Data Breach Response Policy
Created by or for the SANS Institute.
Feel free to modify or use for your organization. If you have a policy to contribute, please
send e-mail to stephen@sans.edu
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 prioritization of the incidents), as well as reporting, remediation, and
feedback mechanisms. The policy shall be well publicized and made easily
available to all personnel whose duties involve data privacy and security
protection.
<ORGANIZATION NAME> 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 <ORGANIZATION NAME>’s
established culture of openness, trust and integrity should respond to such
activity. <ORGANIZATION NAME> Information Security is committed to
protecting <ORGANIZATION NAME>'s employees, partners and the company from
illegal or damaging actions by individuals, either knowingly or unknowingly.
1.1
Background
This policy mandates that any individual who suspects that a
theft, breach or exposure of <ORGANIZATION NAME> Protected data or <ORGANIZATION
NAME> Sensitive data has occurred must immediately provide a description of
what occurred via e-mail to Helpdesk@<ORGANIZATION NAME>.org, by calling
555-1212, or through the use of the help desk reporting web page at http://<ORGANIZATION
NAME>. This e-mail address, phone number, and web page are monitored by the <ORGANIZATION
NAME>’s Information Security Administrator. 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 or Protected Health Information
(PHI) of <ORGANIZATION NAME> members. Any agreements with vendors will
contain language similar that protects the fund.
3.0 Policy Confirmed
theft, data breach or exposure of <ORGANIZATION NAME> Protected data or <ORGANIZATION
NAME> Sensitive data
As soon as a theft, data breach or exposure containing <ORGANIZATION
NAME> Protected data or <ORGANIZATION NAME> Sensitive data is
identified, the process of removing all access to that resource will begin.
The Executive Director will chair an incident response team
to handle the breach or exposure.
The team will include members from:
• IT
Infrastructure
• IT
Applications
• Finance (if
applicable)
• Legal
• Communications
• Member
Services (if Member data is affected)
• Human
Resources
• The affected
unit or department that uses the involved system or output or whose data may
have been breached or exposed
• Additional
departments based on the data type involved, Additional individuals as deemed
necessary by the Executive Director
Confirmed theft, breach or exposure of <ORGANIZATION
NAME> data
The Executive Director will be notified of the theft, breach
or exposure. IT, along with the designated forensic team, will analyze the
breach or exposure to determine the root cause.
Work with Forensic Investigators
As provided by <ORGANIZATION NAME> 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 <ORGANIZATION NAME> 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 <ORGANIZATION NAME> community that have
primary responsibility for maintaining any particular information resource.
Sponsors may be designated by any <ORGANIZATION NAME> 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 <ORGANIZATION NAME>
community, designated by the Executive Director 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 <ORGANIZATION NAME> community to the extent
they have authorized access to information resources, and may include staff,
trustees, contractors, consultants, interns, temporary employees and
volunteers.
• The Incident
Response Team shall be chaired by Executive Management and shall include, but
will not be limited to, the following departments or their representatives:
IT-Infrastructure, IT-Application Security; Communications; Legal; Management;
Financial Services, Member Services; Human Resources.
4.0 Enforcement
Any < ORGANIZATION NAME > 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).
Protected Health
Information (PHI) - Under US law is any information about health status,
provision of health care, or payment for health care that is created or
collected by a "Covered Entity" (or a Business Associate of a Covered
Entity), and can be linked to a specific individual.
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-anonymizing anonymous data can be considered
Protected data -
See PII and PHI
Information Resource -
The data and information assets of an organization, department or unit.
Safeguards -
Countermeasures, controls put in place to avoid, detect, counteract, or
minimize 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 or PHI data. See PII and PHI above.
6.0 Revision History
Version
|
Date of Revision
|
Author
|
Description of Changes
|
1.0
|
August 17, 2016
|
Stephen Northcutt
|
Initial version
|
1.0
|
|
|
|
