Data Privacy and Security Policy¶
Policy Status: Active
This policy is currently active.
Purpose¶
To protect sensitive student information and ensure compliance with industry standards and regulations related to data security and privacy.
Scope¶
This policy applies to all employees, contractors, and third-party service providers who have access to Acme Corp's data and IT systems.
Policy Statement¶
Data Protection¶
All sensitive student data must be encrypted in transit and at rest to ensure confidentiality and integrity.
Access Controls¶
Only authorized personnel are permitted to access sensitive data. Access must be granted based on job role and necessity, following the principle of least privilege.
User Authentication¶
Strong passwords and two-factor authentication (2FA) are required for access to critical systems containing sensitive data.
Data Minimization¶
Collect only the data necessary to fulfill service needs. Data must be deleted when no longer required for business or legal purposes.
Compliance¶
Adhere to applicable regulations (e.g., HIPAA, state-specific data protection laws) to ensure confidentiality, integrity, and availability of data.
Roles and Responsibilities¶
| Role | Responsibility |
|---|---|
| IT Team | Oversee and implement security controls, manage encryption systems, monitor access |
| All Staff | Adhere to privacy and security practices, report violations or concerns |
| Compliance Team | Ensure regulatory compliance, conduct audits, update policies as needed |
| Management | Approve access requests, ensure team compliance with policy |
Procedures¶
- Data Classification: Identify and classify all data according to sensitivity level
- Encryption Implementation: Apply encryption to data in transit (TLS/SSL) and at rest (AES-256 or equivalent)
- Access Request Process: Submit access requests through designated system, require manager approval
- 2FA Enrollment: Enroll all users in two-factor authentication for critical systems within first week of access
- Data Disposal: Follow secure data deletion procedures when data retention period expires
- Compliance Audits: Conduct quarterly audits to verify adherence to data protection standards
Exceptions¶
Any exceptions to encryption or access control requirements must be: - Documented in writing with business justification - Approved by both IT leadership and Compliance Team - Reviewed quarterly for continued necessity - Compensating controls must be implemented where exceptions exist
Compliance and Enforcement¶
- Monitoring: IT team conducts regular security audits and access reviews
- Reporting: All staff must report suspected violations immediately to IT or Compliance
- Violations: Violations of this policy may result in disciplinary actions up to and including termination
- Third Parties: Vendors found in violation may have access revoked and contracts terminated
References¶
- HIPAA Security Rule (45 CFR Part 164, Subpart C)
- HIPAA Privacy Rule (45 CFR Part 160 and Part 164, Subparts A and E)
- SOC 2 Trust Service Criteria
- State-specific data protection laws applicable to student information
Revision History¶
| Version | Date | Author | Changes |
|---|---|---|---|
| 1.0 | 2025-11-08 | Compliance Team | Initial version migrated from Notion |
Document Control - Classification: Internal/Confidential - Distribution: All employees, contractors, and third-party service providers - Storage: GitHub repository - policy-repository