatory, harassing, or defamatory.
  • Use unauthorised devices: Do not access or attempt to access the Bank’s systems or data using an unauthorised device.
  • Unauthorised Access: Do not access Bank systems without authorisation from the system owner.
  • Make Insecure Data Transfers: Do not transfer the Bank’s data to unauthorised personnel or systems

4.2    Reporting Issues and Making Requests

Do:

  • Use the IT Service Desk Portal to report Issues or Incidents or to make Requests. 
  • Follow up with a request via the portal after verbally requesting something from IT.

4.3    Use of Software

Software and Application Requests:

  • Approved Requests Only: Software or applications must not be used or deployed without an approved request. Unauthorised use increases the risk of Cyber Security and Information Governance incidents and leads to inefficient use of Bank resources.
  • Centralised Approval: IT reviews and approves software requests so that our standards are adhered to and that exceptions are granted within our risk appetite. We aim to balance tailoring services to our needs while avoiding duplication and minimising the number of applications in use across the Bank.

Software Installed on Bank Devices

  • Legally Acquired Software: The Bank will provide all necessary software that is legally acquired and licensed. Backup copies of this software are made according to licensing agreements and Bank policies. Using software from any other source is strictly prohibited.
  • Software Checks: To protect its reputation and investment in software, the Bank may perform periodic assessments of software use, announced and unannounced audits of Bank computers, and the removal of any software found on Bank property without a valid license.

Do:

  • Use Bank-Supplied Software and Services: Only use the software and services provided by the Bank.
  • Request Software or Services: If you need software or services for your work, submit a request to the IT Service Desk Portal.
  • Document Requirements: Before requesting new software or applications, colleagues must document their requirements. You can suggest specific software that meets these requirements and explain how it will fulfil them.
  • Request Additional Copies: If you need a copy of software for two Bank devices, submit a request to the IT Service Desk. Approval will be granted if the software license agreement allows it and there are valid business reasons.
  • Comply with Laws and Regulations: Ensure your use of software and cloud services complies with all applicable laws and regulations regarding personally identifiable information, corporate financial data, or any other data owned or collected by the Bank.
  • Use Software for Business Purposes: Use the Bank’s software assets for business purposes only.

Don’t:

  • Install Unauthorised Software: Do not install any software on your Bank devices.
  • Duplicate Software or Licences: Do not make any copies of software or software licences. Unauthorised duplication is illegal and against Bank standards. Breaching this policy may lead to disciplinary action, including dismissal.
  • Open Third-Party Service Accounts: Do not open third-party service accounts or enter into cloud service contracts for Bank-related communications or data.
  • Use Personal Cloud Accounts: Do not use personal cloud service accounts for Bank communications or data.
  • Share Log-In Credentials: Do not share your log-in credentials with anyone.
  • Agree to Unapproved Terms of Service: Do not use cloud services that require agreeing to terms of service without review and approval from the IT Service Desk, ensuring alignment with IT Outsourcing Standards.
  • Pay for Software Personally: Do not pay for software as a service (SaaS) or other applications personally and claim expenses without approval from the Chief Operating Officer (COO).

4.4    Internet Access and Personal Use of Bank Devices and Network

Internet Access: The Bank provides you with access to the internet by setting up an account and providing log in details. The Bank will block access to sites that fall within categories deemed inappropriate. Exceptions will be agreed with HR, and if appropriate Colleague Forum.

Appropriate Use Monitoring: The Bank may monitor both the amount of time spent using online services and the sites visited by Bank colleagues and may limit or revoke access if necessary.

Personal Use: When using the Bank’s IT systems and devices for personal purposes, you do so at your own risk. The Bank will not be responsible for any loss of information, damages, or liability resulting from personal use, including any corruption or misuse of emailed content. Access to the internet for personal use is allowed, provided your use is reasonable and acceptable, and you follow the principles below.

