Data Protection Policy

1. Purpose
This policy establishes the framework for protecting sensitive data managed by Texoma Network Solutions, ensuring compliance with applicable laws and industry standards, and mitigating risks associated with data breaches and unauthorized access.

2. Scope
This policy applies to all systems, networks, personnel, and third-party vendors that access, process, store, or transmit data on behalf of Texoma Network Solutions.

3. Key Principles
Data Minimization: Only collect and retain data necessary for business operations.
Access Control: Access to data is granted on a least-privilege basis.
Accountability: All users are responsible for safeguarding the data they handle.
Transparency: Data subjects are informed of how their data is used and protected.

4. Admin Privileges and Waiver of Liability
No employee, contractor, or third-party vendor shall be granted administrative privileges to any system, application, or infrastructure component without a signed Waiver of Liability and Responsibility Agreement.
This waiver must:
Acknowledge the risks associated with elevated access.
Confirm the individual’s understanding of their responsibilities.
Indemnify the company against misuse or negligence resulting from such access.
Admin access will be revoked immediately if the waiver is not on file or is found to be incomplete.

5. Data Protection Measures
5.1 Authentication and Access Control
Multi-factor authentication (MFA) is mandatory for all privileged accounts.
Role-based access control (RBAC) is enforced across all systems.
Regular audits of access logs and permissions are conducted.
5.2 Encryption
All sensitive data must be encrypted at rest and in transit using industry-standard protocols (e.g., AES-256, TLS 1.2+).
5.3 Data Retention and Disposal
Data is retained only as long as necessary for legal or operational purposes.
Secure deletion methods (e.g., DoD 5220.22-M) are used for data disposal.
5.4 Incident Response
A formal incident response plan is in place.
All data breaches must be reported within 24 hours to the Data Protection Officer (DPO).
5.5 Vendor Management
All vendors must undergo a security assessment before onboarding.
Data processing agreements (DPAs) are required for all third-party data handlers.

6. Compliance Frameworks
This policy aligns with the following standards and regulations:
HIPAA/HITECH (for healthcare data)
CMMC (for DoD contractors)
ISO/IEC 27001 (information security management)
GDPR (EU data protection)
CCPA/CPRA (California consumer privacy)

7. Training and Awareness
All personnel must complete annual data protection training. Specialized training is required for those with access to sensitive or regulated data.

8. Policy Violations
Violations of this policy may result in disciplinary action, including termination of employment or contract, and potential legal consequences.

9. Data Breach Notification
9.1 Definition of a Data Breach
A data breach is defined as any unauthorized access to, disclosure of, or loss of sensitive, confidential, or protected data, whether intentional or accidental.
9.2 Detection and Reporting
All employees and contractors must immediately report any suspected or confirmed data breach to the Data Protection Officer (DPO) or designated authority.
Reports must include the nature of the breach, systems affected, data involved, and any known or suspected cause.
9.3 Notification Timeline
The company will assess the breach within 72 hours of discovery.
If the breach is likely to result in a risk to the rights and freedoms of individuals, affected parties will be notified without undue delay.
Regulatory authorities (e.g., FTC, State Attorney General, GDPR Supervisory Authority) will be notified as required by applicable law.
9.4 Notification Content
Notifications will include:
A description of the nature of the breach.
Contact details of the DPO or relevant contact person.
Likely consequences of the breach.
Measures taken or proposed to address the breach and mitigate its effects.
9.5 Remediation and Documentation
Affected systems will be isolated and investigated.
A root cause analysis will be conducted.
All breaches will be documented, including actions taken and lessons learned.
Policies and controls will be updated as necessary to prevent recurrence.