Data Breach Response Policy

1.0 Purpose

The purpose of the policy is to establish the goals and the vision for the breach response process. This policy will clearly define to whom it applies and under what circumstances, and it will include the definition of a breach, staff roles and responsibilities, standards and metrics (e.g., to enable prioritization of the incidents), as well as reporting, remediation, and feedback mechanisms. The policy shall be well publicized and made easily available to all personnel whose duties involve data privacy and security protection.

Key Media Pty's intentions for publishing a Data Breach Response Policy are to focus significant attention on data security and data security breaches and how Key Media Pty’s established culture of openness, trust and integrity should respond to such activity. Key Media Pty is committed to protecting Key Media Pty 's employees, partners and the company from illegal or damaging actions by individuals, either knowingly or unknowingly.

1.1 Background

This policy mandates that any individual who suspects that a theft, breach or exposure of Key Media Pty protected data or Key Media Pty sensitive data has occurred must immediately provide a description of what occurred via e-mail to [email protected], by calling (02) 8437 4700. This e-mail address, phone number, and web page are monitored by the Key Media Pty’s Information Security Administrator. This team will investigate all reported thefts, data breaches and exposures to confirm if a theft, breach, or exposure has occurred.

2.0 Scope

This policy applies to all whom collect, access, maintain, distribute, process, protect, store, use, transmit, dispose of, or otherwise handle personally identifiable information of Key Media Pty customers or clients. Any agreements with vendors will contain language similar that protects the fund.

3.0 Policy confirmed theft, data breach or exposure of Key Media Pty protected data or Key Media Pty sensitive data

As soon as a theft, data breach or exposure containing Key Media Pty Protected data or Key Media Pty sensitive data is identified, the process of removing all access to that resource will begin.

The Executive Director will be notified of the theft, breach or exposure. IT, along with the designated forensic team, will analyze the breach or exposure to determine the root cause.

In the event of a breach, Key Media Pty communications, legal and human resource departments will decide how to communicate the breach to: a) internal employees, b) the public, and c) those directly affected.

If a theft, breach or exposure has occurred, the Information Security Administrator will follow the appropriate procedure in place and notify those affected, including employees and partners, without undue delay, and in no event later than forty-eight (48) hours, after becoming aware of a personal data breach. Where available, a description of the nature of the personal data breach, the name and contact information of the data protection officer or point of contact, likely consequences of the personal data breach, and description of any measures taken or proposed to address the personal data breach and/or mitigate its possible adverse effects, will be provided.

The Executive Director will chair an incident response team to handle the breach or exposure.

The team will include members from:

  • IT Infrastructure
  • Finance (if applicable)
  • Human Resources
  • The affected unit or department that uses the involved system or output or whose data may have been breached or exposed
  • Additional departments based on the data type involved, Additional individuals as deemed necessary by the Executive Director.

3.2 Ownership and Responsibilities

Roles & Responsibilities:

  • Sponsors - Sponsors are those members of Key Media Pty that have primary responsibility for maintaining any particular information resource. Sponsors may be designated by any Key Media Pty executive in connection with their administrative responsibilities, or by the actual sponsorship, collection, development, or storage of information.
  • Information Security Administrator is that member of the Key Media Pty staff designated by the Executive Director or the CIO, who provides administrative support for the implementation, oversight and coordination of security procedures and systems with respect to specific information resources in consultation with the relevant Sponsors.
  • The Incident Response Team shall be chaired by Executive Management and shall include, but will not be limited to, the following departments or their representatives: IT; Communications; Management; Financial Services; Human Resources.

4.0 Enforcement

Any Key Media Pty personnel found in violation of this policy may be subject to disciplinary action, up to and including termination of employment. Any third party partner company found in violation may have their network connection terminated.

5.0 Definitions

Encryption or encrypted data – The most effective way to achieve data security. To read an encrypted file, you must have access to a secret key or password that enables you to decrypt it. Unencrypted data is called plain text;
Plain text – Unencrypted data.
Hacker – A slang term for a computer enthusiast, i.e., a person who enjoys learning programming languages and computer systems and can often be considered an expert on the subject(s).
Personally Identifiable Information (PII) - Any data that could potentially identify a specific individual. Any information that can be used to distinguish one person from another and can be used for de-anonymizing anonymous data can be considered
Protected data - See PII
Information Resource - The data and information assets of an organization, department or unit.
Safeguards - Countermeasures, controls put in place to avoid, detect, counteract, or minimize security risks to physical property, information, computer systems, or other assets. Safeguards help to reduce the risk of damage or loss by stopping, deterring, or slowing down an attack against an asset.
Sensitive data - Data that is encrypted or in plain text and contains PII data. See PII above.