Do:

  • Be vigilant: Watch out for malicious files or code when downloading any files or attachments.
  • Use the internet responsibly: Ensure your usage is for business-related purposes.
  • Limit Personal Use: Keep your use of the Bank’s internet connectivity, personal webmail and cloud accounts to a reasonable level that does not disrupt your work.
  • Limit tethering and mobile data use: Use the Bank’s mobile data responsibly. It should primarily be used when traveling or working away from home and the office, and only for work-related purposes.
  • Use Guest Wi-Fi: If needed, use ‘Guest Wi-Fi’ from personal devices, following the principles established in this policy.
  • Seek Guidance: Consult your line manager for guidance on acceptable use.

Don’t:

  • Use Personal Accounts for Bank Business: Do not use personal webmail or cloud accounts for Bank business unless you have prior written authorisation from the Chief Operating Officer (COO).
  • Interfere with Work: Do not allow personal internet use to interfere with any Bank colleague’s duties.
  • Violate Data Protection or Privacy: Avoid uploading Bank information to personal webmail or cloud accounts, and do not download personal information onto your Bank laptop.
  • Copy or share copyrighted materials: Only do so with the author’s written permission or if accessing a single copy for your own reference.
  • Use your work email like a personal account: Only use it to support your duties.
  • Interfere with the Bank network: Avoid actions like spreading computer viruses or generating high-volume network traffic that hinders others.
  • Engage in illegal activities: Do not use the internet for illegal purposes or personal gain.
  • Violate Bank policies: Always act in the best interests of the Bank when using our systems.
  • Disclose confidential information: Keep the Bank’s and third parties’ information private.
  • Use Bank assets as personal devices: Do not import personal documents, photographs, pornography, or illegal material onto the Bank’s systems or devices.

4.5    Social Media

Access to social media sites is allowed where there is a business need.

Do:

  • Request Access: Use the IT Service Desk Portal to request access to social media.

Don’t:

  • Disclose Sensitive Information: Do not share sensitive or potentially sensitive material, intellectual property, or similar content on social media.
  • Use Unapproved Platforms: Avoid using social media or messaging applications not provided by the Bank for work-related purposes on either Bank-issued or personal devices. This usage may be subject to Freedom of Information requests, Data Subject Access Requests, or other legal, regulatory, or internal investigations.

For further guidance on appropriate use of social media, refer to the Bank’s Social Media Standards

4.6    Email Use

Email is an important business communication tool. 

Use it responsibly, professionally, effectively, and lawfully.

Key Points:

  • Legal Risks: Emails are subject to the same laws as other written communications and may need to be disclosed in investigations and Freedom of Information requests.
  • Monitoring: The Bank may monitor email communication. All Bank emails, including deleted ones, are archived subject to our retention policies and remain the Bank’s property.

Do:

  • Indicate Information Classification: Clearly mark and respect the information classification on emails. See the Bank’s Information Classification and Handling Standard.
  • Mark Personal Emails: Clearly mark personal emails as reflecting the sender’s views, not the Bank’s.
  • Use Personal Emails Appropriately: Only use a colleague’s personal email address for official material that relates to them personally, such as payslips or contracts.

Don’t:

  • Misuse the Email System: Only use the Bank’s email system for legitimate business purposes.
  • Send Bank Information to Personal Accounts: Do not send Official Bank information or attachments to personal email accounts without prior written approval from the Chief Operating Officer (COO). Approval has been given for certain non-executive directors, but any other case requires written approval.
  • Send Inappropriate Content: Avoid sending chain letters, junk mail, jokes, executable files, or emails with attachments or links that may contain malware.


4.7    Collaboration Software

Microsoft Teams (Teams) is our preferred collaboration tool. 

You need to use this tool in a responsible, professional, effective and lawful manner.

