Data Breach Response Policy

Purpose

The purpose of the policy is to establish the goals and the vision for the breach response process in the MYRTLE GROUP S.A. (“we” or “Cloudback”). 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.

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

Background

This policy mandates that any individual who suspects that a theft, breach or exposure of Cloudback Protected data or Cloudback Sensitive data has occurred must immediately provide a description of what occurred via email to support@cloudback.it or using other options mentioned on the Contact Us web page. This email address and Cloudback’s issue tracker are monitored by the Cloudback’s Support Team. The team will investigate all reported thefts, data breaches, and exposures to confirm if a theft, breach or exposure has occurred. If a theft, breach or exposure has occurred, the Cloudback’s Support Team will follow the appropriate procedure in place.

Scope

This policy applies to all who collect, access, maintain, distribute, process, protect, store, use, transmit, dispose of, or otherwise handle personally identifiable information of Cloudback members and end users.

Policy Confirmed theft, data breach, or exposure of Cloudback Protected data or Cloudback Sensitive data

As soon as a theft, data breach or exposure containing Cloudback Protected data or Cloudback Sensitive data is identified, the process of removing all access to that resource will begin. The Cloudback Support team will handle the breach or exposure. The team will analyze the breach or exposure to determine the root cause and work with Cloudback communications, legal, and human resource departments to decide how to communicate the breach to: a) internal employees, b) the public, and c) those directly affected.

Enforcement

Any Cloudback 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.

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.
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.
Sensitive data - Data that is encrypted or in plain text and contains PII data.