Implementation: Utilizing Advanced Encryption Standard (AES-256) to encrypt personal data stored in databases. This should include not only customer data but also employee data and any other sensitive information.
Purpose: The primary goal is to protect the data at rest against unauthorized access, data breaches, and other potential security incidents.
Monitoring: Encryption algorithms will be regularly reviewed and updated to meet current security standards. This should include quarterly reviews and immediate updates in case of newly discovered vulnerabilities.
2. Secure Data Transmission
Implementation: Employment of HTTPS and SSL/TLS protocols for all data transmitted over the internet.
Purpose: The aim is to secure data during transit from eavesdropping, man-in-the-middle attacks, and data tampering.
Monitoring: Conduct periodic security assessments, including penetration testing, to ensure the integrity and confidentiality of data transmission protocols.
3. Multi-Factor Authentication (MFA)
Implementation: From Phase 4, requiring at least two forms of verification, such as a password and a mobile authentication code, before granting access to systems containing personal data. Adaptive authentication mechanisms may be required for additional verification steps under suspicious circumstances.
Purpose: Multi-factor authentication adds an additional layer of security, making it more difficult for unauthorized users to gain access.
Monitoring: Regularly update and test authentication methods, including biometrics and hardware tokens, to ensure their effectiveness and security.
4. Firewalls and Intrusion Detection Systems
Implementation: Deploying advanced firewalls and intrusion detection systems (IDS) to monitor and control incoming and outgoing network traffic based on an organization's security policy.
Purpose: These tools are essential for identifying and blocking potentially harmful data packets and unauthorized access attempts.
Monitoring: Continuously updating the firewall rules and IDS signatures to adapt to emerging threats as well as regular reviews of logs and alerts for suspicious activity.
5. Regular Software Updates
Implementation: Keeping all software, including operating systems, databases, and applications, up-to-date with the latest security patches.
Purpose: Regular updates protect against known vulnerabilities that could be exploited by attackers.
Monitoring: Implementing automated systems for tracking and applying updates. Conducting regular audits to ensure all systems are up-to-date.
6. Data Backup
Implementation: From Phase 2, performing regular backups of all personal data and storing them in a secure, off-site location. Backups should be encrypted and should include not just databases but also configuration files and logs.
Purpose: Regular backups ensure data integrity and availability in case of hardware failure, data corruption, or a security incident.
Monitoring: Periodically test backup restoration processes to ensure they are functioning correctly. Maintain logs of all backup and restoration activities.
7. Endpoint Security
Implementation: From Phase 2, installing updated antivirus and anti-malware software on all endpoints, including laptops, mobile devices, and servers, that have access to personal data.
Purpose: Endpoint security protects against malware, ransomware, and other malicious software that could compromise data.
Monitoring: Regularly scan all endpoints for vulnerabilities and update security software as needed. Maintain logs of all scans and updates.
8. Data Masking
Implementation: From Phase 3, using data masking techniques to obscure specific data within a database, making it inaccessible to unauthorized users. This is particularly important for non-production environments like development and testing.
Purpose: Data masking protects the data by making it unreadable, even if someone gains unauthorized access to the database.
Monitoring: Regularly reviewing and updating masking rules to ensure they meet current data protection requirements.
9. Secure APIs
Implementation: From Phase 2, using secure and authenticated Application Programming Interfaces (APIs) for transmitting data between services. All API calls should be over HTTPS, and API keys should be securely stored. Implement rate limiting and other security controls to protect against abuse and attacks on APIs should be implemented.
Purpose: Secure APIs ensure that data is securely transferred between different services and is not exposed to potential vulnerabilities.
Monitoring: Conduct regular security audits of API configurations, including penetration testing, to ensure they meet security standards.
10. Data Access Logs
Implementation: Maintain comprehensive logs that record all data access, modifications, and deletions. These logs should include user IDs, timestamps, and the nature of the data accessed.
Purpose: Detailed logs provide an audit trail that can be analyzed in case of a security incident, helping to identify the source and scope of any breaches.
Monitoring: Regularly review logs to identify any suspicious activity and take appropriate action, such as revoking access or initiating an investigation.
11. Data Protection Officer (DPO)
Implementation: Appointing a qualified Data Protection Officer who holds certifications in data privacy and security. This individual will be responsible for overseeing the data protection strategy and its implementation across all departments.