Key Points:

  • Legal Risks: Teams chat messages are subject to the same laws as other written communications. Be aware of the legal risks and the potential need to disclose messages in response to investigations, Freedom of Information requests and in meeting data subject rights.
  • Teams Recording: Colleagues may only record or transcribe Teams calls if granted permission for a specific call or series of calls following a formal request submitted per the Bank’s call recording guidance. Requests that do not comply (e.g., those outside the guidance's scope or submitted on short notice) will be rejected. The guidance covers request procedures, submission timelines, data protection, and recording management. The requesting colleague is responsible for compliance and violations may result in disciplinary action and pose legal, commercial, or reputational risks to the Bank. Only native Teams recording is permitted; third-party software and personal device recordings are strictly prohibited.
  • Monitoring: The Bank may monitor Teams communication. Chat content is archived, and all messages distributed via the Bank’s Teams system are the Bank’s property.
  • Collaboration with Third Parties: IT can provide federated access to partner organisations on request, typically where the Bank has a contractual relationship with the third party. 
  • Third Party Collaboration Tools: Other tools, such as Slack, can be approved for collaborating with third parties where Teams is not an option. For example, IT and Data colleagues have access to the Cross Government Slack Workspace. 
  • WhatsApp: Can be approved by Business Resilience for use on work mobiles during a major incident. 

Do:

  • Indicate Information Classification: Clearly mark and respect the information classification of data shared in Teams. Refer to the Bank’s Information Classification and Handling Standard
  • Blur Your Background:  Whilst on a call do set your camera background to ‘blur’ to prevent any sensitive information from being seen and maintain privacy whilst working from home. Think about who may be around that could hear your discussions and take the necessary steps to work in a private space or use a headset. 
  • Use Discretion with social use: Colleagues can use third-party communication tools on their personal devices at their own discretion but be aware that these communications might be included in an investigation or response to third party request.

Don’t:

  • Misuse Teams: Only use Teams for legitimate business purposes.
  • Send Bank Information to Personal Teams Chats: As with email, do not send Bank information or attachments to personal MS Teams chats.
  • Send Inappropriate Content: Avoid sending jokes, executable files, or attachments or links that may contain malware.
  • Disclose Sensitive Information on Slack: Do not share sensitive or potentially sensitive material, intellectual property, or similar content via Slack or other third-party tools.
  • Join Unapproved Slack Workspaces: Do not join unapproved Workspaces on Slack.
  • Misuse third-party tools:  Work-related messages on either a Bank-issued or personal device are subject to Freedom of Information requests, Data Subject Access requests, or other legal, regulatory, or internal investigations. Do not use third-party tools such as Slack and WhatsApp for work-related purposes without written approval from the Chief Operating Officer (COO). 


4.8    Telephony and Messaging

The Bank provides authorised software for making telephone calls and sending messages through applications such as Teams. 

All calls made from and to a given telephone extension may be logged, recorded and monitored and colleagues should presume no privacy at any time. 

Although voicemail is password protected, an authorised administrator can reset the password and listen to voicemail messages if required to do so.

Do:

  • Use Authorised Tools: Always use approved audio-conferencing tools like Teams to arrange meetings. 
  • Join External Meetings Properly: When joining meetings hosted by external parties, use their conferencing tools as usual. If you need help, contact the IT Service Desk.
  • Share Information Carefully: Only share information if you are certain about the recipient's identity, their entitlement to the information, and their readiness to receive it.
  • Validate identities: Modern tools allow attackers to convincingly impersonate others, for example during remote job interviews. If you have doubts, verify the identity of the person you are speaking to. IT can provide guidance on the best practices for doing this.

Don’t:

  • Avoid Voicemail Risks: Do not leave voicemail messages containing personal information without first considering the potential security and confidentiality risks.
  • Record calls other than in compliance with the Bank’s call recording guidance.

4.9    Bank Devices

Do not remove or alter the tags on Bank equipment as these tags uniquely identify it. 

Report any damaged tags to the IT Service Desk.

