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Alex Denne
Growth @ Ƶ | Introduction to Contracts @ UCL Faculty of Laws | Serial Founder

Creating a Cyber Security Policy

9 Jun 2023
25 min
Text Link

Note: Links to our free templates are at the bottom of this long guide.
Also note: This is not legal advice

Introduction

Creating a strong cyber security policy is becoming increasingly important for organizations, as the potential risks and threats posed by malicious actors in the digital world are growing ever more frequent and sophisticated. An effective cyber security policy is essential for businesses to protect their confidential data, prevent unauthorized access, and keep their operations running smoothly.

At Ƶ, we believe that prevention is key when it comes to keeping organizations safe from cyber attacks. Having the right policies in place can help reduce the chances of a security breach or data loss occurring and provide an added layer of protection. However, simply having a policy isn’t enough - organizations must ensure that it’s tailored to their specific needs, regularly reviewed and updated with any changes in industry regulations or laws taken into account.

For instance, an organization that processes large amounts of customer data may need to establish more stringent protocols than one with fewer customers; conversely a business with employees working remotely or from multiple locations should ensure its staff are properly trained on cyber security best practices.

Our team provides free templates designed specifically for creating comprehensive cyber security policies which take into account different requirements across industries as well as varying legal implications such as data protection laws across countries. To make sure our templates remain up-to-date with market standards, we have established the world’s largest open source legal template library which uses machine learning based on countless datapoints collected over time – allowing users to customize high quality documents and draft them without needing a lawyer’s help!

If you’re looking for help drafting your own effective cyber security policy but don’t know where to start – read on below for our step-by-step guide on how you can use Ƶ’s template library today! No matter what size your organization is or what sector you’re in – following these steps will ensure you have all bases covered when it comes to protecting your business from malicious actors online.

Definitions

Scope: The range of what the policy covers.
Goals: The objectives the policy intends to achieve.
Risk Assessment: Evaluating potential risks associated with the policy.
Threats: Possibilities of something bad happening.
Vulnerabilities: Weaknesses that can be taken advantage of.
Weaknesses: Areas of a policy that may be exploited.
Prioritizing: Ranking risks according to their likelihood and potential impact.
Preventing: Developing measures to stop risks from occurring.
Detecting: Putting measures in place to identify risks.
Responding: Establishing processes for dealing with detected risks.
Documenting: Recording security requirements and procedures.
Implementing: Distributing and testing the security policy.
Outlining: Explaining the responsibilities of employees related to the policy.
Guidance: Information about how to use security measures.
Monitoring: Examining logs and data to identify any areas of weakness.
Audits: Evaluating the policy for changes or improvements.
Assessing: Examining the policy against industry standards and regulations.
Compliance: Ensuring the policy is following applicable laws.
Investigating: Looking into any changes to applicable regulations.
Reporting: Designing a system for employees to report any security issues.

Contents

  1. Identifying the scope and goals of the policy
  2. Establishing a risk assessment process
  3. Assessing the potential risks associated with the policy
  4. Prioritizing risks based on likelihood and potential impact
  5. Developing appropriate security measures
  6. Establishing measures to prevent, detect and respond to risks
  7. Documenting security requirements and procedures
  8. Implementing the security policy
  9. Communicating and distributing the policy to relevant stakeholders
  10. Testing the security measures to ensure they are working correctly
  11. Training and educating employees about the policy
  12. Outlining the responsibilities of employees in relation to the policy
  13. Providing guidance about how to use the security measures
  14. Monitoring and assessing the policy’s effectiveness
  15. Gathering feedback from stakeholders about their experience with the policy
  16. Examining logs and data to identify any areas of weakness
  17. Conducting regular audits and reviews of the policy
  18. Evaluating the policy for any changes or improvements
  19. Assessing the policy against industry standards and regulations
  20. Ensuring compliance with regulations and standards
  21. Investigating any changes to applicable regulations
  22. Adjusting the policy as necessary to remain compliant
  23. Developing a plan for responding to security incidents
  24. Creating a process for identifying and responding to security incidents
  25. Documenting procedures for how to respond in the event of a breach
  26. Establishing a reporting process for security issues
  27. Designing a system for employees to report any security issues
  28. Developing a process for investigating and resolving any reported issues

Get started

Identifying the scope and goals of the policy

  • Assess what type of data is stored within your organization
  • Evaluate any potential risks to the data, such as unauthorized access, natural disasters, or malicious attacks
  • Establish clear objectives for the policy, such as data security, data integrity, and privacy
  • Identify any applicable laws or regulations that must be followed
  • Decide who should be responsible for policy implementation and enforcement

Once you have identified the scope and goals of the policy, you can check this step off your list and move on to the next step of establishing a risk assessment process.