Purpose: The DPO ensures that the company remains in compliance with data protection laws and regulations, such as GDPR or CCPA, depending on the jurisdiction. The DPO also serves as the point of contact for data subjects and regulatory bodies.
Monitoring: Conduct regular performance reviews of the DPO and require quarterly updates on data protection initiatives, changes in laws, and the results of any data audits.
12. Employee Training
Implementation: Conducting training sessions, at least once a year, for all employees on data protection best practices, legal obligations, and company policies. Employees involved in AI model training shall be trained specifically for their roles.
Purpose: The training aims to educate staff on their roles and responsibilities in safeguarding personal data and ensuring compliance with relevant laws.
Monitoring: Administer periodic assessments and quizzes to gauge employee understanding and adherence to data protection principles. Maintain records of training participation and assessment scores.
13. Data Access Control
Implementation: Implementing role-based access control (RBAC) and setting up strict permission hierarchies to limit data access to authorized personnel only. Implementing real-time alerts for unauthorized access attempts and set up automated systems for temporary access revocation in case of suspicious activity.
Purpose: RBAC minimizes the risk of unauthorized data access and potential breaches by ensuring that only those with a legitimate need can access specific data.
Monitoring: Conduct regular audits of access controls, permissions, and user accounts to ensure they are up-to-date and secure. Remove or modify permissions for employees who change roles or leave the company.
14. Data Audits
Implementation: From Phase 2, conducting regular internal and external audits, which include penetration testing and compliance checks, to assess the effectiveness of data protection measures. Third-party experts may be hired, if necessary.
Purpose: Audits identify any weaknesses or vulnerabilities in the data protection strategy and ensure compliance with legal requirements.
Monitoring: Review audit findings promptly and implement recommended changes in a timely manner. Maintain detailed records of all audits conducted.
15. Data Breach Response Plan
Implementation: Developing a comprehensive data breach response plan that outlines the steps to be taken in the event of a data breach. This plan should be easily accessible to key personnel and include contact information of relevant supervisory bodies, data protection advisors, and public relations experts.
Purpose: A well-defined plan ensures a coordinated and effective response to data breaches, minimizing damage and ensuring timely notification to affected parties and regulatory bodies.
Monitoring: Regularly update and test the plan through simulated breach exercises to ensure its effectiveness and readiness.
16. Vendor Assessment
Implementation: Conducting regular assessments of third-party vendors who have access to personal data. These assessments should include security audits, compliance checks, and reviews of data processing agreements.
Purpose: Vendor assessments mitigate the risk of data breaches originating from third parties and ensure that vendors comply with data protection laws.
Monitoring: Perform ongoing evaluations and audits of vendor compliance.
17. Data Processing Agreements
Implementation: Entering into formal data processing agreements with all third parties that process personal data on behalf of the company. These agreements should be reviewed by experts, where possible.
Purpose: Data processing agreements legally bind third parties to comply with the company's data protection standards and comply with relevant laws.
Monitoring: Conduct regular reviews of these agreements to ensure they are current and in compliance with new regulations or changes in business operations.
18. Privacy Policy
Implementation: Maintaining a publicly accessible and easily understandable privacy policy that clearly outlines how personal data is collected, stored, and processed. Marbazzar shall ensure appropriate information flows between the persons who make data-related decisions and the persons responsible for updating the privacy policy.
Purpose: The privacy policy informs individuals about their rights and the company's data practices, fostering transparency and trust and ensures collecting of valid consent.
Monitoring: Conduct periodic reviews and updates to the privacy policy to reflect changes in data processing activities, technologies, or laws.
19. Data Minimization
Implementation: Processing only the data that is strictly necessary for the intended purpose is collected and stored.
Purpose: Data minimization reduces the amount of data stored, thereby minimizing the risk of unauthorized access or breaches.
Monitoring: Conduct regular audits to ensure that unnecessary data is not being collected or stored. Delete or anonymize data that is no longer needed.
20. Transparency
Implementation: Maintaining transparency in all data processing activities by providing individuals with the ability to access, correct, or delete their personal data through user-friendly interfaces, or by contacting the trained staff at Marbazzar.
Purpose: Transparency builds trust and complies with the rights of individuals under data protection laws.
Monitoring: Regularly update disclosure mechanisms and ensure that requests for data access, correction, or deletion are handled promptly and in compliance with legal timeframes.
