The Data Loss Prevention Policy (DLP)
Policy Owner: Chief Information Security Officer (CISO)
Effective Date: 2/13/25
Reviewed On: 2/13/25
Version: 1.0
Approved by: Executive Leadership Team
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1. Purpose
The purpose of this Data Loss Prevention (DLP) Policy is to define the organization’s approach to prevent the unauthorized exposure, loss, or theft of sensitive and confidential data within organization, which operates in the financial services industry. This policy establishes guidelines for identifying, monitoring, and securing sensitive data to ensure compliance with industry standards and regulations, protect intellectual property, maintain customer privacy, and avoid legal and financial risks.
2. Scope
This policy applies to all employees, contractors, third-party vendors, and any other individuals with access to the organization’s systems, networks, and data. It encompasses all forms of data, whether it is digital, printed, or transmitted via email or other communication platforms, and applies to both on-premises and cloud-based systems.
3. Definitions
• Sensitive Data: Any information classified as confidential, proprietary, or personal that could cause harm to the organization, customers, or individuals if exposed. This includes, but is not limited to, financial records, customer data, trade secrets, intellectual property, personally identifiable information (PII), and health-related data (e.g., HIPAA-compliant data).
• Data Loss: Any unauthorized access, destruction, alteration, or transmission of sensitive data outside of organizational controls.
• Data Loss Prevention (DLP): Technologies, processes, and policies used to detect and prevent unauthorized access or leakage of sensitive data.
• DLP Controls: Systems or software tools deployed to monitor, detect, and block data loss incidents.
4. Data Classification and Identification
To ensure that sensitive data is adequately protected, organization will classify data into the following categories:
1. Public: Information that can be shared with the public without harm to the organization.
2. Internal: Information used for internal purposes, which does not include highly sensitive data.
3. Confidential: Information that requires protection, such as customer data and trade secrets.
4. Restricted: High-sensitivity data requiring the highest level of protection, such as financial records and personal health information.
The classification will drive the level of protection required for each type of data. The IT and Security teams are responsible for creating and updating the classification scheme regularly.
5. DLP Controls
• Endpoint Protection: All devices accessing organizational data (computers, mobile phones, tablets, etc.) will be equipped with DLP software to monitor, detect, and prevent data loss incidents.
• Network Protection: Firewalls, intrusion detection systems, and email filtering solutions will be configured to identify and block any unauthorized transfer of sensitive data.
• Cloud Protection: Cloud storage and application services will have built-in DLP solutions, enforcing restrictions on file sharing, access, and transfer based on data classification.
• Encryption: All sensitive data, whether stored on devices, servers, or transmitted over the network, will be encrypted both at rest and in transit using industry-standard encryption protocols.
• Access Control: Data access will be granted based on the principle of least privilege (PoLP). Only authorized personnel should have access to sensitive or restricted data, and access will be reviewed regularly.
• Monitoring and Auditing: Continuous monitoring will be conducted to detect abnormal data movement or usage patterns that could indicate a potential data loss. Audit logs will be maintained and reviewed for signs of unauthorized data access or transfer.
6. Employee Responsibilities
• Data Handling: Employees must ensure that sensitive data is handled according to its classification level. Sensitive data should only be accessed, stored, or transmitted in secure environments.
• Reporting: Any suspected data loss incident, including theft, unauthorized access, or inadvertent data leakage, must be reported immediately to the IT or Security team.
• Training: Employees will undergo annual DLP training to ensure that they understand the importance of data security, proper data handling, and how to recognize potential risks.
• Remote Work Security: Employees working remotely must follow the same DLP protocols, ensuring the security of sensitive data on personal devices, home networks, and during virtual communications.
7. Third-Party Vendor Management
• Vendor Evaluation: All third-party vendors with access to sensitive data must be evaluated for their DLP policies and practices. Only vendors with appropriate safeguards and DLP mechanisms in place will be approved.
• Contracts and Agreements: Data protection clauses must be included in contracts with third-party vendors, ensuring compliance with organization ‘s DLP standards. Third-party vendors must adhere to the same data security requirements as internal employees.
8. Incident Response
• Detection: DLP tools will immediately detect and flag suspicious data activities, such as unusual file access, unapproved transfers, or data being sent to external networks.
• Investigation: The Security team will investigate potential data loss incidents promptly to determine the nature and impact of the event.
• Containment: If a data loss incident is confirmed, immediate steps will be taken to contain the incident, such as disabling compromised accounts or blocking certain data flows.
• Recovery: Efforts will be made to recover any lost data and restore services to normal operations.
• Reporting: All significant data loss incidents will be reported to the appropriate regulatory authorities within the required timeframe as per industry laws (e.g., GDPR, CCPA, etc.).
• Post-Incident Analysis: After a data loss event, a thorough review will be conducted to identify any gaps in security protocols and determine necessary improvements.
9. Compliance and Legal Considerations
• Organization will comply with all relevant data protection laws and regulations, including but not limited to GDPR, CCPA, HIPAA, PCI-DSS, and other industry-specific data protection standards.
• Non-compliance with this policy may result in disciplinary action, up to and including termination, as well as potential legal consequences for individuals responsible for data breaches.
10. Enforcement
• Non-Compliance: Any employee found in violation of this policy will be subject to disciplinary action, which may include access restrictions, suspension, or termination, depending on the severity of the violation.
• Policy Violations: If any employee or third-party vendor is found to be responsible for a data loss incident, appropriate legal and regulatory actions will be taken, including reporting the violation to relevant authorities if required.
11. Policy Review
This policy will be reviewed annually by the CISO and the Security team to ensure its effectiveness, compliance with new laws, and alignment with best practices. Any updates or changes to the policy will be communicated to all employees and relevant stakeholders.
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Approval:
Corey Guillaume
CISO
2/13/2025