4.10    Travelling Outside the UK with Bank Devices

You may occasionally need to take Bank-owned devices outside of the UK so you can access the Bank’s network for work while on official work trips overseas or where you’re wanting to use a device on holiday. 

This must be requested via the IT Service Desk Portal so that IT can ensure that the device is appropriately protected whilst abroad.

Information Security maintain a Veto List based on guidance from the Foreign Office Travel Advisories and the National Cyber Security Centre. 

Working outside the UK requests to these destinations will be rejected. Devices seen in these countries during monitoring will be isolated from the corporate network, and accounts will be disabled without warning. 

Devices that have been to vetoed countries will require complete inspection, sanitisation, and potentially, destruction.

Do:

  • Align with policy: Refer to the Temporarily Working Outside the UK Policy on the Intranet.
  • Check Government advice: Check the foreign office travel advisory before travelling
     

Don’t:

  • Bank assets: Take a Bank device or work materials out of the UK without permission

4.11    Use of Bluetooth Connected Devices

Do not use Bluetooth data sharing functionality to transfer files, either from their paired equipment onto the Bank network or device, or from the Bank network or device to the paired equipment. 

Colleagues can share the internet connection from their Bank phone for connectivity when travelling.

4.12    File and Document Storage

Bank laptops are configured to use Microsoft OneDrive to synchronise files stored on your Desktop and in your Documents folder to the Cloud. 

Documents stored in SharePoint or OneDrive are also accessible from Bank mobile phones. See Appendix 5 for guidance.  

Do:

  • File storage: Use OneDrive, SharePoint or the G:\ drive to securely share, store and collaborate on files and documents.
  • Ask for assistance: Contact the Service Desk for advice if you have any issues with your files.

Don’t:

  • Put information at risk: Store any files or information outside of SharePoint, OneDrive and G: as these are not backed up.

4.13    Personal Data on Bank Devices

When using Bank devices, colleagues are likely to have access to personal data in relation to other individuals including other colleagues. 

The Bank has a separate Data Protection Policy relating to the appropriate handling of personal data.

Do:

  • Align with policy: Check the Bank’s Data Protection Policy before sharing any such personal data. Contact the Bank’s Data Protection Officer if you have any concerns or need further guidance. 
  • Protect your data: Use your OneDrive for storing any personal data.

Don’t:

  • Put information at risk: Allow anyone else to have any access to your Bank devices.

4.14    Personal Devices

The Bank does not support a full Bring Your Own Device (BYOD) policy – that is, the Bank does not allow you to use personal devices for Bank work except in exceptional circumstances where this has been specifically configured. 

When you are using a personal device for other purposes, apply the following principles.

Do:

  • Use the correct network: Access ‘Guest Wi-Fi’ when on Bank premises.
  • Access web services: Access web services for which you have your own login credentials (for example, Diligent).

Don’t:

  • Use the incorrect network: Use ‘BBB Corp – Wi-Fi’ from personal devices.
  • Compromise Banks security: Connect any personal device to the Bank network using your Bank login credentials (username and password).
  • Put information at risk: download (or allow anyone else to download) any Bank information, emails or documents onto a personal device. 
  • Record calls. Calls must only be recorded in your work Teams account and in compliance with the Bank’s call recording guidance.

4.15    Removable Media

Authorised encrypted removable media (USB sticks) are available via the IT Service Desk. 

The IT Service Desk logs serial number, content, date issued, issued to and date returned.

Do: 

  • Ask permission: Submit a request to the IT Service Desk if you need to use removable media.

Don’t: 

  • Ignore guidelines: Use personal removable media, unless you have obtained specific authorisation from the Chief Operating Officer (or an appropriate delegate) via a request to the IT Service Desk.

4.16    Use of Artificial Intelligence (AI)

Colleagues are permitted to use AI in alignment with the bank’s policies and guidance. 

