Controlled Document Procedure

Purpose

GitLab deploys control activities through policies and standards that establish what is expected and procedures that put policies and standards into action.

The purpose of this procedure is to ensure that there is consistency in developing and maintaining controlled documents at GitLab utilizing a hierarchal approach for managing legal and regulatory requirements.

There are two types of documentation at GitLab:

1. Controlled Documents: Formal policies, standards and procedures.
2. Uncontrolled Documents: Informal runbooks, certain handbook pages, guidelines, blog posts, templates, etc.

Everyone at GitLab is welcomed and encouraged to submit an MR to create or suggest changes to controlled documents at any time.

Scope

This procedure applies to all controlled documents developed in support of GitLab’s statutory, regulatory and contractual requirements. Uncontrolled documents are dynamic in nature and not in scope of this procedure.

Roles & Responsibilities:

Procedure

Definitions by Hierarchy

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• Policy: A policy is a high-level statement of intent and defines GitLab’s goals, objectives and culture. Statutory, regulatory, or contractual obligations are commonly the root cause for a policy’s existence. Policies are designed to be centrally managed at the organizational level (e.g. Security Compliance Team or Legal & Ethics Compliance Team).
• Standard: Standards are mandatory actions or rules that give formal policies support and direction by providing specific details that enable policies to be implemented. Standards may take the form of technical diagrams.
• Procedure: Procedures are detailed instructions to achieve a given policy and, if applicable, supporting standard and provid step-by-step instructions to follow. Procedures are decentralized and managed by process/control owners where a security control is translated into a business process.

Creation

At minimum, controlled documents should cover the following key topic areas:

• Purpose: Overview of why the controlled document is being implemented.
• Scope: Who or what does the controlled document apply to.
• Roles & Responsibilities: Who is responsible for doing what. This should refer to departments or roles instead of specific individuals.
• Policy Statements, Standard or Procedure: The details.
• Exceptions: Define how exceptions to the controlled document will be tracked.
• References: Procedure documents should map back to a governing policy or standard, and may relate to one or more procedures or other uncontrolled documentation.

Publishing

Creation of, or changes to, controlled documents must be approved by management or a formally designated representative of the owning department as defined in the Code Owners file prior to publishing.

Most controlled documents will be published to our public facing handbook. However, if there is non public data included in the controlled document, it should be published via an internal facing only mechanism (e.g. an internal GitLab project or an internal only handbook page). Controlled documents should be accessible to all internal team members.

Review

Controlled documents are required to be reviewed and approved on at least an annual basis. Controlled documents may be updated ad-hoc as required by business operations. Ad-hoc changes do not need to be reviewed and approved, but can only be merged by a code owner of the controlled document.

Reviewers of controlled documents are required to

1. Ensure that “say why not just what” transparency is easily understood in the description. The title should be concise but clear on the what.
2. Ensure that announcements for team members are scheduled (Slack, company newsletter), and tick off the MR template task.

List of Controlled Documents

Exceptions

Exceptions to controlled documents must be tracked and approved by the controlled document approver(s) via an auditable format. An exception process should be defined in each controlled document.

Exceptions to this procedure will be tracked as per the Information Security Policy Exception Management Process.

References

• Parent Policy: Information Security Policy
• GCF Compliance Controls
• Data Classifiation Standard
• Controlled Documents Work Instruction