Responsible Disclosure Policy

Scope & Purpose

This Policy applies to the GCI group of companies [including Nasstar and Modality] (hereafter “GCI”) 

This policy covers all GCI owned systems and applications and has been created to provide a transparent approach to the management of disclosure of any vulnerabilities identified. 

The Policy applies to both internal and external individuals or groups.

Policy Statement

GCI understands that protection of customer data is a significant responsibility and requires our highest priority. We therefore take the security of our systems extremely seriously, and we genuinely value the assistance of security researchers and others in the security community to assist in keeping our systems secure. 

GCI constantly monitors and tests its infrastructure and applications to ensure that they remain secure, but appreciates that as an international organisation, we will always be a target for cyber criminals. 

The responsible disclosure of security vulnerabilities helps us ensure the security and privacy of all our users.

If you find any indications of a vulnerability in any of our systems, we kindly ask you to inform us as soon as possible and not to disclose externally until you have done so. This is to ensure that we protect our users by preventing a malicious actor from taking advantage of the situation.


Please follow these steps to make a report:

  • Report any indications for a potential security vulnerability to GCI by emailing You can submit this information anonymously.
  • Provide as much information as you can about your findings (including available indications, for example, IP addresses, logs, screenshots).
  • Do not take advantage of the vulnerability or the problem you have discovered, (for instance, attempt to capture, change or delete any more data than necessary to demonstrate the vulnerability).
  • Do not disclose information about the vulnerability publicly until we have taken action to remediate it.

Once you report a vulnerability to us, we will respond as soon as reasonably practicable to evaluate the issue and
determine next steps.

  • We will handle your report with strict confidentiality and will not pass any of your details to any third party without your explicit permission.
  • We will keep you informed of progress as we resolve the issue. 


Security researchers must not:

  • Access unnecessary amounts of data. For example, 2 or 3 records is enough to demonstrate most vulnerabilities, such as an enumeration or direct object reference vulnerability
  • Use high-intensity invasive or destructive technical security scanning tools to find vulnerabilities
  • Violate the privacy of GCI users, employees, customers, members of the public, contractors, suppliers, services or systems. For example, by sharing, redistributing and/or not properly securing data retrieved from our systems or services;
  • Communicate any vulnerabilities or associated details using methods not described in this Policy, or with anyone other than their assigned GCI security contact
  • Modify data in GCI systems or services which does not belong to the researcher
  • Disrupt GCI services or systems
  • Social engineer, ‘phish’ or physically attack GCI employees, customers, members of the public, contractors, suppliers, services, systems or infrastructure
  • Disclose any vulnerabilities in GCI systems or services to third parties or the public, prior to the GCI confirming that those vulnerabilities have been mitigated or rectified
  • Require financial compensation in order to disclose any vulnerabilities

We ask you to delete securely any and all data retrieved during your research as soon as it is no longer required or within one month of the vulnerability being resolved, whichever occurs first.


This Policy is designed to be compatible with common good practice among well-intentioned security researchers. It does not give you permission to act in any manner that is inconsistent with the law, or which might cause GCI to be in breach of any of its legal obligations, including in respect of computer use, data protection and privacy, third party intellectual property rights and confidentiality (including official secrecy). 

GCI affirms that it will not seek prosecution of any security researcher who reports any security vulnerability on a GCI service or system, where the researcher has acted in good faith and in accordance with this disclosure policy. 

If at any time you are unsure if your intended or actual actions are acceptable, contact GCI for guidance at