Data, Privacy & Security Policy

Document Number: 06
Version: 1.0
Effective Date: [DATE]
Last Reviewed: [DATE]
Approved By: [BOARD/EXECUTIVE BODY]

1. Purpose and Scope

1.1 Purpose

This Data, Privacy & Security Policy establishes comprehensive standards for the collection, processing, storage, and protection of data by [ORGANIZATION NAME] (“Organization”). This policy reflects our commitment to respecting individual privacy, maintaining data security, and complying with applicable privacy regulations including GDPR, CCPA, and other relevant frameworks.

1.2 Scope

This policy applies to:

1.3 Policy Principles

  1. Data Minimization: Collect only what is necessary
  2. Purpose Limitation: Use data only for stated purposes
  3. Privacy by Design: Build privacy into systems and processes
  4. Security First: Protect data with appropriate safeguards
  5. Transparency: Be clear about data practices
  6. Individual Rights: Respect and enable data subject rights

2. Data Collection Principles

2.1 Lawful Basis for Processing

All data collection must have a lawful basis under applicable privacy law:

Basis Use Case Documentation Required
Consent Marketing, optional communications Clear opt-in, granular, revocable
Contract Service delivery, membership Contract terms reference
Legal Obligation Tax reporting, regulatory compliance Legal citation
Vital Interests Emergency contact, health/safety Incident documentation
Public Interest Research in public benefit Research ethics approval
Legitimate Interests Internal analytics, fraud prevention Legitimate Interest Assessment

2.2 Data Minimization

Principle: Collect only data that is directly necessary for the specific purpose identified.

Requirements:

Examples:

Purpose Required Data Not Required
Email newsletter Email address Phone, address, demographics
Event registration Name, email, dietary restrictions SSN, full address (unless shipping)
Donation processing Payment info, name, tax ID (for receipts) Employer, occupation (unless legally required)
Research participation Consent, relevant responses Identifying info (use pseudonymization)

2.3 Purpose Limitation

Principle: Use data only for the purpose for which it was collected, unless compatible additional purpose or new consent obtained.

Compatible Purposes (generally permitted):

Incompatible Purposes (require new basis):

2.4 Collection Methods

Direct Collection:

Automated Collection:

Third-Party Collection:

3. Privacy Commitments

3.1 Core Privacy Pledge

The Organization commits to:

We Will NOT:

We Will:

3.2 Privacy Notice Requirements

All collection points must include a privacy notice containing:

  1. Identity: Who is collecting the data
  2. Contact: Data protection officer contact
  3. Purpose: Why data is being collected
  4. Legal Basis: Lawful basis for processing
  5. Recipients: Who data will be shared with
  6. Transfers: International transfer safeguards
  7. Retention: How long data will be kept
  8. Rights: Data subject rights and how to exercise
  9. Complaints: How to lodge complaints with authorities
  10. Automated Decisions: Existence of profiling (if any)

3.3 Special Categories of Data

The following “special category” data receives enhanced protection:

Category Examples Requirements
Racial/Ethnic Origin Race, ethnicity Explicit consent or substantial public interest
Political Opinions Party affiliation, voting Explicit consent or substantial public interest
Religious Beliefs Religion, denomination Explicit consent or substantial public interest
Health Data Medical conditions, disabilities Explicit consent or health/social care purpose
Biometric Fingerprints, facial recognition Explicit consent, Data Protection Impact Assessment
Genetic DNA, genetic markers Explicit consent, DPIA, specialized security
Sexual Orientation LGBTQ+ status Explicit consent
Criminal History Convictions, offenses Official authority or substantial public interest

Collection of special category data requires:

3.4 Children’s Data

COPPA/GDPR Requirements:

Verifiable Consent Methods:

4. Data Subject Rights

4.1 Rights Overview

Data subjects have the following rights:

Right Description Response Time
Access Obtain copy of personal data 30 days
Rectification Correct inaccurate data 30 days
Erasure Delete data (“right to be forgotten”) 30 days
Restriction Limit processing 30 days
Portability Receive data in machine-readable format 30 days
Objection Object to processing Immediate effect
Automated Decision Human review of automated decisions 30 days

4.2 Request Handling Procedures

Receipt:

Processing:

Response:

Extensions:

4.3 Exemptions and Limitations

Requests May Be Denied When:

Situation Rationale
Legal obligation to retain Tax, employment law requirements
Legal proceedings Litigation hold or defense
Public interest Research, public health, journalism
Manifestly unfounded Harassment, excessive requests
Excessive requests Repetitive, unreasonable burden
Others’ rights Would disclose another person’s data

Partial Response: When portions must be withheld, provide:

5. Security Baseline

5.1 Security Governance

Security Officer: [NAME/TITLE]
Responsibilities:

Security Committee:

5.2 Access Controls

Principle of Least Privilege:

Authentication Requirements:

