ImgBot Data Breach Response Policy

This policy is based on the 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.

ImgBot 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 ImgBot’s established culture of openness, trust and integrity should respond to such activity. ImgBot Information Security is committed to protecting ImgBot'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 ImgBot Protected data or ImgBot Sensitive data has occurred must immediately provide a description of what occurred via e-mail to help@imgbot.net. This e-mail address is monitored by ImgBot’s Information Security Administrator (@dabutvin). ImgBot 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 (PII) or Protected Health Information (PHI) of ImgBot members. Any agreements with vendors will contain similar protective language.

3.0 Policy Confirmed theft, data breach or exposure of ImgBot Protected data or ImgBot Sensitive data

As soon as a theft, data breach, or exposure containing ImgBot Protected data or ImgBot Sensitive data is identified, the process of removing all access to that resource will begin.

The Executive Director (@dabutvin) will be notified of the theft, breach, or exposure and will analyze the breach or exposure to determine the root cause. Additionally the Executive Director will 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 ImgBot community that have primary responsibility for maintaining any particular information resource. Sponsors may be designated by any ImgBot 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 ImgBot community, designated by the Executive Director, 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 ImgBot 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 ImgBot 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 access to ImgBot 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 if 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 1.0

• June 23, 2018
• Author: @dabutvin
• Initial version