Data Protection Policy

   Last Update Status: Updated 25 Apr 2024

1. Introduction

In today's digital age, data is one of the most valuable assets for organizations. BITHOST PRIVATE LIMITED recognizes the critical importance of protecting data to maintain trust with clients, partners, and stakeholders. This Data Protection Policy outlines our commitment to ensuring the confidentiality, integrity, and availability of data within our organization.

2. Purpose

The purpose of this policy is to establish a standard for the secure use and protection of company and it's client data.

3. Scope

This policy applies to all data generated, collected, processed, or stored by BITHOST PRIVATE LIMITED, regardless of the format or medium. It covers all systems, processes, and personnel involved in handling company data, whether digital or physical.

4. Policy

  1. Data Classification
    Data classification is essential for determining the appropriate level of protection required for different types of data. Our policy defines various classification levels, such as public, internal, confidential, and highly confidential, each with specific handling requirements based on sensitivity and criticality.
    1. Confidentiality
      1. Financial reports containing revenue projections.
      2. Intellectual property such as patents, trademarks, and proprietary algorithms.
      3. Employee contracts and personnel records.
      4. Non-disclosure agreements (NDAs) with clients or partners.
      5. Clients shared credentials for development, deployment, any for any other reason.
    3. Integrity
      1. Database records for customer transactions.
      2. Software source code and configuration files.
      3. Development specifications for products.
      4. Research data for analytic experiments.
    5. Availability
      1. Customer-facing web applications and e-commerce platforms.
      2. Emergency response procedures and disaster recovery plans.
      3. Real-time monitoring data for network, server, infra performance.
    7. Regulatory Compliance
      1. Healthcare records protected by HIPAA regulations.
      2. Personally identifiable information (PII) subject to GDPR requirements.
      3. Archived emails and correspondence for legal purposes.
      4. Temporary backups stored in a disaster recovery facility.
      5. Data marked for deletion after reaching the end of its retention period.
    9. Data Sensitivity
      1. Top-secret BITHOST documents containing classified information.
      2. Trade secrets and proprietary formulas for product or client application development.
      3. Publicly available marketing materials and press releases.
      4. nternal memos and communications for company employees.
    11. Access Control
      1. User account credentials and authentication tokens.
      2. Administrative privileges for network, server infrastructure devices.
      3. Departmental budgets and financial forecasts accessible only to authorized personnel.
      4. Customer support tickets and sensitive client communications restricted to relevant teams.
  3. Data Handling Procedures
    1. Data Collection and Acquisition
      1. Implementing secure web forms to collect customer information for registration or purchases.
      2. Conducting surveys or interviews to gather feedback from clients or stakeholders.
      3. Integrating APIs to retrieve real-time data from external sources.
    3. Data Storage and Retention
      1. Utilizing encrypted databases to store sensitive customer data, company data.
      2. Implementing hierarchical storage systems to archive historical data while keeping frequently accessed data readily available.
      3. Defining data retention policies to comply with regulatory requirements and business needs, such as retaining financial records for auditing purposes.
      4. Regularly backing up critical data to secure off-site locations or cloud storage platforms to prevent data loss in case of disasters or hardware failures.
    5. Data Processing and Analysis
      1. Using data analytics tools to extract insights from large datasets and identify trends or patterns.
      2. Employing data transformation techniques such as normalization or aggregation to prepare raw data for analysis.
      3. Conducting data cleansing activities to remove duplicates, errors, or inconsistencies from datasets.
      4. Implementing machine learning algorithms to automate decision-making processes or predict future outcomes based on historical data.
    7. Data Transmission and Sharing
      1. Encrypting sensitive data before transmitting it over public networks or internet to ensure confidentiality and integrity.
      2. Establishing secure communication channels, such as Virtual Private Networks (VPNs) or Secure File Transfer Protocol (SFTP), for transmitting confidential files between remote locations.
      3. Implementing access controls and user authentication mechanisms to restrict data access to authorized individuals or groups.
      4. Providing training and guidelines to employees on secure communication practices and the proper handling of sensitive information when sharing data externally.
    9. Data Disposal and Destruction
      1. Shredding physical documents containing sensitive information before disposal to prevent unauthorized access or identity theft.
      2. Using data wiping software to securely erase data from decommissioned storage devices, such as hard drives or USB drives, before recycling or disposal.
      3. Implementing secure deletion procedures to remove obsolete or redundant data from databases or file systems while ensuring compliance with data privacy regulations.
      4. Documenting and verifying the destruction of sensitive data through audit trails or certificates of destruction to demonstrate compliance with data protection requirements.
  5. Security Measures
    1. Access Control
      1. Implementing role-based access control (RBAC) to restrict access to sensitive systems and data based on users' roles and responsibilities.
      2. Enforcing strong authentication methods such as multi-factor authentication (MFA) to verify users' identities before granting access.
      3. Monitoring and auditing user activities to detect and respond to unauthorized access attempts or suspicious behavior.