System Type Minimum Requirement
Standard systems Strong password + MFA
Administrative systems Strong password + hardware MFA
Critical infrastructure Certificate-based + MFA
External access VPN + MFA

Password Policy:

5.3 Encryption Standards

Data at Rest:

Data in Transit:

Key Management:

5.4 Network Security

Perimeter Protection:

Network Segmentation:

Monitoring:

5.5 Endpoint Security

Device Requirements:

Prohibited:

Remote Work:

5.6 Application Security

Development:

Production:

Third-Party:

5.7 Physical Security

Office Security:

Data Center / Server Room:

Remote Work:

6. Incident Response

6.1 Incident Classification

Severity Definition Examples Response Time
Critical Active breach, massive data exposure Ransomware, major unauthorized access Immediate
High Confirmed breach, significant data Unauthorized admin access, customer data exposure 1 hour
Medium Potential breach, limited data Phishing success, misdirected email 4 hours
Low Attempted attack, no breach Failed intrusion attempts, spam 24 hours

6.2 Incident Response Team

Core Team:

Extended Team (as needed):

6.3 Response Procedures

Phase 1: Detection and Analysis (0-1 hour)

  1. Identify and confirm incident
  2. Assign severity classification
  3. Activate response team
  4. Preserve evidence
  5. Document timeline

Phase 2: Containment (1-4 hours)

  1. Isolate affected systems
  2. Block attack vectors
  3. Prevent data exfiltration
  4. Maintain business continuity where safe

Phase 3: Eradication (4-24 hours)

  1. Remove attacker access
  2. Patch vulnerabilities
  3. Clean compromised systems
  4. Verify integrity

Phase 4: Recovery (24-72 hours)

  1. Restore from clean backups
  2. Verify system integrity
  3. Return to normal operations
  4. Enhanced monitoring

Phase 5: Post-Incident (1-4 weeks)

  1. Complete forensic analysis
  2. Document lessons learned
  3. Update security controls
  4. Conduct post-mortem

6.4 Breach Notification

Legal Notification Requirements:

Jurisdiction Trigger Timeline Recipients
GDPR Likely result in risk to rights 72 hours to DPA Supervisory authority; data subjects if high risk
CCPA Unauthorized access Without unreasonable delay California Attorney General; consumers if >500 affected
Other States Varies Varies (typically 30-60 days) Attorney General; affected individuals

Internal Notification:

External Communication:

6.5 Documentation Requirements

Maintain for duration of litigation plus 7 years:

7. Third-Party Processors

7.1 Due Diligence

Before Engagement:

Minimum Security Requirements:

7.2 Data Processing Agreements

All processors must sign DPA containing:

7.3 Ongoing Monitoring

Annual Review:

Continuous Monitoring:

8. International Data Transfers

8.1 Transfer Mechanisms

From EU/EEA:

From UK:

From Other Jurisdictions:

8.2 Transfer Impact Assessment (TIA)

Required before international transfers:

  1. Document laws in destination country
  2. Assess impact on data subject rights
  3. Identify supplementary measures if needed
  4. Implement additional safeguards
  5. Periodic re-assessment

8.3 Supplementary Measures

When destination laws may impede data subject rights:

9. Compliance and Governance

9.1 Privacy by Design

All new projects and systems must undergo:

Privacy Impact Assessment (PIA) for:

Data Protection Impact Assessment (DPIA) for:

9.2 Training and Awareness

Audience Training Frequency
All Staff General security and privacy awareness Annually
Developers Secure coding, privacy engineering Annually
Managers Data handling, incident reporting Annually
New Hires Security and privacy basics Within 30 days
High-Risk Roles Specialized training Semi-annually

9.3 Audits and Assessments

Annual Activities:

Quarterly Activities:

9.4 Record Keeping

Maintain for compliance:

Retention: Duration of processing plus [NUMBER] years

10. Implementation Notes

10.1 Immediate Actions (0-30 Days)

10.2 Short-Term Actions (30-90 Days)

10.3 Ongoing Actions

10.4 Key Contacts

Role Name/Email Responsibilities
Data Protection Officer [EMAIL] GDPR compliance, data subject rights
Security Officer [EMAIL] Security program, incident response
Privacy Counsel [EMAIL] Legal compliance, regulatory matters
IT Security Lead [EMAIL] Technical security implementation

11. Regulatory Compliance Summary

11.1 GDPR (General Data Protection Regulation)

Applicability: Processing personal data of EU residents
Key Requirements:

11.2 CCPA/CPRA (California)

Applicability: For-profit or non-profit with >$25M revenue or >100K CA residents’ data
Key Requirements:

11.3 Other State Laws

Monitor compliance requirements for:

11.4 Industry-Specific

If Applicable:

Document Control

Version Date Author Changes
1.0 [DATE] [AUTHOR] Initial policy

Acknowledgment

I have received, read, and understood the Data, Privacy & Security Policy. I agree to comply with its requirements and understand that violations may result in disciplinary action.

Employee Name: _________
Signature: _________
Date: _________