GDPR -PRIVACY POLICY

Data Breach Response Policy(Purpose)

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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.

Mandli Technologies Private Ltd Information Security's intentions for publishing a Data Breach Response Policy are to focus significant attention on data security and data security breaches and how Mandli Technologies Private Ltd’s established culture of openness, trust and integrity should respond to such activity.

Mandli Technologies Private Ltd Information Security is committed to protecting Mandli Technologies Private Ltd's employees, partners and the company from illegal or damaging actions by individuals, either knowingly or unknowingly.

Background

This policy mandates that any individual who suspects that a theft, breach or exposure of Mandli Technologies Private Ltd Protected data or Mandli Technologies Private Ltd Sensitive data.

This e-mail address, phone number, and web page are monitored by the Mandli Technologies Private Ltd’s Information Security Administrator.

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 Information Security Administrator will follow the appropriate procedure in place.

Scope

This policy applies to all whom collect, access, maintain, distribute, process, protect, store, use, transmit, dispose of, or otherwise handle personally identifiable information or Protected Health Information (PHI) of Mandli Technologies Private Ltd members. Any agreements with vendors will contain language similar that protects the fund.

Policy Confirmed theft, data breach or exposure of Mandli Technologies Private Ltd Protected data or Mandli Technologies Private Ltd Sensitive data

As soon as a theft, data breach or exposure containing Mandli Technologies Private Ltd Protected data or Mandli Technologies Private Ltd 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:
• IT Infrastructure
• IT Applications
• Finance (if applicable)
• Legal
• Communications
• Member Services (if Member 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. IT, along with the designated forensic team, will analyze the breach or exposure to determine the root cause.

Work with Forensic Investigators

As provided by Mandli Technologies cyber insurance, the insurer will need to provide access to forensic investigators and experts that will determine how the breach or exposure occurred; the types of data involved; the number of internal/external individuals and/or organizations impacted; and analyze the breach or exposure to determine the root cause.

Develop a communication plan.

Work with Mandli Technologies Private Ltd communications, legal and human resource departments to decide how to communicate the breach to: a) internal employees, b) the public, and c) those directly affected.

Ownership and Responsibilities

Roles & Responsibilities:

Sponsors - Sponsors are those members of the Mandli Technologies Private Ltd community that have primary responsibility for maintaining any particular information resource. Sponsors may be designated by any Mandli Technologies Private Ltd Executive in connection with their administrative responsibilities, or by the actual sponsorship, collection, development, or storage of information.

Information Security Administrator is that member of the Mandli Technologies Private Ltd community, designated by the Executive Director or the Director, Information Technology (IT) Infrastructure, 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 include virtually all members of the Mandli Technologies community to the extent they have authorized access to information resources, and may include staff, trustees, contractors, consultants, interns, temporary employees and volunteers.

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

Enforcement

Any Mandli Technologies Private Ltd 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.

Definitions

Encryption or encrypted data – The most effective way to achieve data security. 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;

Plain text – Unencrypted data.

Hacker – A slang term for a computer enthusiast, i.e., a person who enjoys learning programming languages and computer systems and can often be considered an expert on the subject(s).

Protected Health Information (PHI) - Under US law is any information about health status, provision of health care, or payment for health care that is created or collected by a "Covered Entity" (or a Business Associate of a Covered Entity), and can be linked to a specific individual.

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.

Protected data - See PII and PHI

Information Resource - The data and information assets of an organization, department or unit.

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 - Data that is encrypted or in plain text and contains PII or PHI data. See PII and PHI above.

Acceptable Use Policy

IT security team’s intentions for publishing an Acceptable Use Policy are not to impose restrictions that are contrary to Mandli Technologies Private Ltd’s established culture of openness, trust and integrity. IT security team is committed to protecting Mandli Technologies Private Ltd's employees, partners and the company from illegal or damaging actions by individuals, either knowingly or unknowingly. Internet/Intranet/Extranet-related systems, including but not limited to computer equipment, software, operating systems, storage media, network accounts providing electronic mail, WWW browsing, and FTP, are the property of Mandli Technologies Private Ltd. These systems are to be used for business purposes in serving the interests of the company, and of our clients and customers in the course of normal operations. Please review Human Resources policies for further details.

