Security Incidents & Data Breach Management Policy and Procedure

Security Incidents & Data Breach Management Policy and Procedure
April 14, 2025
Incident Management Plan
Introduction
This plan outlines the procedures for identifying, responding to, mitigating, and recovering from cybersecurity incidents affecting monecopote.com. The goal is to ensure the well-functioning of the platform in compliance with laws and regulations in force and protect it from cyber threats.
Baticlick is committed to exercising due care and attention to (i) taking preventive measures against cyber incidents, (ii) handling them appropriately when they occur, (iii) providing information to staff and other concerned parties (users, sellers, clients, partners, contractors, suppliers, authorities) as necessary, and (iv) restoring access and operations as soon as possible.
Incident categories
Potential threats include :
DDoS Attacks – Disrupting website availability.
Malware Infections – Injecting malicious code into the platform.
Unauthorized Access – Data breaches or account takeovers.
Payment Fraud – Fake transactions affecting users.
Phishing/Social Engineering – Attacks on admins or users.
Preventive measures to be considered in this context include :
Regular security audits – Conduct periodic penetration testing.
Strong access controls – Use MFA and role-based permissions.
Data encryption – Secure sensitive information.
Web Application Firewall (WAF) – Protect against attacks.
Backup & disaster recovery – Ensure daily backups are stored securely.
Incident detection & reporting shall be done as follows :
Monitoring of the trafic and logs by an external service provider
User reporting by means of a contact form to report suspicious activities
Automated alerts for abnormal traffic or login attempts
Incident response steps
When an incident is detected, it is crucial to follow a structured approach to contain and mitigate the threat effectively. The following five-phase response process will be implemented:
- Identification & Classification (to determine whether an incident has occurred and assess its severity.)
Initial detection by system monitoring and review of user reports on suspicious activities (e.g. unauthorized logins, fraudulent transactions)
Log & analyze data by gathering logs from affected systems, including access logs, error logs, and network traffic, and by identifying attack vectors (e.g., phishing, malware, SQL injection).
Classify the Incident: Low severity for minor security issuee (e.g., failed login attempts) ; medium severity for incidents with potential impact (e.g., small-scale malware infection) ; high severity for active threat affecting users or business operations ; critical severity for major security breaches (e.g., data leak, ransomware attack)
Activate response team by notifying the incident response lead and IT security
2. Containment (to limit the spread and damage of the incident while preserving forensic evidence.
Short-Term Actions:
Network containment (Block malicious IPs or geo-restrict access if necessary ; segregate affected systems from the main network)
Account containment (Disable compromised user/admin accounts ; enforce password resets for affected users)
Application containment (Temporarily disable affected website functionalities (e.g., payment gateway, order processing) ; update firewall rules to block malicious traffic.
Long-Term Actions :
Secure backups (Verify that recent backups are uncompromised ; if necessary, shift traffic to a backup server)
Preserve evidence (Make copies of affected system logs for forensic analysis ; document all actions taken during containment)
3. Eradication & recovery (to remove the root cause of the incident and restore normal operations.
Eradication Steps:
Identify the attack vector (analyze logs, malware signatures, and attack patterns ; determine whether human error, system vulnerability, or external attack was the cause)
Patch vulnerabilities (apply software updates, security patches, and configuration fixes ; strengthen firewall, authentication, and API security)
Malware removal (run antivirus/malware scans on affected systems ; delete or quarantine infected files
Recovery Steps:
Restore services (reinstall affected applications if necessary ; restore data from backups, ensuring no malware reinfection)
Monitor for residual threats (conduct post-recovery penetration testing. increase log monitoring for unusual behavior)
4. Communication & notification (to ensure timely and transparent communication with stakeholders)
Internal communication (inform management, IT and legal teams ; conduct a status update meeting with the response team)
External communication (notify affected users ; advise users to reset passwords and enable 2FA ; if legally required, report breaches to data protection authorities ; inform third-party vendors if their services were affected)
5. Post-incident review & lessons learned (to improve security defenses to prevent future incidents)
Actions:
Conduct an incident review (analyze logs, attack vectors, and response effectiveness ; identify gaps in detection, containment, and recovery processes)
Document findings (create a detailed report including root cause analysis and response steps ; recommend improvements for security policies)
Enhance security controls (update firewall rules, IDS/IPS settings, and access controls ; implement additional training for staff to recognize cyber threats)
Contact & response team
Incident response lead: Gaëtan Bio
IT security contact :Gaëtan Bio
Legal & compliance contact : Gaëtan Bio
Appendix 2: Incident Response Instructions for IT Systems
DOs
Immediately isolate the affected system to stop further issues. Use phone communication instead of email. Save all logs, such as firewall and system logs. Create backup copies of any damaged files and store them securely. Determine where the affected system is in the network. List all systems connected to the affected system. Identify programs running on the system, the impact of the issue, and allowable downtime. If the system is collected as evidence, ensure services continue by using backups or a redundant system.
DON’Ts
Do not discuss the issue with anyone except your manager or designated contacts. Do not delete or modify files on the affected system. Do not contact the suspected individual. Do not perform any forensic analysis.
Appendix 3: Overview of Privacy Risk Ratings
Factor | RISK RATING | ||
LOW | MEDIUM | HIGH | |
Nature of personal information | Publicly available personal information not associated with any other information | Personal information unique to the organization that is not medical or financial information | Medical, psychological, counselling, or financial information or unique public body identification number |
Relationships | Accidental disclosure to contractor who reported breach and confirmed destruction or return of the information | Accidental disclosure to a stranger who reported the breach and confirmed destruction or return of the information | Disclosure to an individual with some relationship to or knowledge of the affected individual(s), particularly disclosures to motivated family members, neighbours or co‐ workers |
Theft | |||
Cause of the breach | Technical error that has been resolved | Accidental loss or disclosure | Intentional breach. Cause unknown Technical error – if not resolved |
Scope | Very few affected individuals | Identified and limited group of affected individuals | Large group or entire scope of group not identified (over 100) |
Containment efforts | Data was adequately encrypted Portable storage device was remotely wiped and there is evidence that the device was not accessed prior to wiping Hard copy files or device were recovered almost immediately and all files appear intact and/or unread | Portable storage device was remotely wiped within hours of loss but there is no evidence to confirm that the device was not accessed prior to wiping Hard copy files or device were recovered but sufficient time passed between the loss and recovery that the data could have been accessed | Data was not encrypted Data, files or device have not been recovered Data at risk of further disclosure particularly through mass media or online |
Foreseeable harm from the breach | No foreseeable harm from the breach | Loss of business or employment opportunities, hurt, humiliation, damage to reputation or relationships, social/relational harm Loss of trust in My Eco Best Friend Loss of My Eco Best Friend assets Loss of My Eco Best Friend contracts or business Financial exposure |