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Disclosure Policy: How to Establish and Maintain an Effective Disclosure Process



The Department of Health and Human Services (HHS)is committed to ensuring the security of the American public by protecting their information from unwarranted disclosure. This policy is intended to give security researchers clear guidelines for conducting vulnerability discovery activities and to convey our preferences in how to submit discovered vulnerabilities to us.




Disclosure Policy



This policy describes what systems and types of research are covered under this policy, how to send us vulnerability reports, and how long we ask security researchers to wait before publicly disclosing vulnerabilities.


If you make a good faith effort to comply with this policy during your security research, we will consider your research to be authorized, we will work with you to understand and resolve the issue quickly, and HHS will not recommend or pursue legal action related to your research.


Though we develop and maintain other internet-accessible systems or services, we ask that active research and testing only be conducted on the systems and services covered by the scope of this document. If there is a system not in scope that you think merits testing, please contact us to discuss it first. We will increase the scope of this policy over time.


HHS is committed to timely correction of vulnerabilities. However, we recognize that public disclosure of a vulnerability in absence of a readily available corrective action likely increases versus decreases risk. Accordingly, we require that you refrain from sharing information about discovered vulnerabilities for 90 calendar days after you have received our acknowledgement of receipt of your report. If you believe others should be informed of the vulnerability prior to our implementation of corrective actions, we require that you coordinate in advance with us.


Efforts made in good faith to comply with this policy during all security research will be considered authorized. The DOC will work with the researcher to understand and quickly resolve issues and will not recommend or pursue legal action related to your research. Should legal action be initiated by a third party against the security researcher for research conducted in accordance with this policy, the DOC will reaffirm this authorization.


Though the DOC develops and maintains other internet-accessible systems or services, we ask that active research and testing be conducted only on the systems and services covered by the scope of this document. We will increase the scope of this policy over time. This policy applies to anyone wishing to conduct vulnerability discovery activities, including research and testing.


While the DOC Office of the Chief Information Officer (OCIO) is responsible for the development and maintenance for various internet-accessible systems or services, research and testing should only be conducted on the systems and services covered by the scope of this policy. The scope of this policy is subject to change; please contact DOC@ResponsibleDisclosure.com if questions arise regarding systems not currently in scope.


At the same time, we believe that disclosure in absence of a readily available patch tends to increase risk rather than reduce it, and so we ask that security researchers refrain from sharing reports with others, or releasing reports to the public, while patching is occurring. If there is a need to inform others of the submitted report before the patch is available, please coordinate with DOC at DOC@ResponsibleDisclosure.com prior to release for assessment.


Information submitted under this policy shall be used by the DOC for defensive cybersecurity purposes (i.e. to mitigate or remediate vulnerabilities). If an issue has been reported and determined to be both within the program scope and determined to be a valid security issue, the DOC will validate the finding(s) and the security researcher can disclose the vulnerability after a resolution has been issued. The details within the Vulnerability Intake form may be submitted to an independent third-party vendor for evaluation and handling


(5) IntegrityFairnessDisclose information with a consistent content by a method which is equally accessible to our stakeholders, while giving full consideration to prevent any selective disclosure.


(1) Information Gathering Process Officers responsible for information disclosure will make efforts to gather information. If any information requiring timely disclosure is grasped, the officer will report it to the Corporate Communications Department (department in charge of information disclosure).The Corporate Communications Department reports all information requiring timely disclosure to the Corporate Accounting Department in charge of provisional financial reporting.


(3)Disclosure Process After obtaining approval by director of the Corporate Communications Department (and after being resolved by the Corporate Management Committee and/or the Board of Directors on important matters), information for timely disclosure is submitted to securities exchanges via TDNET. Statutory disclosures excluding disclosures based on Fair Disclosure Rules are provided via EDINET. The information that is disclosed in accordance with Fair Disclosure Rules is posted on the Company website.


Fairness: Highly transparent IR Provide fair and clear disclosure of information based on the precepts of the Fair Disclosure Rules stipulated in the Financial Instruments and Exchange Act, as well as statutory and timely disclosures. Through this, we will fulfill our responsibility for accountability to all stakeholders while engaging in a sincere dialogue.


A quiet period of three weeks prior to the announcement of financial results for quarters and full year is observed in order to prevent leak of financial information. During this period, representatives of the Company will refrain from answering questions or making comments related to the financial results or performance forecasts. However, this quiet period does not apply to other information including statutory and timely disclosures.


As part of a U.S. government agency, the Office of Personnel Management (OPM) takes seriously our responsibility to protect the public's information, including financial and personal information, from unwarranted disclosure.


This policy describes what systems and types of research are covered under this policy, how to send us vulnerability reports, and how long we ask security researchers to wait before publicly disclosing any vulnerabilities.


If you make a good faith effort to comply with this policy during your security research, OPM will consider your research to be authorized. OPM will not pursue legal action against authorized research.


Any services not expressly listed above, such as any connected services, are excluded from scope and are not authorized for testing. Additionally, vulnerabilities found in non-federal systems from our vendors fall outside of this policy's scope and should be reported directly to the vendor according to their disclosure policy (if any). If you are not sure whether a system or endpoint is in scope or not, contact us at vulnerabilitydisclosure@opm.gov before starting your research.


We believe that vulnerability disclosure is a two-way street. Vendors, as well as researchers, must act responsibly. This is why Google adheres to a 90-day disclosure deadline. We notify vendors of vulnerabilities immediately, with details shared in public with the defensive community after 90 days, or sooner if the vendor releases a fix. That deadline can vary in the following ways:


This policy is strongly in line with our desire to improve industry response times to security bugs, but also results in softer landings for bugs marginally over deadline. We call on all researchers to adopt disclosure deadlines in some form, and feel free to use our policy verbatim if you find our record and reasoning compelling. Creating pressure towards more reasonably-timed fixes will result in smaller windows of opportunity for blackhats to abuse vulnerabilities. In our opinion, vulnerability disclosure policies such as ours result in greater overall safety for users of the Internet.


Any exceptions to disclosure will be predicated upon the possibility, narrowly and clearly defined, that the potential harm to interests, entities or parties arising from the disclosure of information would outweigh the benefits, that GCF is legally obligated to non-disclosure or has received information from third parties clearly marked as confidential. GCF may, in exceptional circumstances, decide not to disclose or delay dissemination of information that would normally be accessible if it determines that the harm that might occur by doing so will outweigh the benefits of access. GCF may also, in exceptional circumstances, make available to the public information ordinarily excluded from disclosure when it determines that the benefit would outweigh the potential harm, except where GCF is legally obligated to confidentiality.


Our public disclosure policy covers information that is held by the Transparency International Secretariat in its premises and on the servers that it uses, and outlines the criteria and processes determining its public disclosure. It also contains guidance on how to make requests for information.


Across the globe, a growing number of trade sanctions laws (adopted by the EU, US, UN, and other countries) can affect the placement of reinsurance and the payment of premiums and claims. These laws are complex and, often, can change during and after the policy period. For certain classes of business, it is becoming increasingly common for reinsurers to impose a sanctions exclusion clause, which states that the reinsurance cannot respond where coverage or payment of a claim would expose reinsurers to sanctions penalties.


This is a copy of the vulnerability disclosure policy for 18F and the Technology Transformation Services (TTS). The official document lives in GitHub. If you would like to comment or suggest a change to the policy, please open a GitHub issue. 2ff7e9595c


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