Microsoft CoPilot is provided by our enterprise technology partner Microsoft and is our preferred choice; colleagues can leverage other tools if they follow the guidelines.

Do

  • Only use a Bank device: If access is via the browser Microsoft Edge should be used.
  • Follow Government guidance: The Government Security Group Guidance for ChatGPT use.
  • Register with Bank Email: If using online Generative AI (GenAI) tools register for an account using your Bank email address.
  • Validate outputs: Don't assume that what has been provided by AI tools is accurate. Always check the accuracy of the information provided.
  • Report Concerns: Raise a Risk Incident if are concerned about any disclosure that have occurred.
  • Seek guidance from the Data and Information Governance Team.

Don’t

  • Avoid Personal and Sensitive Data: Do not input personal data or data classified above OFFICIAL level into any online Generative AI tool.
  • Non-Work Use: Do not use CoPilot, ChatGPT (or any other GenAI tool) for non-work-related activities on a Bank device, or to generate inappropriate content for work.

4.17    Use of Music Streaming Services

Access to music streaming services via a Bank provided laptop is allowed, providing that your use is reasonable, and you follow the principles below.

Do:

  • Be reasonable: Keep your use of personal music streaming to a reasonable level.
  • Protect the Bank: if using a Bank device, only use a browser-based version of the service.
  • Seek guidance: Consult your line manager for guidance on acceptable use.

Don’t:

  • Impact your colleagues: Play loud music in the offices or disturb colleagues.
  • Put the Bank at risk: Sign up to music streaming services with a Bank email address. 

Personal use of the Bank’s IT systems and devices is at your own risk. 

The Bank will not accept responsibility for any loss of information, damages or liability arising from any Bank colleague’s personal use of the Bank’s IT systems and devices.

4.18    Intellectual Property Rights

Intellectual Property (IP) refers to creative work, which can be treated as an intangible asset or physical property. 

IP rights can be found in a wide range of work products, including research reports, inventions, improvements, discoveries, software design, software coding, charts, drawings, specifications, notebooks, tracings, photographs, negatives, draft or final reports, findings, recommendations, data and memoranda. 

Any IP created by or for the Bank and created by Bank colleagues in carrying out their employment duty, is the property of the Bank.

In your use of the Bank’s IT systems and devices:

Do:

  • Protect the Bank: Be careful to protect the Bank’s intellectual property, and do not misuse that of our customers.

Don’t:

  • Put the Bank at risk: Use or share intellectual property except where it is an authorised and necessary part of your job.
     

5. Key Requirements - IT Asset Management

IT Asset Management is a key control against our technology infrastructure risk.

Scope:

  • All infrastructure, including network, server, and storage hardware, software, and peripherals.
  • All laptops and associated hardware.
  • All monitors, printers, and scanners.
  • All phones (mobile and smartphones) and portable computing equipment.
  • Projectors, microphones, and video conferencing equipment.
  • Software applications.

5.1    Colleague Responsibilities

  • Colleagues are responsible for the physical security of Bank assets assigned to them.
  • Loss, theft, or damage must be reported promptly and in line with the Bank’s policies and procedures.

5.2    Line Manager Responsibilities 

  • Follow the Joiners, Movers and Leavers (JML) process in line with HR Guidance. 
  • Request new assets in advance through the JML process. 
  • Ensure leavers are aware that they need to return their assets to IT in line with HR policies.

5.3    IT Responsibilities

The Infrastructure and Operations team are responsible for IT Asset Management including the following:

IT Asset Governance 

  • Policies and procedures to procure, register, maintain, track, replace and dispose of IT assets.
  • That service providers and colleagues manage and use IT assets in accordance with our policies.

IT Asset Requirements

  • Active IT assets are comprised of modern, manufacturer supported hardware.
  • Active IT assets reside in environments in line with manufacturer recommendations and industry best practice, and with current maintenance and support contracts.
  • Regular patching of IT assets to ensure compliance and security best practices.
  • Modifications only by authorised staff.

