Data, Privacy & Security Policy

Document Number: 06

Version: 1.0

Effective Date: DATE

Last Reviewed: DATE

Approved By: BOARD/EXECUTIVE BODY

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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:

• All Personnel: Board members, officers, employees, volunteers, contractors, and agents
• All Data: Personal data, organizational data, and third-party data in our custody
• All Systems: Information technology systems, cloud services, and third-party processors
• All Activities: Data collection, processing, storage, transmission, and destruction
• All Locations: Physical offices, remote work, cloud environments, and partner systems

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

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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:

• Document the specific purpose for each data element collected
• Review collections annually for continued necessity
• Delete data when purpose is fulfilled (unless retention required)
• Do not collect "nice to have" data without explicit justification

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):

• Archiving in public interest
• Scientific or historical research
• Statistical analysis (anonymized)
• Internal operational improvements

Incompatible Purposes (require new basis):

• Marketing to non-consented individuals
• Selling or sharing with third parties
• Uses materially different from original purpose
• New data controller relationship

2.4 Collection Methods

Direct Collection:

• Web forms with clear privacy notices
• In-person with informed consent
• Phone with verbal privacy notice

Automated Collection:

• Website analytics (cookie consent required)
• System logs (anonymized where possible)
• Public sources (disclosed in privacy notice)

Third-Party Collection:

• Processor agreements required
• Verify third-party compliance
• Disclose source in privacy notice

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3. Privacy Commitments

3.1 Core Privacy Pledge

The Organization commits to:

We Will NOT:

• Sell personal data to third parties
• Share data with third parties for their marketing
• Use data for purposes beyond those disclosed
• Retain data longer than necessary
• Collect data from children under 13 without parental consent
• Discriminate against individuals exercising privacy rights

We Will:

• Be transparent about data practices
• Provide meaningful privacy choices
• Protect data with appropriate security
• Honor data subject rights promptly
• Notify of breaches as required by law
• Regularly review and improve privacy practices

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:

• Data Protection Impact Assessment (DPIA)
• Enhanced security measures
• Explicit opt-in consent (if consent basis)
• Documentation of lawful basis
• Limited access and strict need-to-know

3.4 Children's Data

COPPA/GDPR Requirements:

• No collection from children under 13 without verifiable parental consent
• For 13-16: Informational notice sufficient (opt-out)
• Clear age gating on websites and services
• No behavioral advertising to children
• Enhanced security for children's data

Verifiable Consent Methods:

• Credit card verification
• Signed consent form
• Video conference with parent
• Phone call with trained staff

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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:

• Acknowledge request within 72 hours
• Verify identity of requestor
• Log request in tracking system

Processing:

• Gather relevant data across systems
• Review for legal exemptions (e.g., legal obligation to retain)
• Prepare response in accessible format
• Quality assurance review

Response:

• Provide data or explanation of action taken
• Explain any exemptions applied
• Include information on appeal process
• Document completion

Extensions:

• Complex requests: May extend to 60 days with notification
• High volume: May extend with notification
• Must explain basis for extension

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:

• Redacted version with explanation
• Basis for withholding (legal citation)
• Appeal rights

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5. Security Baseline

5.1 Security Governance

Security Officer: NAME/TITLE

Responsibilities:

• Security policy development and enforcement
• Risk assessment and management
• Incident response coordination
• Security awareness training
• Vendor security evaluation

Security Committee:

• Cross-functional representation (IT, Legal, Operations)
• Monthly security reviews
• Incident post-mortems
• Policy approval authority

5.2 Access Controls

Principle of Least Privilege:

• Access granted on need-to-know basis
• Role-based access control (RBAC)
• Regular access reviews (quarterly)
• Immediate revocation upon termination

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:

• Minimum 12 characters
• Complexity required (upper, lower, number, special)
• No dictionary words or personal info
• Changed immediately if suspected compromise
• Password manager required

5.3 Encryption Standards

Data at Rest:

• Full disk encryption on all devices
• Database encryption (AES-256)
• Encrypted backups
• Secure key management (HSM or KMS)

Data in Transit:

• TLS 1.3 minimum for web traffic
• VPN for remote access
• SFTP/FTPS for file transfers
• Encrypted email for sensitive data

Key Management:

• Keys stored in hardware security module or cloud KMS
• Key rotation annually or on compromise
• Separation of duties for key access
• Key escrow for business continuity

5.4 Network Security

Perimeter Protection:

• Next-generation firewall with IDS/IPS
• DDoS protection
• Web application firewall (WAF)
• Regular penetration testing (annual)

Network Segmentation:

• VLAN separation by function
• Critical systems isolated
• Guest network separate from production
• Zero-trust architecture for remote access

Monitoring:

• 24/7 security monitoring
• SIEM for log aggregation and analysis
• Anomaly detection
• Threat intelligence feeds

5.5 Endpoint Security

Device Requirements:

• Organization-approved devices for work data
• MDM enrollment for all mobile devices
• EDR (Endpoint Detection and Response) on all endpoints
• Automatic updates and patching

Prohibited:

• Personal email for work data
• Unapproved cloud storage
• Unencrypted removable media
• Jailbroken/rooted devices

Remote Work:

• VPN required for system access
• Home network security recommendations
• Dedicated workspace guidance
• No work in public spaces with visible screens

5.6 Application Security

Development:

• Secure coding standards
• Code review requirements
• Dependency vulnerability scanning
• Static and dynamic security testing (SAST/DAST)

Production:

• Regular vulnerability scanning
• Patch management (critical: 24 hours, high: 7 days)
• Change management process
• Segregated production access