    3. Encryption
      1. Encrypting sensitive data at rest and in transit using strong encryption algorithms to prevent unauthorized access or interception.
      2. Implementing end-to-end encryption for communication channels and storage systems to ensure data confidentiality and integrity.
    5. Network Security
      1. Deploying firewalls, intrusion detection/prevention systems (IDS/IPS), and network segmentation to protect against unauthorized access, malware, and network-based attacks.
      2. Conducting regular vulnerability assessments and penetration testing to identify and remediate security weaknesses in network infrastructure and applications.
    7. Endpoint Security
      1. Installing and updating anti-malware software, endpoint protection platforms (EPP), and host-based intrusion detection systems (HIDS) to defend against malware, ransomware, and other threats.
      2. Enforcing device encryption, endpoint management policies, and secure configuration standards to protect endpoints such as desktops, laptops, and mobile devices.
    9. Security Awareness Training
      1. Providing ongoing cybersecurity awareness training and education for employees to promote good security practices and behavior.
      2. Conducting simulated phishing exercises to test employees' awareness and responsiveness to phishing attacks and social engineering tactics.
    11. Incident Response and Management
      1. Developing incident response plans and procedures to effectively detect, contain, and mitigate security incidents and data breaches.
      2. Establishing a dedicated incident response team and coordinating with internal stakeholders and external partners (e.g., law enforcement, regulatory agencies) to manage security incidents and minimize impact.
    13. Security Policy and Governance
      1. Developing and enforcing security policies, standards, and guidelines that outline organizational security requirements, responsibilities, and acceptable use of IT resources.
      2. Establishing governance structures and compliance frameworks (e.g., ISO 27001, NIST Cybersecurity Framework) to manage risks, ensure regulatory compliance, and continuously improve security posture.
  7. Employee Responsibilities
    1. Security Awareness
      1. Stay informed about security policies, procedures, and best practices relevant to their role and responsibilities.
      2. Participate in security awareness training sessions to understand common threats, phishing tactics, and security protocols.
      3. Remain vigilant and report any suspicious activities or security incidents to the appropriate personnel or IT/security team.
    3. Access Control
      1. Use strong, unique passwords or passphrases for accessing accounts, systems, and applications.
      2. Follow the principle of least privilege by only accessing data and resources necessary for performing job duties.
      3. Keep login credentials confidential and refrain from sharing passwords or granting unauthorized access to others.
    5. Data Handling
      1. Treat sensitive and confidential information with care and adhere to data classification guidelines.
      2. Encrypt sensitive data when transmitting or storing it on portable devices or external media.
      3. Follow proper data disposal procedures when deleting or discarding physical and electronic records to prevent data breaches.
    7. Device Security
      1. Keep work devices (e.g., computers, smartphones, tablets) physically secure and locked when not in use.
      2. Install security updates, patches, and antivirus software on devices to protect against malware and cyber threats.
      3. Avoid connecting to unsecured Wi-Fi networks and use virtual private networks (VPNs) for secure remote access to corporate resources.
    9. Email and Communication
      1. Exercise caution when opening email attachments or clicking on links from unknown or suspicious sources.
      2. Verify the authenticity of email requests for sensitive information or financial transactions before responding.
      3. Use encrypted communication channels for transmitting confidential or sensitive information.
    11. Physical Security
      1. Adhere to facility access policies and procedures, including badge access and visitor registration protocols.
      2. Report any physical security breaches, such as unauthorized access or suspicious individuals, to security personnel or management.
      3. Keep work areas clean and organized to prevent unauthorized access to documents or equipment containing sensitive information.
    13. Compliance and Policy Adherence
      1. Understand and comply with industry regulations, legal requirements, and organizational policies related to privacy, security, and compliance.
      2. Seek clarification or guidance from management or compliance officers if unsure about the interpretation or application of policies.
      3. Acknowledge and sign off on security policies and agreements as required by the organization.
    15. Incident Reporting and Response
      1. Promptly report security incidents, data breaches, or policy violations to the appropriate channels within the organization.
      2. Cooperate with incident response teams and provide relevant information or assistance during investigations.
      3. Follow incident response procedures and instructions provided by security or management personnel.
  9. Third-Party Data Handling
    1. Vendor Selection
      1. Conduct thorough due diligence and risk assessments when selecting third-party vendors or service providers.
      2. Evaluate vendors' security practices, certifications, compliance with industry regulations, and track record of handling sensitive data.
      3. Prioritize vendors who demonstrate a commitment to data protection, transparency, and accountability.
    3. Contractual Agreements
      1. Establish comprehensive contracts or service level agreements (SLAs) that clearly define the roles, responsibilities, and obligations of both parties regarding data handling.
      2. Include provisions for data security, confidentiality, breach notification, data ownership, access controls, and audit rights in contractual agreements.
      3. Specify the mechanisms for monitoring, auditing, and enforcing compliance with contractual terms, including remedies for breaches or non-compliance.