IT Asset Register

  • Accurate records are maintained from acquisition to disposal, validated by regular audits.
  • Maintained by IT to track assets, including location, owners, and device details.
  • Manages assets for JML
  • Records decommissioned assets.
  • Tracks active assets until passed to second beneficiaries.

IT Asset Procurement

  • Must follow the Bank’s Supplier Management Policy and Standards.

IT Asset Security

  • IT assets and their information are protected from loss, damage, unauthorised access, or misuse.
  • IT provides securely configured devices.
  • Access protected in line with the Information Security Standards. 
  • Prompt reporting any IT asset losses and administer the approved procedures to prevent any data loss

IT Asset Disposal Requirements

  • IT updates the asset register on disposal.
  • Secure disposal follows Information Security Standards, approved procedures and legal obligations.

IT Assets to Second Beneficiaries

  • IT engages with parties to re-use assets for charities, schools and other approved beneficiaries.
  • Aligns with carbon reduction and Environmental, Social and Governance (ESG) mission.
     

6. Key Requirements - IT Disaster Recovery

IT Disaster Recovery (DR) ensures continuity of critical IT services and quick return to normal operations after disruptions. 

This includes restoration of availability in line with agreed Recovery Time Objectives (RTO), and restoration of integrity in line with agreed Recovery Point Objectives (RPO).

6.1    IT Responsibilities

The Infrastructure and Operations team are responsible for IT Disaster Recovery. 

Inputs to the IT Disaster Recovery Plan

  • Business Impact Analysis (BIA): Identifies critical activities, and the IT resources required to support them including impact rating, RPO and RTO. IT will define our DR approach in line with BIA.
  • Critical Services: Services without which the Bank cannot function, linked to our Key Processes. Included in the IT DR Plan to ensure they are maintained and can recover to meet RTO and RPO.
  • Dependencies: Internal and external dependencies are identified and included in the runbook and test specifications.


IT Disaster Recovery Governance

  • IT DR Plan Documentation: Identifies and documents critical services, responsibilities, and resources needed to maintain/recover operations during disruptions and is updated following the annual BIA refresh.
  • Managed Service Recovery Plans: Developed with Managed Service Partners for services under their responsibility; vendor-provided services require regular IT DR testing assurance.
  • ‘As a Service’ Vendor Assurance: Our contracts for critical services will stipulate vendors regularly test their IT DR capabilities for services delivered ‘as a service’ and provide DR plans, DR testing reports, and compliance certifications or audits from third party companies.

Invocation of the IT Disaster Recovery Plan

  • Coordinated under IT Major Incident Management: IT DR will be invoked as part of IT Major Incident Management (MIM). IT MIM ensures a coordinated response across internal and external technical teams, according to tested and repeatable processes. 
  • Execute by Emergency Response Team (ERT): Cross party team established to support IT MIM by efficiently responding to IT Disaster Recovery scenarios with skilled personnel.

Links to Strategic Recovery and Incident Management Plan 

  • Incident Notification: The Business Resilience Director or deputy is informed of all PI incidents to consider if the IRT needs to be invocated.
  • MIM Input: A senior MIM representative provides input if the IRT is invoked.

External Engagement 

  • Critical Partners: Critical partners are engaged in the definition, maintenance, execution, and testing of the IT Disaster Recovery Plan.
  • Risk and Compliance: ensure corrective action is taken where the Bank falls outside of risk appetite through the Risk Management Framework, and by supporting funding requests, driving through improvements, or other means in line with the Bank’s processes.

Measuring compliance with the IT DR Plan with the IT DR Policy

  • Regular Exercises: Ensures the plan remains valid and incident response is rehearsed in a controlled environment.
  • Testing Frequency: Monthly, quarterly, and annual tests cover key areas like file restoration, host failures, UPS capability, and connectivity.
  • Validation and Retests: Test reports are validated by IT Governance, with retests conducted as needed.

