Data Breach Policy

1. Introduction

Vendo recognizes the importance of maintaining the security and confidentiality of all data we collect, store, and process. This Data Breach Policy establishes the procedures and responsibilities for identifying, reporting, containing, investigating, and remediating data breaches involving Vendo's systems or data, including personal data and confidential information.

2. Purpose

The purpose of this policy is to:

• Define what constitutes a data breach
• Establish procedures for responding to data breaches
• Define roles and responsibilities for data breach response
• Ensure compliance with relevant laws, regulations, and contractual obligations
• Minimize the impact of data breaches on affected individuals and on Vendo

3. Scope

This policy applies to:

• All employees, contractors, consultants, temporary workers, and other personnel affiliated with Vendo
• All data assets, systems, networks, and applications owned, operated, or managed by Vendo, including those hosted in third-party environments
• All types of data, including personal data, confidential information, and intellectual property

4. Definition of a Data Breach

A data breach is a security incident that results in the unauthorized access, acquisition, use, modification, disclosure, or destruction of data. Data breaches can be categorized as follows:

• Confidentiality breach: Unauthorized or accidental disclosure of or access to data
• Integrity breach: Unauthorized or accidental alteration of data
• Availability breach: Unauthorized or accidental loss of access to or destruction of data

Examples of data breaches include but are not limited to:

• Unauthorized access to systems or databases
• Theft or loss of devices containing data (laptops, mobile devices, storage media)
• Unauthorized disclosure of data to third parties
• Malware infections that compromise data security
• Phishing attacks that result in unauthorized access to accounts or systems
• Inadvertent disclosure of data due to human error

5. Roles and Responsibilities

5.1 Data Breach Response Team (DBRT)

The Data Breach Response Team consists of:

• Chief Information Security Officer (CISO) - Team Lead
• Data Protection Officer (DPO)
• IT Security Manager
• Legal Counsel
• Corporate Communications Representative
• Other members as appropriate for specific incidents

5.2 DBRT Responsibilities

• Assess the severity and scope of data breaches
• Determine notification requirements
• Coordinate response activities
• Communicate with affected parties
• Document breach-related activities
• Conduct post-breach analysis

5.3 All Personnel

• Immediately report suspected or confirmed data breaches
• Cooperate with the DBRT during investigations
• Assist in containment and remediation activities as directed
• Maintain confidentiality regarding breach information

6. Data Breach Response Process

6.1 Identification and Reporting

Any individual who suspects or becomes aware of a data breach must immediately report it to the IT Help Desk, their manager, the CISO, or the DPO. Reports should include:

• Date and time of discovery
• Description of the incident
• Types of data potentially affected
• Systems or applications potentially affected
• Any actions already taken to address the breach

The CISO must be notified of all potential data breaches within 24 hours of discovery.

6.2 Initial Assessment

Upon receiving a report of a potential data breach, the CISO will:

• Assemble the appropriate members of the DBRT
• Conduct an initial assessment to determine if a data breach has occurred
• Determine the nature, scope, and severity of the breach
• Identify the types of data affected and the potential impact
• Determine if the breach involves personal data subject to regulatory requirements

6.3 Containment

The DBRT will work to contain the breach and prevent further unauthorized access to or disclosure of data. Containment activities may include:

• Isolating affected systems or networks
• Shutting down systems if necessary
• Revoking or changing access credentials
• Removing unauthorized content from websites or repositories
• Recovering or securing lost or stolen devices

6.4 Investigation

The DBRT will conduct a thorough investigation to:

• Determine the root cause of the breach
• Identify all affected data, systems, and individuals
• Assess the potential harm to affected individuals
• Determine if the breach is ongoing or has been contained
• Identify any vulnerabilities that contributed to the breach
• Collect and preserve evidence for potential legal proceedings

6.5 Notification

The DBRT, in consultation with Legal Counsel, will determine notification requirements based on applicable laws, regulations, and contractual obligations. Notifications may be required for:

• Data protection authorities (e.g., within 72 hours under GDPR)
• Affected individuals
• Law enforcement agencies
• Customers or partners
• Payment card issuers or processors (for payment card breaches)
• Insurance providers

Notifications will include:

• Description of the breach
• Types of data affected
• Measures taken to address the breach
• Recommendations for affected individuals to protect themselves
• Contact information for questions or concerns

6.6 Remediation

The DBRT will develop and implement a remediation plan to:

• Address the vulnerabilities that led to the breach
• Restore affected systems and data
• Implement additional security controls as necessary
• Provide support for affected individuals (e.g., credit monitoring)
• Update policies, procedures, or training as needed

6.7 Post-Breach Analysis

Following the resolution of a data breach, the DBRT will conduct a post-breach analysis to:

• Document the breach and response activities
• Assess the effectiveness of the response
• Identify lessons learned
• Recommend improvements to prevent similar breaches
• Update the data breach response plan as needed

7. Data Breach Classification

Data breaches are classified based on their severity and potential impact:

• Low: Limited impact, no sensitive data exposed, affecting few individuals
• Medium: Moderate impact, potential exposure of some sensitive data, affecting a moderate number of individuals
• High: Significant impact, exposure of sensitive data, affecting a large number of individuals
• Critical: Severe impact, exposure of highly sensitive data, affecting a large number of individuals, potential legal or regulatory consequences

The classification of a breach will determine the level of response and resources allocated.

8. Documentation and Record Keeping

The DBRT will maintain detailed records of all data breaches, including:

• Date and time of the breach
• Date and time of discovery
• Description of the breach
• Types of data affected
• Number of individuals affected
• Response actions taken
• Notifications made
• Remediation measures implemented
• Lessons learned

All breach documentation will be stored securely and retained in accordance with Vendo's data retention policies and applicable legal requirements.

9. Training and Awareness

Vendo will provide training and awareness programs to ensure that all personnel understand:

• How to identify potential data breaches
• How to report suspected breaches
• Their responsibilities in preventing breaches
• Their roles in the breach response process

Members of the DBRT will receive specialized training on data breach response procedures.

10. Policy Review

This policy will be reviewed annually, or more frequently if significant changes occur in Vendo's business, technology environment, or regulatory requirements. Updates to the policy will be communicated to all personnel.

11. References

This policy is supported by the following related documents:

• Information Security and Data Protection Policy
• Security Incident Response Policy
• Data Protection Impact Assessment Procedure
• Privacy Policy
• Other supporting standards, procedures, and guidelines