Policy Data Safety

Introduction

This Data Safety Policy aligns with the National Institute of Standards and Technology (NIST) standards and incorporates best practices from frameworks such as GDPR, HIPAA, and PCI DSS. This policy governs the protection of sensitive data throughout its lifecycle, ensuring confidentiality, integrity, and availability through mandatory controls, technical safeguards, and risk management practices.

1. Purpose of the Policy

The primary objectives of this Data Safety Policy are to:

• Protect sensitive data against unauthorized access, disclosure, alteration, and destruction

• Ensure compliance with legal, regulatory, and contractual obligations (e.g., NIST, GDPR, HIPAA, PCI DSS)

• Establish a framework for identifying, assessing, and mitigating data risks

• Provide actionable guidelines for effective incident response and remediation

1.1 Scope

This policy applies to all employees, contractors, and third-party service providers who handle sensitive or regulated data across digital, physical, and verbal communication channels.

2. Data Classification

2.1 Classification Levels

2.2 Data Handling Procedures

• Access Control: Enforced via Role-Based Access Control (RBAC) for appropriate data access

• Data Encryption: Required for both data at rest and in transit using industry-standard methods

• Data Masking: Used to obfuscate sensitive information in non-production environments

• Audit Trails: Maintained for all access and modifications to sensitive data

3. Data Protection Measures

3.1 Data Encryption

3.1.1 Data at Rest Encryption

• All sensitive or classified data stored on physical or virtual devices, databases, and cloud storage must be encrypted using AES-256 or a stronger algorithm.

• Encryption keys must be managed using a centralized, secure key management system (KMS).

• Devices containing sensitive data (e.g., laptops, mobile devices) must utilize full-disk encryption.

3.1.2 Data in Transit Encryption

• All sensitive data transmitted across networks must be protected using TLS 1.2 or higher, preferably TLS 1.3.

• HTTPS with strong cipher suites must be enforced for all web-based data transactions.

• VPN or IPsec tunnels must be used for secure internal communications over untrusted networks.

• Email transmission involving restricted or confidential data must use secure email gateways with encryption enabled (e.g., S/MIME or PGP).

3.2 Access Control

• RBAC based on least privilege and separation of duties

• Multi-Factor Authentication (MFA) required for accessing production and sensitive systems

• Centralized identity and access management (IAM) for visibility and enforcement

• Access reviews conducted quarterly or upon role changes

3.3 Data Retention and Secure Deletion

Data Retention:

• Retention periods must align with legal, regulatory, or contractual obligations and be defined in the Data Retention Schedule.

• Archived data must be stored in encrypted, tamper-proof formats.

Secure Deletion:

• When data reaches the end of its lifecycle, it must be securely deleted using NIST 800-88 Rev.1 compliant methods (e.g., cryptographic erasure or multi-pass overwrite).

• For cloud environments, data must be deleted via secure API calls ensuring object-level erasure and invalidation of encryption keys.

• Physical media must be sanitized or destroyed using certified shredding or degaussing services.

4. Incident Response Plan

4.1 Incident Response Team

• A designated team of security, legal, IT, and communications professionals is responsible for managing security incidents.

• Roles and responsibilities are clearly defined and documented in the incident response playbook.

4.2 Incident Detection and Reporting

• Security Information and Event Management (SIEM) tools continuously monitor for anomalies.

• All employees must report suspected incidents immediately through defined communication channels.

4.3 Response Procedures

• Rapid containment of the threat

• Root cause analysis and evidence collection

• Communication to affected parties and regulatory bodies as required

• Lessons learned and post-incident review

5. Training and Awareness

5.1 Training Programs

• Mandatory onboarding and annual training for all employees on data handling and security protocols

• Specialized training for teams managing sensitive data, encryption, and system configurations

5.2 Awareness Campaigns

• Periodic security bulletins and phishing simulations

• Employee feedback loops to measure awareness effectiveness

6. Compliance and Auditing

6.1 Compliance Checks

• Scheduled internal audits

• External audits for compliance with SOC 2, ISO 27001, HIPAA, and others

• Continuous vulnerability scanning and configuration management validation

6.2 Continuous Improvement

• Annual policy reviews or following a major security event

• Incident reviews and audit outcomes inform policy and control improvements

7. Policy Review

This policy will be reviewed annually or upon major infrastructure or regulatory changes and updated to ensure continued alignment with industry best practices and evolving threat landscapes.