Data Breach Response Policy

Overview

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 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. Elodyn publishes a Data Breach Response Policy to focus significant attention on data security and data security breaches and how Elodyn’s established culture of openness, trust and integrity should respond to such activity. Elodyn is committed to protecting its employees, partners and the company from illegal or damaging actions by individuals, either knowingly or unknowingly. Wavelength is a property of Elodyn Inc.

Background

This policy mandates that any individual who suspects that a theft, breach or exposure of Personal Data (as defined in the Data License Agreement) has occurred must immediately provide a description of what occurred via email to security [e-mail] or by calling [phone]. This email address and phone number are monitored by Elodyn’s CEO. Elodyn 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 CTO 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 of Elodyn or its customers’ constituents.

Policy

1. Confirmed theft, data breach or exposure of Personal Data.

   1. As soon as a theft, data breach or exposure containing Personal Data is identified, the process of removing all access to that resource will begin.

   2. The CEO will chair an incident response team to handle the breach or exposure.

   3. The CEO 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.

2. Work with Forensic Investigators

   1. As provided by Elodyn’s 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.

1. Develop a communication plan.

   1. Work with Elodyn to decide how to communicate the breach to: a) internal employees, b) the public, and c) those directly affected.

   2. Elodyn will notify all customers whose data is confirmed exposed or stolen within 24 hours of confirmation via email and/or phone.

   3. Elodyn will work with customers to appropriately report the data breach to affected parties.

2. Enforcement

   1. Any Elodyn personnel 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.