HOW WE HANDLE DATA BREACHES
Internal Breach Response Policy

1. IMMEDIATE RESPONSE (First Hour)
   - STOP: Contain the breach immediately
   - ASSESS: Determine scope and severity
   - NOTIFY: Alert the incident response team
   - DOCUMENT: Begin incident log

2. INCIDENT RESPONSE TEAM ROLES
   - Incident Commander: [NAME/ROLE]
   - Technical Lead: [NAME/ROLE]
   - Communications Lead: [NAME/ROLE]
   - Legal/Compliance: [NAME/ROLE]

3. CONTAINMENT ACTIONS (Within 2 Hours)
   - Isolate affected systems
   - Preserve evidence
   - Change relevant passwords/access codes
   - Secure physical areas if needed

4. ASSESSMENT AND INVESTIGATION (Within 24 Hours)
   - Determine what data was accessed
   - Identify number of affected individuals
   - Assess risk to data subjects
   - Document all findings

5. NOTIFICATION REQUIREMENTS
   - Regulators: Within 72 hours of awareness
   - Data subjects: Without undue delay if high risk
   - Law enforcement: If criminal activity suspected
   - Insurance: Check policy requirements

6. COMMUNICATION GUIDELINES
   - Be honest and transparent
   - Provide clear, non-technical explanations
   - Offer practical steps for affected individuals
   - Coordinate all external communications

7. RECOVERY AND LESSONS LEARNED
   - Implement fixes to prevent recurrence
   - Update security measures
   - Review and update this policy
   - Conduct post-incident review

8. RECORD KEEPING
   - Maintain detailed incident logs
   - Document all decisions and actions
   - Keep copies of all communications
   - Retain records for regulatory compliance

EMERGENCY CONTACTS:
- IT Security: [PHONE/EMAIL]
- Data Protection Officer: [PHONE/EMAIL]
- Insurance: [PHONE/EMAIL]
- Key Regulators: [PHONE/EMAIL]

Last Updated: [DATE]
Next Review: [DATE]