Data Breach Response Policy

1.0 Purpose

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.

Tulip 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 Tulip’s established culture of openness, trust and integrity should respond to such activity. Tulip Information Security is committed to protecting Tulip's employees, partners and the company from illegal or damaging actions by individuals, either knowingly or unknowingly.

1.1 Background

This policy mandates that any individual who suspects that a theft, breach or exposure of Tulip Protected data or Tulip Sensitive data has occurred must immediately provide a description of what occurred via e-mail to support@tulip.org, alert on-call engineering and file a IT Security Deviation ticket. This e-mail address and web page are monitored by the Tulip’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.

2.0 Scope

This policy applies to all whom collect, access, maintain, distribute, process, protect, store, use, transmit, dispose of, or otherwise handle secure, confidential or personally identifiable information of Tulip employees or affiliates. Any agreements with vendors will contain language similar that protects the entities.

3.0 Policy Confirmed Theft, Data Breach or Exposure of Tulip Protected Data or Tulip Sensitive Data

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

The team may include members from:

• IT Infrastructure

• IT Applications

• Finance (if applicable)

• Legal

• Communications

• Customer Services (if Customer 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.

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 Tulip 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 Tulip 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.

3.2 Ownership and Responsibilities

Roles & Responsibilities:

• Sponsors are those members of the Tulip community that have primary responsibility for maintaining any particular information resource. Sponsors may be designated by any Tulip 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 Tulip community, designated by the Tulip Executive in charge of 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 Tulip 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.

4.0 Enforcement

Any Tulip 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.

5.0 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.

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.