DATA BREACH RESPONSE POLICY 

# 1. 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.

Homebrewed Tech LLC intentions for publishing a Data Breach Response Policy are to focus significant attention on data security and data security breaches, and how Homebrewed Tech LLC’s established culture of openness, trust and integrity should respond to such activity. Homebrewed Tech LLC’s is committed to protecting Homebrewed Tech LLC’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 Protected or Sensitive data has occurred must immediately provide a description of what occurred via e-mail to [craftcellr@gmail.com](mailto:craftcellr@gmail.com). This e-mail address is monitored by the Executive Director's team. This 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 Executive Director will follow the appropriate procedure in place.

# 2. 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 members. Any agreements with vendors should contain language similar that protects Homebrewed Tech LLC.

# 3. Confirmed Theft, Data Breach, or Exposure of Protected or Sensitive Data

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

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

The team will include members from:

  • Engineering - Finance (if applicable)

  • Legal (if applicable)

  • Communications

  • Users Services (if User data is affected)

  • 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

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

# 4. Ownership and Responsibilities

  • **Sponsors** - Sponsors are those members of the Homebrewed Tech LLC community that have primary responsibility for maintaining any information resource. Sponsors may be designated by any Homebrewed Tech LLC Executive in connection with their administrative responsibilities, or by the actual sponsorship, collection, development, or storage of information.

  • **Executive Director** - a member of the Homebrewed Tech LLC community 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.

  • **Users** - virtually all members of the community to the extent they have authorized access to information resources, and may include users, staff, trustees, contractors, consultants, interns, temporary employees and volunteers.

  • **Incident Response Team** shall be chaired by Executive Management and shall include, but will not be limited to, the following departments or their representatives: Infrastructure, Application Security; Communications; Legal; Management; Financial Services, Member Services; Human Resources.

# 5. Enforcement

Any Homebrewed Tech LLC 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.

# 6. Definitions and Terms

  • **Encryption or Encrypted Data** - 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.

  • **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.

  • **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** - A generalized term that typically represents data classified as Restricted, according to the data classification scheme defined in this Guideline. This term is often used interchangeably with confidential data.