Storage of the IT Disaster Recovery Plan

  • SharePoint Repository: The plan is stored in the IT Infrastructure and Operations SharePoint repository with the Test Governance documentation.
  • Partner Copies: Copies are also held by partners responsible for supporting the plan’s delivery.

6.2    Business Resilience Team Responsibilities 

  • Business Impact Analysis: Annual review and refresh of the Business Impact Analysis 
  • Invoking the Incident Response Team: Liaising with a Core Member of the Incident Response Team (IRT) to decide if the IRT is to be invoked during a major/critical incident where the IT DR Plan is invoked.

6.3    Managed Service Partners Responsibilities

  • Providing technical expertise: Managed Service Partners are responsible for defining, maintaining, and executing the IT Disaster Recovery Plan for the services they oversee.
  • Collaborating with stakeholders: Managed Service Partners must work closely with other stakeholders to ensure the effective execution of the IT Disaster Recovery Plan.

     

7. Non-Compliance

This policy sets out what the Bank expects from all colleagues using IT systems and devices, to work effectively and to support the Bank’s reputation. 

Your compliance with this policy is mandatory. 

Any breach of this policy may lead to disciplinary action, which could result in dismissal.

The Bank actively monitors compliance with this policy. 

Breaches of this policy are reported via the Risk Incident Portal on the Bank Intranet and assessed by the Policy Owner to determine what action is required. 

This may include disciplinary action in accordance with the Bank’s Disciplinary Policy.

Failure to comply could expose the Bank and its partners to out-of-tolerance risk in the delivery of resilient IT services.
 

8. Aligned Policies, Standards, and Procedures

Policies

  • Information Security Policy
  • Supplier Management Policy
  • Data Protection Policy
  • Code of Conduct
  • Disciplinary Policy and Procedure
  • Business Resilience Policy
  • Temporarily Working Remotely Outside the UK Policy

Standards

  • IT Outsourcing 
  • INFSC07 Secure Asset Sanitisation and Disposal Standards
  • Information Classification and Handling Standard
  • Social Media Standards
  • Backup & Restore Standards.docx

Procedures

  • System Development Lifecycle (SDLC)
  • Cyber Incident Response Plan
  • Major Incident Management (MIM) 
  • BBB IT Disaster Recovery Plan v5.4.docx
  • Disciplinary Policy and Procedure 
  • Strategic Recovery and Incident Management Plan (SR&IMP)

Other

  • Code of Conduct
  • Ops Charter
  • IT Handbook
  • IT Critical Services by Key Process (Draft)
  • Risk Management Framework
     

9. Policy Controls

Library ReferenceControl TitleDescription
C_LIB_KP_04_10Disaster Recovery Test AssuranceTo ensure effective recovery if a disaster occurs.
C_LIB_IT_02_3IT Asset ManagementEnsure that IT Assets are available, secured and tracked through their lifecycle via the Banks IT Asset Register.
C_LIB_KP_04_9IT Disaster Recovery PlanTo maintain the Bank's systems and processes, at a minimum level, during a disruptive incident and facilitate a recovery (return to ‘normal’ operations) as soon as possible.
C_LIB_IT_03_1Monitoring and Event Management - business applicationsCritical business applications are monitored appropriately, issues are escalated and responded to in a timely manner
C_LIB_IT_02_2Monitoring and Event Management - infrastructureCritical infrastructure is monitored and issues are escalated and responded to in a timely manner
C_LIB_IT_02_4Service Resilience (Disaster Recovery)Critical Services with successful Service Resilience tests in line with Plan
C_LIB_IT_01_4Technology Policy, Procedures and StandardsDefine repeatable controls to be consistently implemented across the Bank
C_LIB_IT_01_2Technology Management Systems and ApplicationsTechnology tools used to manage and monitor the estate, i.e. JIRA, CMDB etc
C_LIB_CM_01_10System Development Lifecycle (SDLC)Standardised processes to ensure Technology meets the requirements of the business
C_LIB_IT_03_2Support Model in place for all business applicationsEnsure business applications comprise of components that are always up to date
C_LIB_IT_02_1Support Model in place for all infrastructureEnsure infrastructure services comprise of components that are always up to date
C_LIB_CM_01_5Awareness of Change Enablement Process and ProcedureTo ensure IT change process and procedure is followed
C_LIB_IS_04_1Privileged Access ManagementProtect against unauthorised access to IT assets and information and ensure access rights are managed appropriately.
C_LIB_IT_01_1IT StrategyTechnology has a documented strategy, aligned to the business plan and updated annually, which provides a roadmap of work required across the IT estate, including material outsource arrangements, change programmes, lights on activities and the budgets aligned to each.
C_LIB_IT_03_3Application SuitabilityColleagues have access to the applications needed to fulfil their roles and deliver the Banks objectives
C_LIB_IT_01_3MI and ReportingTo provide relevant and timely reporting and MI for the effective management of systems, services and resources across the IT estate
C_LIB_CM_02_2Monthly IT Budget Review Meetings with FinanceTo review the IT budget monthly to track spend against the agreed budget.