Policy Compliance

Compliance Measurement The IT security team team will verify compliance to this policy through various methods, including but not limited to, business tool reports, internal and external audits, and feedback to the policy owner. Exceptions Any exception to the policy must be approved by the IT security team team in advance. Non-Compliance An employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment. Related Standards, Policies and Processes Data Classification Policy Data Protection Standard Social Media Policy Minimum Access Policy Password Policy Definitions and Terms The following definition and terms can be found in the SANS Glossary located at: https://www.sans.org/security-resources/glossary-of-terms/

Email Policy

Overview :-- Electronic email is pervasively used in almost all industry verticals and is often the primary communication and awareness method within an organization. At the same time, misuse of email can post many legal, privacy and security risks, thus it’s important for users to understand the appropriate use of electronic communications. Purpose The purpose of this email policy is to ensure the proper use of Mandli Technologies Private Ltd email system and make users aware of what Mandli Technologies Private Ltd deems as acceptable and unacceptable use of its email system. This policy outlines the minimum requirements for use of email within Mandli Technologies Private Ltd Network. Scope This policy covers appropriate use of any email sent from a Mandli Technologies Private Ltd email address and applies to all employees, vendors, and agents operating on behalf of Mandli Technologies Private Ltd.

Policy:-- All use of email must be consistent with Mandli Technologies Private Ltd policies and procedures of ethical conduct, safety, compliance with applicable laws and proper business practices. Mandli Technologies Private Ltd email account should be used primarily for Mandli Technologies Private Ltd business-related purposes; personal communication is permitted on a limited basis, but non-Mandli Technologies Private Ltd related commercial uses are prohibited. All Mandli Technologies Private Ltd data contained within an email message or an attachment must be secured according to the Data Protection Standard. Email should be retained only if it qualifies as a Mandli Technologies Private Ltd business record. Email is a Mandli Technologies Private Ltd business record if there exists a legitimate and ongoing business reason to preserve the information contained in the email. Email that is identified as a Mandli Technologies Private Ltd business record shall be retained according to Mandli Technologies Private Ltd Record Retention Schedule. The Mandli Technologies Private Ltd email system shall not to be used for the creation or distribution of any disruptive or offensive messages, including offensive comments about race, gender, hair color, disabilities, age, sexual orientation, pornography, religious beliefs and practice, political beliefs, or national origin. Employees who receive any emails with this content from any Mandli Technologies Private Ltd employee should report the matter to their supervisor immediately.

Legal and Regulatory Compliance Policy

Policy Statement:-- Mandli Technologies Private Ltd is committed to and conducts its business activities lawfully and in a manner that is consistent with its compliance obligations. The Legal and Regulatory Compliance Policy (Compliance Policy) establishes the overarching principles and commitment to action for Mandli Technologies Private Ltd with respect to achieving compliance by: identifying a clear compliance framework within which Mandli Technologies Private Ltd operates; promoting a consistent, rigorous and comprehensive approach to compliance throughout Mandli Technologies Private Ltd; developing and maintaining practices that facilitate and monitor compliance within Mandli Technologies Private Ltd; seeking to ensure standards of good corporate governance, ethics and community expectations; and engendering a culture of compliance where every person within Mandli Technologies Private Ltd accepts personal responsibility for compliance and acts ethically and with integrity.

Scope :-- This policy applies to Mandli Technologies Private Ltd.’s directors and employees, and to all contractors working for or at Mandli Technologies Private Ltd (our people). Mandli Technologies Private Ltd.’s legal and regulatory compliance obligations include: Legal obligations, including: o legislative; contractual; permits, licences and other forms of authorisation; o common law; equitable obligations; and relevant industry codes and compulsory standards; External obligations, including: Regulatory policies and codes; and Mandli Technologies Private Ltd policies, procedures and guidelines. Detailed operational procedures support Mandli Technologies Private Ltd’s legal and regulatory compliance obligations.

Contact us

If you have any questions about this GDPR -PRIVACY POLICIES, please contact us at:(https://www.mandli.org/contactus)

Website : www.mandli.org