Establishing a risk assessment process

  • Develop a risk assessment process that evaluates the potential risks associated with the implementation of the new policy.
  • Identify the resources needed such as personnel, technology, and other tools to complete the risk assessment.
  • Determine the criteria to be used when evaluating potential risks and the severity of the risks.
  • Develop a timeline for completing the risk assessment and forecast any potential risks.
  • Utilize tools, such as risk assessment software, to evaluate and report on the risks associated with the new policy.
  • When the risk assessment process is complete, document the results, assign owners to any identified risks and develop strategies to mitigate or address them.

You’ll know you are ready to move on to the next step when you have a risk assessment process plan in place that includes the resources and criteria needed to complete the assessment, as well as a timeline for completing the assessment.

Assessing the potential risks associated with the policy

  • Gather information about the organization and its activities to identify potential risks.
  • Identify the sources of potential cyber security risks, such as external threats, employee activities, and system vulnerabilities.
  • Assess the potential impact of each identified risk.
  • Assess the likelihood of each identified risk.
  • Document the identified risks and their associated impact and likelihood.
  • Once the risks have been identified and assessed, you can check this step off your list and move on to the next step.

Prioritizing risks based on likelihood and potential impact

  • Gather all the risks that have been identified and organize them into a table with columns labeled “risk,” “likelihood,” and “potential impact”
  • Assign a numerical rating to each risk that reflects its likelihood and potential impact
  • Assess the total risk score for each risk by multiplying its likelihood score by its potential impact score
  • Rank the risks according to their total risk score, with the highest risk appearing first in the list
  • When the risk assessment is complete and the risks have been ranked according to their total risk score, you can move on to developing appropriate security measures.

Developing appropriate security measures

  • Determine the type of security measures required to address the identified risks.
  • Consider the cost, complexity and effectiveness of the security measures.
  • Develop a plan to implement the security measures.
  • Test the security measures to ensure they are functioning correctly.
  • Adjust the security measures as needed to address any deficiencies.
  • Document the security measures in the security policy.

When you have completed this step of creating a cyber security policy, you will have a clear plan of the security measures you will use to protect your organization. You will be able to move on to the next step: Establishing measures to prevent, detect and respond to risks.

Establishing measures to prevent, detect and respond to risks

  • Identify and assess potential risks to your organization’s cyber security
  • Develop a plan of action to address each risk
  • Create policies and procedures for the prevention, detection, and response to cyber security threats
  • Ensure the organization understands and follows the policies and procedures
  • Implement security measures that can detect and respond to threats in a timely manner
  • Update policies, procedures, and security measures as needed

When you can check this off your list and move on to the next step:

  • When you have identified and assessed potential risks and have established measures to prevent, detect and respond to them.

Documenting security requirements and procedures

  • Identify the security requirements and procedures that need to be implemented in order to protect the organization’s data.
  • Create a document outlining all of the security requirements and procedures.
  • Ensure that all security requirements and procedures are in line with applicable laws and regulations.
  • Make sure that the document is easily accessible to all employees and stakeholders.
  • Regularly review the security requirements and procedures document to ensure that it is up to date.

When you can check this off your list and move on to the next step:

  • When all security requirements and procedures have been documented and are in line with applicable laws and regulations.
  • When the document is easily accessible to all employees and stakeholders.
  • When the document has been regularly reviewed and updated.

Implementing the security policy

  • Create a plan for implementation of the policy, including timelines and resources required
  • Assign responsibility for implementation to a dedicated security officer or team
  • Create a process to ensure compliance with the policy, including monitoring and auditing
  • Make the policy available to all users and ensure they understand their responsibilities
  • Educate users on the policy and its importance to the organization
  • Train staff on how to use the security policy and update it if needed
  • Develop a process for reviewing the policy and updating it as needed

When you have completed these tasks, you can move on to communicating and distributing the policy to relevant stakeholders.