Third-Party:

• Security assessment before procurement
• Annual security review
• Right to audit clauses
• Incident notification requirements

5.7 Physical Security

Office Security:

• Badge access control
• Visitor escort required
• Clean desk policy
• Secure disposal (shredding)

Data Center / Server Room:

• Multi-factor physical access
• Environmental controls
• CCTV monitoring
• Fire suppression systems

Remote Work:

• Secure home office setup
• Privacy screens for laptops
• Safe storage of devices
• No unattended devices in public

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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:

• Security Officer (Incident Commander)
• IT/Systems Administrator
• Legal Counsel
• Communications Lead
• Executive Sponsor

Extended Team (as needed):

• HR (personnel incidents)
• External forensics
• Law enforcement liaison
• Insurance carrier
• Affected system owners

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:

• Board Chair: Within 4 hours for Critical/High
• Full Board: Within 24 hours
• Insurance carrier: Within policy timeframe

External Communication:

• Draft by Legal and Communications
• Board approval required
• Transparent but legally protective
• Offer credit monitoring if SSN/financial involved

6.5 Documentation Requirements

Maintain for duration of litigation plus 7 years:

• Incident timeline
• All communications
• Forensic analysis
• Response actions taken
• Notification records
• Post-incident report
• Lessons learned

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7. Third-Party Processors

7.1 Due Diligence

Before Engagement:

• Security questionnaire
• SOC 2 Type II or equivalent review
• Data Processing Agreement (DPA) execution
• Privacy Shield or SCCs for international transfers

Minimum Security Requirements:

• Encryption at rest and in transit
• Access controls and MFA
• Incident response capabilities
• Annual penetration testing
• Business continuity plan

7.2 Data Processing Agreements

All processors must sign DPA containing:

• Processing instructions and limitations
• Subprocessor authorization and notification
• Security measures and audits
• Breach notification (24-48 hours)
• Data subject rights assistance
• Return/destruction of data upon termination
• Audit rights

7.3 Ongoing Monitoring

Annual Review:

• Security certification renewal
• Incident history review
• Compliance attestation
• Contract compliance verification

Continuous Monitoring:

• Threat intelligence on processors
• News and breach monitoring
• Performance and availability

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8. International Data Transfers

8.1 Transfer Mechanisms

From EU/EEA:

• Standard Contractual Clauses (SCCs) - mandatory
• Adequacy decisions (UK, limited others)
• Binding Corporate Rules (if applicable)

From UK:

• UK Addendum to SCCs
• UK adequacy regulations

From Other Jurisdictions:

• Local law compliance
• Contractual safeguards
• Data localization requirements

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:

• Enhanced encryption (data encrypted with keys held in origin country)
• Pseudonymization before transfer
• Strict purpose limitation
• Enhanced monitoring

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9. Compliance and Governance

9.1 Privacy by Design

All new projects and systems must undergo:

Privacy Impact Assessment (PIA) for:

• New data collections
• New processing activities
• Significant system changes
• New vendor relationships

Data Protection Impact Assessment (DPIA) for:

• Systematic monitoring
• Large-scale special category processing
• Automated decision-making with significant effects
• New technologies (AI, biometrics)

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:

• Security risk assessment
• Privacy compliance audit
• Penetration testing
• Vulnerability scanning
• Third-party security reviews

Quarterly Activities:

• Access reviews
• Policy compliance spot checks
• Incident metrics review
• Security metrics review

9.4 Record Keeping

Maintain for compliance:

• Processing activities records (ROPA)
• Consent records
• Data subject request logs
• DPIAs and PIAs
• Security assessments
• Incident reports
• Training records
• Processor agreements

Retention: Duration of processing plus NUMBER years

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10. Implementation Notes

10.1 Immediate Actions (0-30 Days)

• Appoint Data Protection Officer / Privacy Officer
• Inventory all data processing activities (ROPA)
• Map all data flows and international transfers
• Review and update privacy notices
• Implement consent management platform
• Establish data subject request intake process

10.2 Short-Term Actions (30-90 Days)

• Complete DPIAs for high-risk processing
• Audit third-party processors for DPA compliance
• Deploy data subject rights request management system
• Conduct security risk assessment
• Implement security monitoring and alerting
• Develop incident response playbooks

10.3 Ongoing Actions

• Monthly security metrics review
• Quarterly access reviews
• Quarterly privacy compliance checks
• Annual penetration testing
• Annual policy and training refresh
• Annual ROPA update
• Continuous consent and preference management

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 |

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11. Regulatory Compliance Summary

11.1 GDPR (General Data Protection Regulation)

Applicability: Processing personal data of EU residents

Key Requirements:

• Lawful basis for processing
• Data subject rights
• Privacy by design
• Breach notification (72 hours)
• DPO (if required by scale/sensitivity)
• Records of processing activities

11.2 CCPA/CPRA (California)

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

Key Requirements:

• Privacy notice at collection
• Right to know, delete, opt-out
• Do not sell/share (opt-out link)
• Service provider contracts
• Consumer request fulfillment

11.3 Other State Laws

Monitor compliance requirements for:

• Virginia CDPA
• Colorado CPA
• Connecticut CTDPA
• Utah UCPA
• Emerging state privacy laws

11.4 Industry-Specific

If Applicable:

• HIPAA (health information)
• FERPA (educational records)
• GLBA (financial information)
• COPPA (children's online privacy)

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Document Control

| Version | Date | Author | Changes |

|---------|------|--------|---------|

| 1.0 | DATE | AUTHOR | Initial policy |

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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: _________________________