Data Breach Response 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 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.
 
Vizias, LLC 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 Vizias, LLC’s established culture of openness, trust and integrity should respond to such activity. Vizias, LLC Administration is committed to protecting Vizias, LLC's employees, partners and the company from illegal or damaging actions by individuals, either knowingly or unknowingly.
           
1.2 Background
This policy mandates that any individual who suspects that a theft, breach or exposure of Vizias, LLC Protected data or Vizias, LLC Sensitive data has occurred must immediately provide a description of what occurred via e-mail to info@vizias.com or through the use of the web page at https://vizias.com.  This e-mail address and web page are monitored by the Vizias, LLC’s administrative team. 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 Administrator will follow the appropriate procedure in place.
           
2.0 Scope
This policy applies to all who collect, access, maintain, distribute, process, protect, store, use, transmit, dispose of, or otherwise handle personally identifiable information or Protected Health Information (PHI) of Vizias, LLC members and clients.
      
3.0 Policy of Confirmed theft, data breach or exposure of Vizias, LLC Protected data or Vizias, LLC Sensitive data
As soon as a theft, data breach or exposure containing Vizias, LLC Protected data or Vizias, LLC Sensitive data is identified, the process of removing all access to that resource will begin.
 
The Chief Technology Officer will chair an incident response team to handle the breach or exposure.
 
The team will include:
•           Chief Executive Officer
•           Chief Operations Officer
•           Chief Technology Officer
•           Human Resources
•           Finance
 
3.1 Confirmed theft, breach or exposure of Vizias, LLC data
The Chief Executive Officer will be notified of the theft, breach or exposure. Administration and the CTO will analyze the breach or exposure to determine the root cause.
 
3.2 Incident Timeline
 
Discovery/Reporting

  • Determination that an incident has happened

  • Involvement of Management

  • Involvement of CTO

 
Immediate Response (0--1 Business Day)

  • Containment

  • Opening of Incident Case Files

  • Escalation

  • Activation of the Incident Response Team and/or Alternate Plans

 
Continuing Response (0-15+ days)

  • Analysis and Planning

  • Investigation

  • Mitigation and Correction

  • Notification

  • Closing of Incident Case File

  • Reporting


3.3 Work with Forensic Investigators (if necessary)
Vizias, LLC will 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. 
 
3.4 Develop a communication plan
Vizias, LLC financial, administrative and human resource team members will decide how to communicate the breach to: a) internal employees, b) the public, and c) those directly affected within 48 hours of discovering the breach.
 
4.0 Ownership and Responsibilities
Roles & Responsibilities:
 
•           Sponsors - Sponsors are those members of the Vizias, LLC community that have primary responsibility for maintaining any particular information resource. Sponsors may be designated by any Vizias, LLC Executive in connection with their administrative responsibilities, or by the actual sponsorship, collection, development, or storage of information.
•           Administrator is that member of the Vizias, LLC community, designated by the Chief Executive Officer, 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 Vizias, LLC 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 Chief Technology Officer and shall include, but will not be limited to, the following departments or their representatives: Management; Financial Services, Human Resources.
 
4.0 Enforcement
Any Vizias, LLC 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.