Standard Operating Procedure (SOP): Data Security

Prepared for: Citadel Innovations
Tagline: Secure choices, made clear.
Effective Date: [DATE]
Prepared by: [REPRESENTATIVE_NAME], [REPRESENTATIVE_TITLE]

Purpose

The purpose of this SOP is to establish a comprehensive framework for data security at Citadel Innovations, a Cybersecurity Reviews Hub, to protect sensitive data, maintain user trust, ensure compliance with applicable regulations (e.g., GDPR, CCPA), and mitigate risks associated with data breaches. This SOP outlines the policies, procedures, and responsibilities for safeguarding data across all operations of [COMPANY_NAME].

Scope

This SOP applies to all employees, contractors, vendors, and third-party service providers who handle or have access to data managed by [COMPANY_NAME]. It covers:
1. Data classification framework
2. Access control procedures
3. Password and authentication policies
4. Incident response plan
5. Data backup and recovery procedures
6. Employee security training requirements
7. Vendor security assessment
8. Compliance monitoring (GDPR/CCPA)
9. Security audit schedule

Definitions

• Sensitive Data: Any data that, if disclosed, could result in harm to individuals or the organization. Examples include user credentials, payment information, and personally identifiable information (PII).
• PII: Personally Identifiable Information, such as names, email addresses, phone numbers, and IP addresses.
• GDPR: General Data Protection Regulation, applicable to EU residents.
• CCPA: California Consumer Privacy Act, applicable to California residents.
• Access Control: Mechanisms to ensure only authorized individuals can access specific data.

Responsibilities

Procedures

1. Data Classification Framework

Purpose:

To categorize data based on sensitivity and criticality to ensure appropriate protection levels.

Steps:

1. Identify Data Types:
   - Classify data into categories: Public, Internal, Confidential, and Sensitive.
   - Examples:

   • Public: Blog posts, general website content.
   • Internal: Employee training materials, internal communications.
   • Confidential: User reviews, unpublished research.
   • Sensitive: User PII, payment details, proprietary algorithms.

2. Label Data:
   - Use metadata tags or file naming conventions to label data according to classification.

3. Define Handling Requirements:
   - Public: No restrictions.
   - Internal: Accessible to employees only.
   - Confidential: Restricted to specific teams. Encryption required for storage and transmission.
   - Sensitive: Strict access controls, encryption, and multi-factor authentication (MFA).

4. Review and Update:
   - Conduct quarterly reviews of data classifications to ensure accuracy.

2. Access Control Procedures

Purpose:

To ensure that only authorized personnel can access specific data and systems.

Steps:

1. Role-Based Access Control (RBAC):
   - Assign access based on job roles.
   - Example: Only the IT team can access server configurations.

2. Access Requests:
   - Require written approval from the DSO for new access requests.

3. Access Reviews:
   - Conduct biannual access reviews to revoke unnecessary permissions.

4. Account Termination:
   - Disable accounts of departing employees within 24 hours of their exit.

3. Password and Authentication Policies

Purpose:

To enforce strong authentication practices and reduce unauthorized access risks.

Steps:

1. Password Requirements:
   - Minimum 12 characters, including uppercase, lowercase, numbers, and symbols.
   - Prohibit reuse of the last 5 passwords.

2. Multi-Factor Authentication (MFA):
   - Require MFA for all systems containing Confidential or Sensitive data.

3. Password Management Tools:
   - Use a password manager like LastPass or 1Password for secure storage.

4. Password Expiry:
   - Require password changes every 90 days.

4. Incident Response Plan

Purpose:

To respond effectively to data breaches or security incidents.

Steps:

1. Detection:
   - Use monitoring tools like Splunk or SolarWinds to detect anomalies.

2. Containment:
   - Isolate affected systems immediately.

3. Notification:
   - Notify the DSO within 1 hour of detection.
   - Notify affected users within 72 hours if PII is compromised (GDPR requirement).

4. Investigation:
   - Conduct a root cause analysis within 5 business days.

5. Remediation:
   - Implement fixes and update policies to prevent recurrence.

5. Data Backup and Recovery Procedures

Purpose:

To ensure data availability in case of loss or corruption.

Steps:

1. Backup Frequency:
   - Perform daily incremental backups and weekly full backups.

2. Storage:
   - Store backups in an encrypted format on AWS S3 or Azure Blob Storage.

3. Testing:
   - Test recovery procedures quarterly.

4. Retention:
   - Retain backups for 12 months.

6. Employee Security Training Requirements

Purpose:

To ensure employees understand and follow data security protocols.

Steps:

1. Onboarding Training:
   - Provide mandatory training within 7 days of hire.

2. Annual Refresher:
   - Conduct annual security training sessions.

3. Phishing Simulations:
   - Conduct quarterly phishing tests using tools like KnowBe4.

7. Vendor Security Assessment

Purpose:

To ensure third-party vendors meet [COMPANY_NAME]’s security standards.

Steps:

1. Initial Assessment:
   - Require vendors to complete a security questionnaire.

2. Contractual Obligations:
   - Include data protection clauses in all vendor agreements.

3. Ongoing Monitoring:
   - Conduct annual reviews of vendor compliance.

8. Compliance Monitoring (GDPR/CCPA)

Purpose:

To ensure adherence to data protection regulations.

Steps:

1. Data Mapping:
   - Maintain an up-to-date inventory of all PII processed.

2. User Rights Requests:
   - Respond to GDPR/CCPA data access or deletion requests within 30 days.

3. Privacy Policy Updates:
   - Review and update the privacy policy annually.

9. Security Audit Schedule

Purpose:

To identify and address vulnerabilities proactively.

Steps:

1. Internal Audits:
   - Conduct quarterly internal audits using tools like Nessus or Qualys.

2. External Audits:
   - Engage a third-party auditor annually. Typical cost: $10,000–$20,000.

3. Reporting:
   - Submit audit findings to the DSO within 10 business days of completion.

Escalation Path

• First Level: IT Team
• Second Level: Data Security Officer
• Third Level: Executive Leadership

Metrics/KPIs

• Incident Response Time: < 2 hours for initial containment.
• Backup Success Rate: 100% of scheduled backups completed.
• Training Completion Rate: 100% of employees trained annually.
• Audit Findings Resolution: 90% of findings resolved within 30 days.

Review Schedule

• This SOP will be reviewed semi-annually by the DSO and updated as necessary to reflect changes in technology, regulations, or business operations.

Prepared by:
[REPRESENTATIVE_NAME]
[REPRESENTATIVE_TITLE]
[DATE]