    5. Data Protection Measures
      1. Implement encryption and access controls to protect data transferred to or stored by third-party vendors.
      2. Ensure that data is anonymized or pseudonymized whenever feasible to minimize the risk of unauthorized access or exposure.
      3. Regularly review and assess third-party vendors' security controls and practices to ensure alignment with industry standards and organizational requirements.
    7. Risk Management
      1. Identify and assess potential risks associated with third-party data handling, including data breaches, unauthorized access, data loss, or service interruptions.
      2. Develop risk mitigation strategies and contingency plans to address identified risks and ensure business continuity.
      3. Monitor and review third-party vendors' compliance with contractual agreements and security requirements on an ongoing basis.
    9. Compliance and Regulatory Requirements
      1. Ensure that third-party vendors comply with relevant data protection regulations, industry standards, and contractual obligations.
      2. Conduct periodic audits or assessments of third-party vendors' compliance with regulatory requirements and security standards.
      3. Maintain documentation and records of third-party data handling activities to demonstrate compliance with legal and regulatory obligations.
    11. Incident Response and Notification
      1. Establish procedures for reporting and responding to security incidents or data breaches involving third-party vendors.
      2. Require third-party vendors to promptly notify the organization of any security incidents, data breaches, or unauthorized access to sensitive data.
      3. Collaborate with third-party vendors to investigate and remediate security incidents, mitigate potential harm, and minimize the impact on affected individuals or organizations.
  11. Incident Response
    1. Preparation
      1. Develop and maintain an incident response plan (IRP) that outlines roles, responsibilities, and procedures for responding to security incidents.
      2. Establish an incident response team (IRT) composed of individuals from various departments, including IT, security, legal, communications, and executive leadership.
      3. Conduct regular training, drills, and tabletop exercises to ensure that the incident response team is prepared to effectively respond to different types of security incidents.
      4. Identify and document critical assets, systems, and processes that may be targeted or impacted by security incidents.
    3. Detection and Analysis
      1. Implement monitoring tools, intrusion detection systems (IDS), and security information and event management (SIEM) solutions to detect security incidents and anomalous activities.
      2. Establish procedures for triaging, analyzing, and prioritizing security alerts to determine their severity and potential impact on the organization.
      3. Collect and preserve evidence related to security incidents for forensic analysis and investigation purposes while maintaining chain of custody and integrity.
    5. Containment and Mitigation
      1. Take immediate actions to contain the spread and minimize the impact of security incidents by isolating affected systems, networks, servers, or assets.
      2. Disable compromised accounts, revoke unauthorized access privileges, or block malicious IP addresses to prevent further damage or unauthorized access.
      3. Implement temporary remediation measures or workarounds to restore critical services or functionality while investigating and addressing the root cause of the incident.
    7. Eradication and Recovery
      1. Identify and remediate vulnerabilities or weaknesses exploited by security incidents to prevent recurrence.
      2. Restore affected systems, applications, and data from backups or snapshots to their pre-incident state or a known good configuration.
      3. Validate the effectiveness of remediation actions and recovery efforts through testing, validation, and monitoring of restored systems and services.
    9. Post-Incident Analysis and Lessons Learned
      1. Conduct a post-incident analysis (PIA) or post-mortem to evaluate the organization's response to the security incident, identify areas for improvement, and capture lessons learned.
      2. Document findings, recommendations, and corrective actions resulting from the post-incident analysis to enhance incident response procedures, policies, and controls.
      3. Share insights and best practices with relevant stakeholders, including incident response team members, management, and other departments, to strengthen the organization's overall security posture.
    11. Communication and Reporting
      1. Maintain open and transparent communication channels with internal stakeholders, external partners, customers, and regulatory authorities throughout the incident response process.
      2. Prepare and disseminate timely and accurate incident notifications, updates, and reports to inform stakeholders about the nature of the incident, impact, remediation efforts, and follow-up actions.
      3. Comply with legal, regulatory, and contractual requirements related to incident reporting, notification, and disclosure while preserving the organization's reputation and credibility.
  13. Review and Approval
    1. Document Review and Approval
      1. Policies and Procedures: Establish review and approval processes for developing, updating, and maintaining organizational policies, procedures, and guidelines.
      2. Document Lifecycle: Define stages and checkpoints for document review, revision, validation, and final approval, including roles and responsibilities of reviewers and approvers.
      3. Version Control: Implement version control mechanisms to track changes, revisions, and updates to documents, ensuring that the latest approved versions are accessible and utilized.
      4. Electronic Signatures: Use electronic signature solutions or digital approval workflows to capture and authenticate approvals from designated reviewers and approvers.
    3. Change Management
      1. Change Requests: Require submission of change requests for proposed modifications, enhancements, or updates to systems, processes, configurations, or documentation.
