Standard Operating Procedure (SOP): Data Security

Effective Date: [DATE]
Prepared by: [REPRESENTATIVE_NAME], [REPRESENTATIVE_TITLE]
Approved by: [REPRESENTATIVE_NAME], [REPRESENTATIVE_TITLE]

Purpose

This SOP outlines the data security protocols for [COMPANY_NAME], a WordPress Experts Marketplace operating via [WEBSITE_URL]. The purpose is to safeguard sensitive data, ensure compliance with GDPR and CCPA regulations, and protect the integrity of our platform, clients, and vendors.

Scope

This SOP applies to all employees, contractors, vendors, and third-party service providers who access, process, or manage data on behalf of [COMPANY_NAME]. It covers:
1. Data classification and handling.
2. Access control and authentication.
3. Incident response.
4. Data backup and recovery.
5. Employee training.
6. Vendor security assessments.
7. Compliance monitoring.
8. Security audits.

Definitions

• Sensitive Data: Includes personally identifiable information (PII), payment information, client project details, and proprietary business data.
• GDPR: General Data Protection Regulation, applicable to EU residents.
• CCPA: California Consumer Privacy Act, applicable to California residents.
• Access Control: Mechanisms to restrict access to data based on roles and responsibilities.
• Incident: Any event that compromises the confidentiality, integrity, or availability of data.

Responsibilities

• Data Protection Officer (DPO): Oversees compliance with GDPR/CCPA, manages incident response, and conducts audits.
• IT Manager: Implements technical controls, manages access permissions, and ensures system security.
• HR Manager: Coordinates employee security training and ensures adherence to policies.
• Vendor Manager: Conducts security assessments for third-party vendors.

Procedures

1. Data Classification Framework

Purpose:

To categorize data based on sensitivity and define handling requirements.

Steps:

1. Identify Data Types:
   - Client PII (e.g., names, emails, payment details).
   - Vendor information (e.g., profiles, contracts).
   - Internal business data (e.g., financials, operational plans).

2. Classify Data:
   - Public: Data intended for public access (e.g., blog posts).
   - Internal: Data restricted to employees (e.g., operational SOPs).
   - Confidential: Sensitive data requiring strict access controls (e.g., client PII).

3. Label Data: Use tools like Azure Information Protection or Google Workspace Labels to tag data appropriately.

4. Define Handling Rules:
   - Public: No restrictions.
   - Internal: Accessible only via company devices.
   - Confidential: Encrypted at rest and in transit, accessible only via VPN.

2. Access Control Procedures

Purpose:

To ensure only authorized personnel access sensitive data.

Steps:

1. Role-Based Access Control (RBAC):
   - Assign roles (e.g., Admin, Vendor Manager, Client Support).
   - Use tools like Okta or Microsoft Azure AD to enforce RBAC.

2. Least Privilege Principle:
   - Grant access only to the data necessary for job functions.

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

4. Multi-Factor Authentication (MFA):
   - Require MFA for all admin accounts using tools like Duo Security.

3. Password and Authentication Policies

Purpose:

To enforce strong authentication practices.

Steps:

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

2. Password Management Tools:
   - Mandate the use of 1Password or LastPass for storing credentials.

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

4. Account Lockout:
   - Lock accounts after 5 failed login attempts.

4. Incident Response Plan

Purpose:

To respond effectively to data breaches or security incidents.

Steps:

1. Detection:
   - Use tools like Splunk or LogRhythm to monitor for anomalies.

2. Containment:
   - Disconnect affected systems from the network.

3. Notification:
   - Notify the DPO within 1 hour.
   - Notify affected clients/vendors within 72 hours (GDPR/CCPA requirement).

4. Investigation:
   - Conduct root cause analysis using forensic tools like FTK Imager.

5. Remediation:
   - Patch vulnerabilities and update security protocols.

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 using AWS Backup or Veeam.

2. Storage:
   - Store backups in geographically redundant locations.

3. Testing:
   - Conduct quarterly recovery tests to ensure backup integrity.

4. Retention Policy:
   - Retain backups for 12 months.

6. Employee Security Training

Purpose:

To educate employees on data security best practices.

Steps:

1. Onboarding Training:
   - Provide security training within the first week of employment.

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

3. Phishing Simulations:
   - Use tools like KnowBe4 to conduct quarterly phishing tests.

4. Metrics:
   - Track training completion rates (target: 100%).

7. Vendor Security Assessment

Purpose:

To evaluate the security posture of third-party vendors.

Steps:

1. Initial Assessment:
   - Require vendors to complete a security questionnaire (e.g., SOC 2 compliance).

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

3. Ongoing Monitoring:
   - Conduct annual reviews of vendor security practices.

8. Compliance Monitoring

Purpose:

To ensure adherence to GDPR and CCPA regulations.

Steps:

1. Data Mapping:
   - Maintain a record of data flows and processing activities.

2. Consent Management:
   - Use tools like OneTrust to manage user consent.

3. Data Subject Requests:
   - Respond to access/deletion requests within 30 days.

4. Audits:
   - Conduct semi-annual compliance audits.

9. Security Audit Schedule

Purpose:

To identify and mitigate vulnerabilities.

Steps:

1. Frequency:
   - Conduct internal audits quarterly and external audits annually.

2. Tools:
   - Use Nessus or Qualys for vulnerability scanning.

3. Reporting:
   - Submit audit reports to the DPO and executive team.

4. Remediation:
   - Address critical vulnerabilities within 7 days.

Escalation Path

1. First Level: IT Manager
2. Second Level: Data Protection Officer
3. Final Level: CEO

Metrics and KPIs

• Incident Response Time: < 1 hour for detection, < 72 hours for notification.
• Backup Success Rate: 100% daily backups completed.
• Training Completion Rate: 100% of employees trained annually.
• Access Review Completion: 100% of access reviews conducted quarterly.

Review Schedule

• Frequency: Semi-annual review of this SOP.
• Responsible Party: Data Protection Officer.

By adhering to this SOP, [COMPANY_NAME] ensures the security of sensitive data, compliance with legal requirements, and the trust of clients and vendors.