1. Purpose
This policy establishes TheAgencyFounder’s procedures for identifying, assessing, and notifying clients — including Meta — in the event of a confirmed or suspected data breach. Its objective is to ensure compliance with applicable laws, contractual obligations, and industry best practices, while minimizing the impact of a breach.
2. Scope
This policy applies to all employees, contractors, vendors, and third parties who handle, access, process, or store data shared by Meta or any other client under our partnership agreement.
3. Definition of a Data Breach
A data breach is any confirmed or suspected incident in which there is unauthorized access to, disclosure of, or loss of client data — including, but not limited to:
- Unauthorized access by internal or external parties
- Accidental disclosure or transmission of data to unauthorized recipients
- Loss or theft of devices containing client data
- Ransomware or malicious attack impacting confidentiality, integrity, or availability
4. Breach Detection & Reporting
- Immediate Reporting: Any employee, contractor, or vendor who becomes aware of a potential breach must report it within 1 hour to the Data Protection Officer (DPO) at: [Insert DPO contact details]
- Incident Logging: All incidents will be recorded in the Security Incident Register with details such as date, time, nature of breach, and initial containment steps.
- Investigation: The Security & IT team will investigate and confirm whether the event qualifies as a breach.
5. Notification Procedure
Once a breach is confirmed:
- Internal Notification: Notify the CEO, DPO, and legal counsel immediately.
- Client Notification: Notify Meta (and any affected clients) within 72 hours of confirmation, or sooner if contractually required.
- Notification will include:
- Nature and scope of the breach
- Categories and volume of data affected
- Date/time of the incident
- Containment and remediation measures taken
- Contact details for follow-up
- Nature and scope of the breach
- Notification will include:
- Regulatory Reporting: Where applicable, notify relevant regulatory authorities as required by law.
- Internal Notification: Notify the CEO, DPO, and legal counsel immediately.
6. Containment & Recovery
- Isolate affected systems to prevent further damage.
- Implement temporary security measures while permanent fixes are deployed.
- Conduct forensic analysis to determine the root cause.
- Patch vulnerabilities and restore affected services.
7. Post-Incident Review
- Conduct a Post-Breach Review Meeting within 7 days to document lessons learned.
- Update security controls, policies, and staff training based on findings.
8. Employee Responsibilities
- Complete mandatory annual security awareness training.
- Immediately report any suspicious activity or security anomalies.
9. Enforcement
Failure to follow this policy may result in disciplinary action, termination of contracts, or legal action, depending on the severity of the violation.