10. Definitions

 

Non-Standard Request

Request for a new IT service or technology that is not currently provided by the Bank. 

IT Incident

An event resulting in degradation or interruption to an IT Service and should be reported to the IT Service Desk via the IT Portal.

IT Disaster Recovery

IT Disaster Recovery ensures that the availability and performance of a service are maintained at sufficient levels in case of a disaster. 

It provides a framework for building organisational resilience with the capability of producing an effective response that safeguards the interests of key stakeholders and the organisation’s reputation, brand, and value-creating activities (Source: Axelos ITIL v4).

Recovery Time Objectives (RTO)

The maximum acceptable amount of time for restoring a network or service and regaining access to data after an unplanned disruption.

Recovery Point Objective (RPO)

The maximum amount of data – as measured by time – that can be lost after a recovery from a disaster, failure, or comparable event before data loss will exceed what is acceptable to the Bank.

Encryption Key

A unique code designed to unscramble and decipher encrypted data. Each key is specific to a specific encryption code, therefore making each key unique and difficult to replicate.

Cloud Services

Some of the software used at the Bank is provided by a cloud services provider ‘as a service’ over the Internet, rather than being hosted by us in our data centres. 

There are several types (see below), the option chosen depends on cost, availability, applicability, and maturity of existing solutions.

Software-as-a-service

Service like SharePoint. 

Here the Bank doesn’t run servers or write software, but IT is responsible for backing up our data, controlling access and other administrative tasks.

Platform-as-a-service

Such as Microsoft Azure App Service, used to by software developers to create web-based applications.

The Bank isn’t responsible for servers or software here, but is responsible for the code.

Infrastructure-as-a-service

Physical hardware that the Bank isn’t responsible for e.g. cooling, heating or power but is responsible for the operating systems on the virtual servers, and the software running on them.

Generative AI (GenAI)

Generative AI models use neural networks to identify the patterns and structures within existing data to generate new and original content.

Enterprise Technology

The Bank’s core systems for communication and collaboration (MS Windows, O365, Teams), data storage (MS Azure), system integration (MS Power Platform, Azure Functions), Information Security (MS Sentinel, Defender), access management (MS AD and Entra), IT Service Management (Atlassian Jira), data sharing (ShareFile).

Appendix 2: Scope Definitions

 ColleaguesEmployees
Permanent Employees (Full or part time)YesYes
Fixed terms contract employees (FTC)YesYes
ApprenticesYesYes
InternsYesYes
Secondees - outYesYes
Secondees - inYesYes
Board Members (exective directors)YesYes
Non exective directors (NEDs)Yes 
ContractorsYes 
TempaYes 
Professional ServiceYes