DATA BREACH POLICY
1.0 Purpose
The purpose of the policy is to establish the goals and the vision for the breach response process. This policy will clearly define to whom it applies and under what circumstances, and it will include the definition of a breach, staff roles and responsibilities, standards and metrics (e.g., to enable prioritisation of the incidents), as well as reporting, remediation, and feedback mechanisms. The policy shall be well publicised and made easily available to all personnel whose duties involve data privacy and security protection.
Meta Results Information Security's intentions for publishing a Data Breach Response Policy are to focus significant attention on data security and data security breaches and how Meta Results’s established culture of openness, trust and integrity should respond to such activity. Meta Results Information Security is committed to protecting Meta Results's employees, partners and the company from illegal or damaging actions by individuals, either knowingly or unknowingly.
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Background
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This policy mandates that any individual who suspects that a theft, breach or exposure of Meta Results Protected data or Meta Results Sensitive data has occurred must immediately provide a description of what occurred via e-mail to sheila@metaresults.com. This e-mail address, phone number, and web page are monitored for Meta Results’s Information Security. This team will investigate all reported thefts, data breaches and exposures to confirm if a theft, breach or exposure has occurred. If a theft, breach or exposure has occurred, the Information Security Administrator will follow the appropriate procedure in place.
2.0 Scope
This policy applies to all whom collect, access, maintain, distribute, process, protect, store, use, transmit, dispose of, or otherwise handle personally identifiable information of Meta Results members or that of its training clients. Any agreements with vendors will contain language similar that protects the organisation.
3.0 Policy Confirmed theft, data breach or exposure of Meta Results Protected data or Meta Results Sensitive data
As soon as a theft, data breach or exposure containing Meta Results Protected data or Meta Results Sensitive data is identified, the process of removing all access to that resource will begin.
The CEO will chair an incident response team to handle the breach or exposure.
The team will include members from:
• IT Infrastructure
• Finance (if applicable)
• Communications
• Member Services (if Member data is affected)
• The affected unit or department that uses the involved system or output or whose data may have been breached or exposed
Confirmed theft, breach or exposure of Meta Results OR Clients Data
The CEO will be notified of the theft, breach or exposure. IT, along with the designated team, will analyze the breach or exposure to determine the root cause.
As provided by Meta Results cyber insurance, the insurer will need to provide access to forensic investigators and experts that will determine how the breach or exposure occurred; the types of data involved; the number of internal/external individuals and/or organizations impacted; and analyze the breach or exposure to determine the root cause.
Develop a communication plan.
Work with Meta Results communications, legal and human resource departments to decide how to communicate the breach to: a) internal employees, b) the public, and c) those directly affected.
3.2 Ownership and Responsibilities
Roles & Responsibilities:
• Sponsors - Sponsors are those members of the Meta Results community that have primary responsibility for maintaining any particular information resource. Sponsors may be designated by any Meta Results Executive in connection with their administrative responsibilities, or by the actual sponsorship, collection, development, or storage of information.
• Information Security Administrator is that member of the Meta Results community, designated by the CEO or the Director, Information Technology (IT) Infrastructure, who provides administrative support for the implementation, oversight and coordination of security procedures and systems with respect to specific information resources in consultation with the relevant Sponsors.
• Users include virtually all members of the Meta Results community to the extent they have authorized access to information resources and may include staff, trustees, contractors, consultants, interns, temporary employees and volunteers.
4.0 Enforcement
Any Meta Results personnel found in violation of this policy may be subject to disciplinary action, up to and including termination of employment. Any third party partner company found in violation may have their network connection terminated.
5.0 Definitions
Encryption or encrypted data – The most effective way to achieve data security. To read an encrypted file, you must have access to a secret key or password that enables you to decrypt it. Unencrypted data is called plain text;
Plain text – Unencrypted data.
Hacker – A slang term for a computer enthusiast, i.e., a person who enjoys learning programming languages and computer systems and can often be considered an expert on the subject(s).
Personally Identifiable Information (PII) - Any data that could potentially identify a specific individual. Any information that can be used to distinguish one person from another and can be used for de-anonymising anonymous data can be considered
Protected data - See PII
Information Resource - The data and information assets of an organisation, department or unit.
Safeguards - Countermeasures, controls put in place to avoid, detect, counteract, or minimise security risks to physical property, information, computer systems, or other assets. Safeguards help to reduce the risk of damage or loss by stopping, deterring, or slowing down an attack against an asset.
Sensitive data - Data that is encrypted or in plain text and contains PII data. See PII above.