1.1. Prodigi holds, processes, and shares a limited amount of end-consumer personal data which is an asset needing to be suitably protected.
1.2. Every care is taken to protect personal data from incidents (either accidentally or deliberately) to avoid a data protection breach that could compromise security.
1.3. Compromise of information, confidentiality, integrity, or availability may result in harm to individual(s), reputational damage, detrimental effect on service provision, legislative non-compliance, and/or financial costs.
2.1. Prodigi is obliged under the Data Protection Act to have in place an institutional framework designed to ensure the security of all personal data during its lifecycle, including clear lines of responsibility.
2.2. This Policy sets out the procedure to be followed to ensure a consistent and effective approach is in place for managing data breach and information security incidents across Prodigi.
3.1. This Policy relates to all personal and sensitive data held by Prodigi regardless of format.
3.2. This Policy applies to all staff at Prodigi. This includes temporary, casual or agency staff and contractors, consultants, suppliers and data processors working for, or on behalf of Prodigi.
3.3. The objective of this Policy is to contain any breaches, to minimise the risk associated with the breach and consider what action is necessary to secure personal data and prevent further breaches.
4. Definition / Types of Breach
4.1. For the purpose of this Policy, data security breaches include both confirmed and suspected incidents.
4.2. An incident in the context of this Policy is an event or action which may compromise the confidentiality, integrity or availability of systems or data, either accidentally or deliberately, and has caused or has the potential to cause damage to Prodigi’s information assets and/or reputation.
4.3. An incident includes but is not restricted to, the following:
- Loss or theft of confidential or sensitive data or equipment on which such data is stored (e.g. loss of laptop, USB stick, iPad/tablet device, or paper record);
- Equipment theft or failure;
- Unauthorised use of, access to or modification of data or information systems Attempts (failed or successful) to gain unauthorised access to information or IT system(s);
- Unauthorised disclosure of sensitive / confidential data;
- Website defacement;
- Hacking attack;
- Unforeseen circumstances such as a fire or flood; and
- Human error
5. Reporting an incident
5.1. Any individual who accesses, uses or manages Prodigi’s information is responsible for reporting data breach and information security incidents immediately to the Data Protection Officer at firstname.lastname@example.org.
5.2. If the breach occurs or is discovered outside normal working hours, it must be reported as soon as is practicable.
5.3. The report will include full and accurate details of the incident, when the breach occurred (dates and times), who is reporting it, if the data relates to people, the nature of the information, and how many individuals are involved.
6. Containment and Recovery
6.1. The Data Protection Officer (DPO) will firstly determine if the breach is still occurring. If so, the appropriate steps will be taken immediately to minimise the effect of the breach.
6.2. An initial assessment will be made by the DPO in liaison with relevant team members to establish the severity of the breach and who will take the lead investigating the breach (this will depend on the nature of the breach in some cases it could be the DPO).
6.3. The DPO will establish whether there is anything that can be done to recover any losses and limit the damage the breach could cause.
6.4. The DPO will establish who may need to be notified as part of the initial containment and will inform the police, where appropriate.
6.5. Advice from experts across Prodigi may be sought in resolving the incident promptly.
6.6. The DPO, in liaison with the relevant team members will determine the suitable course of action to be taken to ensure a resolution to the incident.
7. Investigation and Risk Assessment
7.1. An investigation will be undertaken by the DPO immediately and wherever possible within 24 hours of the breach being discovered / reported.
7.2. The DPO will investigate the breach and assess the risks associated with it, for example, the potential adverse consequences for individuals, how serious or substantial those are and how likely they are to occur.
7.3. The investigation will need to take into account the following:
- the type of data involved its sensitivity;
- the protections are in place (e.g. encryptions);
- what’s happened to the data, has it been lost or stolen;
- whether the data could be put to any illegal or inappropriate use;
- who the individuals are, number of individuals involved and the potential effects on those data subject(s); and
- whether there are wider consequences to the breach
8.1. The DPO, in consultation with the CTO and CEO, will determine who needs to be notified of the breach.
8.2. Every incident will be assessed on a case by case basis; however, the following will need to be considered:
- Whether there are any legal/contractual notification requirements;
- Whether notification would assist the individual affected – could they act on the information to mitigate risks?
- Whether notification would help prevent the unauthorised or unlawful use of personal data?
- Would notification help Prodigi meet its obligations under the seventh data protection principle;
If a large number of people are affected, or there are very serious consequences, whether the Information Commissioner’s Office (ICO) should be notified. The ICO will only be notified if personal data is involved. Guidance on when and how to notify ICO is available from their website at: https://ico.org.uk/for-organisations/guide-to-eidas/breach-reporting/.
8.3. Notification to the individuals whose personal data has been affected by the incident will include a description of how and when the breach occurred and the data involved. Specific and clear advice will be given on what they can do to protect themselves, and include what action has already been taken to mitigate the risks. Individuals will also be provided with a way in which they can contact Prodigi for further information or to ask questions on what has occurred.
8.4. The DPO must consider notifying third parties such as the police, insurers, bank or credit card companies, and trade unions. This would be appropriate where illegal activity is known or is believed to have occurred, or where there is a risk that illegal activity might occur in the future.
9. Evaluation and response
9.1. Once the initial incident is contained, the DPO will carry out a full review of the causes of the breach; the effectiveness of the response(s) and whether any changes to systems, policies and procedures should be undertaken.
9.2. Existing controls will be reviewed to determine their adequacy, and whether any corrective action should be taken to minimise the risk of similar incidents occurring.
9.3. The review will consider:
- Where and how personal data is held and where and how it is stored;
- Where the biggest risks lie, and will identify any further potential weak points within its existing measures;
- Whether methods of transmission are secure; sharing minimum amount of data necessary;
- Identifying weak points within existing security measures;
- Staff awareness; and
- Implementing a data breach plan and identifying a group of individuals responsible for reacting to reported breaches of security.
9.4. If deemed necessary a report recommending any changes to systems, policies and procedures will be considered by Prodigi Group’s board of directors.