      2. Impact Assessment: Conduct impact assessments to evaluate the potential implications, risks, and benefits of proposed changes on business operations, security, compliance, and stakeholders.
      3. Change Approval Board (CAB): Establish a Change Approval Board or Change Control Board to review, assess, prioritize, and approve change requests based on predefined criteria and risk thresholds.
      4. Emergency Changes: Define procedures and escalation paths for expediting approval of emergency changes or critical updates required to address security incidents, service disruptions, or regulatory compliance issues.
    5. Project Review and Governance
      1. Project Initiation: Require project charters or initiation documents to undergo review and approval by project sponsors, stakeholders, or governance bodies before project commencement.
      2. Project Milestones: Conduct periodic project reviews and milestone assessments to evaluate progress, performance, risks, and compliance with project objectives, timelines, and budgets.
      3. Project Closure: Obtain formal sign-off and approval from project sponsors or stakeholders to close out projects, deliverables, or phases, ensuring that project outcomes meet agreed-upon requirements and expectations.
    7. Regulatory Compliance
      1. Regulatory Approvals: Obtain regulatory approvals or permits for activities, projects, products, or services subject to regulatory oversight, ensuring compliance with legal requirements, industry standards, and licensing obligations.
      2. Audit and Compliance Reviews: Conduct periodic audits, assessments, and compliance reviews to evaluate adherence to regulatory requirements, internal policies, and industry standards, documenting findings and implementing corrective actions as necessary.
    9. Training and Awareness
      1. Training Approval: Require approval of training programs, courses, or materials by training coordinators, managers, or subject matter experts to ensure alignment with organizational objectives and employee development needs.
      2. Training Attendance: Track attendance and completion of approved training activities to verify compliance with training requirements and regulatory mandates.
  15. Document History
    1. Version Control
      1. Each document is assigned a unique version number or identifier to distinguish between different iterations or revisions.
      2. Changes to the document are tracked and recorded systematically, allowing users to reference previous versions and track the evolution of the document over time.
      3. Version control mechanisms ensure that users are working with the most recent and approved version of the document, minimizing the risk of errors or discrepancies.
    3. Change Tracking
      1. Document management systems or collaboration tools often include features for tracking changes, enabling users to annotate edits, comments, or suggestions directly within the document.
      2. Changes made by individual users are recorded along with timestamps, facilitating accountability and transparency regarding who made specific modifications and when they occurred.
      3. Change tracking functionality allows reviewers and approvers to assess proposed changes, provide feedback, and approve final versions of the document.
    5. Revision History
      1. Document management systems maintain a revision history or audit trail that provides a chronological record of all changes made to the document, including the date, time, and nature of each modification.
      2. Revision history logs may include details such as the user who initiated the change, the type of modification (e.g., edits, deletions, additions), and any comments or annotations associated with the change.
      3. Revision history logs serve as a valuable reference for auditing purposes, enabling organizations to demonstrate compliance with regulatory requirements and internal policies regarding document management and control.
    7. Access Controls
      1. Access to document history, revision logs, and previous versions may be restricted to authorized users or roles to maintain confidentiality, integrity, and security of the information.
      2. Document management systems enforce access controls based on user permissions, ensuring that only authorized individuals can view or modify document history records.
    9. Documentation and Archiving
      1. Document history records are typically stored and archived alongside the current version of the document, providing a complete audit trail of its lifecycle.
      2. Archived document history may be retained for a specified period in accordance with organizational policies, regulatory requirements, or legal obligations.
      3. Document management systems facilitate efficient retrieval and retrieval of document history records, enabling users to access previous versions or review historical changes as needed.
  17. Contact Information
    1. Email Address: An email address allows for electronic communication. It may include a person's or organization's name followed by the "@" symbol and the domain name (e.g., [email protected]).
    2. Phone Number: A phone number enables voice communication. It may include a country code, area code, and local number (e.g., +1 123-456-7890).
    3. Website URL: A website URL (Uniform Resource Locator) specifies the address of a website on the internet (e.g., www.example.com).
    4. Social Media Handles: Social media handles refer to usernames or account names on social media platforms such as Twitter, LinkedIn, Facebook, Instagram, etc.
    5. Instant Messaging ID: Instant messaging IDs, such as those for platforms like WhatsApp, Telegram, or Skype, enable real-time text or voice communication.

5. Policy Compliance

  1. Compliance Measurement
    The Infosec team will verify compliance to this policy through various methods, including but not limited to, business tool reports, internal and external audits, and feedback to the policy owner. 
  2. Exceptions
    Any exception to the policy must be approved by the Infosec team in advance. 
  3. Non-Compliance
    An employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment.


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