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. 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 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:

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