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SOP: Data Security

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Standard Operating Procedure (SOP): Data Security

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

Purpose

The purpose of this SOP is to establish a comprehensive framework for ensuring the security of data managed by [COMPANY_NAME] in its role as a provider of Microsoft 365 (M365) backup and compliance services. This document outlines the procedures for data classification, access control, password and authentication policies, incident response, data backup and recovery, employee training, vendor assessments, compliance monitoring, and security audits.

Scope

This SOP applies to all employees, contractors, and third-party vendors of [COMPANY_NAME] who interact with customer data, internal systems, or M365 environments. It covers all data processed, stored, or transmitted by [COMPANY_NAME] as part of its M365 backup and compliance services.

Definitions

  • M365: Microsoft 365, a suite of cloud-based productivity tools.
  • PII: Personally Identifiable Information.
  • GDPR: General Data Protection Regulation.
  • CCPA: California Consumer Privacy Act.
  • RTO: Recovery Time Objective.
  • RPO: Recovery Point Objective.

Responsibilities

  • Data Security Officer (DSO): Oversees implementation and compliance with this SOP.
  • IT Team: Implements technical controls, monitors systems, and responds to incidents.
  • HR Department: Ensures employees complete security training.
  • Compliance Officer: Monitors adherence to GDPR, CCPA, and other applicable regulations.
  • Vendors: Adhere to security requirements outlined in vendor agreements.

Procedures

1. Data Classification Framework

  1. Purpose: Ensure data is categorized based on sensitivity and criticality to enable appropriate security measures.
  2. Steps:
    - Classify all data into the following categories:
    • Public: Non-sensitive data available to the public.
    • Internal: Data used internally but not sensitive.
    • Confidential: Sensitive business data, including customer contracts and operational details.
    • Restricted: Highly sensitive data, including PII and financial information.
    • Use M365 tools like Microsoft Purview for automated data classification.
    • Review classifications quarterly and update as necessary.
  3. Metrics:
    - 100% of data classified within 30 days of creation or receipt.
    - Quarterly review completion rate.

2. Access Control Procedures

  1. Purpose: Limit access to data based on roles and responsibilities.
  2. Steps:
    - Implement Role-Based Access Control (RBAC) using Azure Active Directory (AAD).
    - Enforce the principle of least privilege for all accounts.
    - Use Conditional Access policies in AAD to restrict access based on location, device, and risk level.
    - Conduct quarterly access reviews to ensure permissions are current.
  3. Metrics:
    - Zero unauthorized access incidents per quarter.
    - 100% completion of quarterly access reviews.

3. Password and Authentication Policies

  1. Purpose: Strengthen account security through robust authentication measures.
  2. Steps:
    - Require Multi-Factor Authentication (MFA) for all accounts.
    - Enforce password complexity: minimum 12 characters, including uppercase, lowercase, numbers, and symbols.
    - Use Azure AD Password Protection to block commonly used passwords.
    - Rotate passwords every 90 days for privileged accounts.
  3. Metrics:
    - 100% MFA adoption across all accounts.
    - Zero password-related breaches per quarter.

4. Incident Response Plan

  1. Purpose: Ensure rapid and effective response to security incidents.
  2. Steps:
    - Detect incidents using Microsoft Sentinel for real-time monitoring and alerts.
    - Classify incidents as Low, Medium, High, or Critical.
    - Respond based on severity:
    • Low/Medium: Resolve within 24 hours.
    • High: Resolve within 8 hours.
    • Critical: Immediate response, resolved within 4 hours.
    • Document incidents in an incident log.
    • Conduct post-incident reviews to identify root causes and preventive measures.
  3. Metrics:
    - Incident resolution times within SLA.
    - 100% of incidents documented and reviewed.

5. Data Backup and Recovery Procedures

  1. Purpose: Ensure data availability and integrity through reliable backup and recovery processes.
  2. Steps:
    - Use Microsoft 365 Backup Solutions (e.g., Veeam Backup for M365 or AvePoint Cloud Backup).
    - Configure backups to meet RTO of 4 hours and RPO of 15 minutes.
    - Test recovery processes monthly to ensure functionality.
    - Retain backups for a minimum of 7 years to meet compliance requirements.
  3. Metrics:
    - 100% successful backup completion rate.
    - Monthly recovery test success rate.

6. Employee Security Training Requirements

  1. Purpose: Equip employees with the knowledge to identify and mitigate security risks.
  2. Steps:
    - Conduct mandatory security training during onboarding.
    - Provide quarterly refresher courses on topics such as phishing, social engineering, and data handling.
    - Use platforms like KnowBe4 or Cofense for phishing simulations.
  3. Metrics:
    - 100% employee training completion rate.
    - Phishing simulation failure rate below 5%.

7. Vendor Security Assessment

  1. Purpose: Ensure third-party vendors meet [COMPANY_NAME]’s security standards.
  2. Steps:
    - Require vendors to complete a security questionnaire.
    - Review vendor compliance with ISO 27001, SOC 2, or equivalent certifications.
    - Conduct annual vendor security audits.
    - Include security requirements in vendor contracts.
  3. Metrics:
    - 100% of vendors assessed annually.
    - Zero vendor-related security incidents.

8. Compliance Monitoring

  1. Purpose: Maintain compliance with GDPR, CCPA, and other applicable regulations.
  2. Steps:
    - Use Microsoft Purview Compliance Manager to track compliance status.
    - Conduct annual Data Protection Impact Assessments (DPIAs).
    - Maintain records of processing activities (ROPA) for GDPR compliance.
    - Provide CCPA-mandated opt-out mechanisms for data subjects.
  3. Metrics:
    - 100% compliance with GDPR/CCPA requirements.
    - Zero regulatory violations.

9. Security Audit Schedule

  1. Purpose: Regularly evaluate the effectiveness of security controls.
  2. Steps:
    - Conduct internal security audits quarterly.
    - Engage a third-party auditor annually for penetration testing and compliance reviews.
    - Use tools like Qualys or Tenable.io for vulnerability scanning.
    - Address audit findings within 30 days.
  3. Metrics:
    - 100% of audits completed on schedule.
    - 100% of audit findings resolved within 30 days.

Escalation Path

  • Critical Incidents: Escalate immediately to the DSO and Executive Leadership.
  • High Incidents: Escalate to the IT Team Lead within 1 hour.
  • Compliance Issues: Escalate to the Compliance Officer within 24 hours.

Review Schedule

  • This SOP will be reviewed semi-annually by the DSO and Compliance Officer.
  • Updates will be communicated to all stakeholders within 7 days of approval.

Approval

Prepared by:
[REPRESENTATIVE_NAME]
[REPRESENTATIVE_TITLE]

Approved by:
[REPRESENTATIVE_NAME]
[REPRESENTATIVE_TITLE]

Date: [DATE]

This SOP is now ready for implementation by [COMPANY_NAME].

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