1. Purpose
The purpose of this policy is to establish a systematic framework for identifying, reporting, managing, and resolving information security and operational incidents within Bayarcash. The goal is to minimize the impact of incidents, protect customer and company data, and restore normal operations as quickly as possible.
2. Scope
This policy applies to:
- All Bayarcash employees, contractors, vendors, and third parties with access to Bayarcash systems or data.
- All IT systems, applications, databases, networks, and digital assets managed by Bayarcash.
- All types of incidents, including cybersecurity breaches, data leaks, service disruptions, or fraud attempts.
3. Policy Statement
Bayarcash is committed to:
- Detecting, containing, and responding to incidents promptly and effectively.
- Ensuring incidents are properly documented, investigated, and reported.
- Preventing recurrence through lessons learned and continuous improvement.
- Maintaining compliance with applicable regulatory and data protection requirements (e.g., PCI DSS, GDPR, AML laws).
4. Definitions
- Incident: Any event that disrupts normal operations, compromises security, or threatens the confidentiality, integrity, or availability of systems or data.
- Security Breach: Unauthorized access, disclosure, or misuse of Bayarcash data or systems.
- Incident Response Team (IRT): A designated group responsible for managing and resolving incidents.
5. Roles & Responsibilities
5.1 Incident Response Team (IRT)
- Lead incident detection, containment, eradication, and recovery efforts.
- Maintain incident documentation and evidence.
- Coordinate communication and escalation during incidents.
5.2 IT / Security Team
- Implement monitoring tools and alerts for early detection.
- Provide technical support during containment and recovery.
- Conduct post-incident technical reviews.
5.3 Management
- Approve major decisions during critical incidents.
- Communicate with external stakeholders, regulators, and customers when necessary.
5.4 Employees
- Immediately report suspected incidents to the IRT or IT Security Team.
- Preserve evidence and cooperate during investigations.
6. Incident Categories
| Category | Examples | Priority Level |
|---|---|---|
| Category 1 - Critical | Data breach, ransomware, system outage affecting transactions | High |
| Category 2 - Major | Unauthorized access attempts, malware detection | Medium |
| Category 3 - Minor | Phishing email reports, failed login attempts | Low |
7. Incident Response Process
7.1 Identification
- Detect incidents through automated alerts, employee reports, or monitoring systems.
- Log incident details: date, time, system affected, and nature of incident.
7.2 Containment
- Isolate affected systems or networks to prevent further impact.
- Disable compromised accounts, block malicious IPs, and restrict access if necessary.
7.3 Eradication
- Remove malware, unauthorized code, or compromised accounts.
- Apply patches, update security configurations, and verify threat removal.
7.4 Recovery
- Restore systems and services from clean backups.
- Verify that affected systems are fully functional and secure.
- Closely monitor systems for recurrence.
7.5 Post-Incident Review
- Conduct a root cause analysis (RCA).
- Document lessons learned and update policies or controls.
- Report to management and, if required, regulatory bodies.
8. Incident Reporting & Escalation
- All incidents must be reported immediately to the IRT via [designated email or hotline].
- High-severity incidents must be escalated to senior management and the Compliance Team within 1 hour.
- Regulatory or customer-impacting incidents must be reported to relevant authorities within legally mandated timeframes (e.g., 72 hours under GDPR).
9. Communication Protocol
- The IRT Lead coordinates all internal and external communication.
- No employee shall disclose incident details publicly or to unauthorized parties.
- Communication with media or law enforcement requires approval from the Executive Management and Legal/Compliance teams.
10. Evidence Preservation
- Maintain logs, screenshots, system images, and any related evidence.
- Evidence must be securely stored and handled to preserve integrity for possible legal or regulatory review.
11. Training & Awareness
- All employees must undergo annual incident response and security awareness training.
- The IRT will conduct incident response simulations at least twice per year to ensure readiness.
12. Documentation & Record Keeping
- Each incident must have a completed Incident Report Form documenting:
- Description of incident
- Root cause
- Actions taken
- Impact assessment
- Lessons learned
- Incident records must be retained for at least 7 years in accordance with the Record Retention Policy.
13. Compliance & Audit
- Regular audits will be conducted to ensure adherence to this policy and related procedures.
- Non-compliance may result in disciplinary action, up to and including termination.
14. Continuous Improvement
- The IRT will review incident patterns and update security measures accordingly.
- Lessons learned will be incorporated into future incident prevention and response strategies.
15. Policy Review
This policy shall be reviewed annually or following major incidents, regulatory changes, or updates in Bayarcash’s operational environment.