Communicating and distributing the policy to relevant stakeholders

  • Draft a communication plan to explain the policy to stakeholders
  • Create a process to distribute the policy to all relevant stakeholders
  • Reach out to stakeholders to ensure they understand the policy
  • Monitor feedback from stakeholders to ensure policy is understood and accepted
  • Track stakeholders’ acknowledgement of the policy
  • Update stakeholders as needed when policy changes occur

When you can check this off your list and move on to the next step:

  • When all stakeholders have acknowledged the policy and understand the security requirements.

Testing the security measures to ensure they are working correctly

  • Test the security measures implemented to ensure they are functioning as intended.
  • Utilize automated tools such as vulnerability scanners and penetration testing to detect potential threats.
  • Ensure that all security measures are regularly updated and are able to protect against evolving threats.
  • Monitor access to systems and networks to protect against unauthorized access.
  • Confirm that the security measures are compliant with applicable regulations and standards.

When you have completed the testing process, you will have validated that your security measures are working as intended. You can then move on to the next step of training and educating employees about the policy.

Training and educating employees about the policy

  • Develop a training program to educate employees on the cyber security policy
  • Ensure the training program includes information on identifying threats, recognizing suspicious activity, and reporting security incidents
  • Provide refresher training every 6 months or after any significant changes to the policy
  • Document that each employee is aware of their roles and responsibilities under the policy
  • Allow for open discussion between staff and management on the policy
  • Once the training program has been completed, document that all employees have been trained on the policy
  • Allow for the employees to ask questions and provide feedback on the policy
  • Check off this step once all employees have completed the training program and have been documented to have received the necessary information

Outlining the responsibilities of employees in relation to the policy

  • Review existing policies and procedures related to cyber security
  • Draft a statement on the responsibilities of employees in relation to the policy
  • Clarify the roles and responsibilities of those who are in charge of the policy
  • Ensure that the responsibilities are clearly understood and communicated to all employees
  • Make sure employees are aware of the consequences of not abiding by the policy
  • Include a section on reporting any suspected cyber security breaches

You can check this step off your list when you have a finalized version of the policy outlining the responsibilities of employees in relation to it.

Providing guidance about how to use the security measures

  • Create a set of guidelines to instruct employees on how to use the security measures that have been implemented.
  • Ensure that the guidelines are clear, effective and easy to understand.
  • Provide examples of how the guidelines should be used in practice.
  • Make sure that the guidelines are updated and revised when necessary.
  • Once the guidelines have been written and communicated to employees, test them to make sure they are effective.

How you’ll know when you can check this off your list and move on to the next step:

  • Once the guidelines have been written, tested and communicated to employees, you can check this off your list and move on to the next step.

Monitoring and assessing the policy’s effectiveness

  • Establish a process for regular review of the policy and its effectiveness
  • Establish a timeline for review
  • Track and measure the effectiveness of the policy
  • Assess user feedback and employee compliance
  • Analyze the results of the review and make necessary changes to the policy
  • When the policy has been implemented and regularly reviewed, this step is complete and you can move on to the next step.

Gathering feedback from stakeholders about their experience with the policy

  • Create a survey for stakeholders to provide feedback on the policy.
  • Ask questions about their experience with the policy, including how easy it was to understand, how helpful it was in their day-to-day activities, and any issues they may have encountered.
  • Ensure that the survey is anonymous to encourage honest feedback.
  • Analyze the collected feedback and identify areas of improvement.
  • Discuss the feedback with the stakeholders and ask for additional input.
  • Once the feedback has been analyzed and discussed, you can check this step off your list and move on to the next step.

Examining logs and data to identify any areas of weakness

  • Review logs and data regularly to identify any areas of weakness
  • Look for areas where security protocols and procedures are not being followed
  • Monitor for any suspicious activity that could indicate a potential breach
  • Compare your data to industry standards and best practices
  • Evaluate any changes in your security posture from the previous audit
  • Once you’ve identified any areas of weakness, take steps to address them
  • Check off this step when all logs and data have been thoroughly examined and any areas of weakness have been addressed.

Conducting regular audits and reviews of the policy

  • Assign personnel to be responsible for and conduct regular audits and reviews of the policy
  • Schedule regular meetings to review the policy and determine if it is meeting the organization’s needs
  • Ensure that all personnel are aware of the policy and their responsibilities to adhere to it
  • Document findings and any changes that need to be made
  • Once all necessary changes have been made and approved, the policy is ready to be implemented
  • Once the policy is implemented, it should be reviewed and audited regularly to ensure it is up-to-date and effective
  • After each review and audit, the policy should be updated as needed
  • When all of the above steps have been completed, the policy review and audit process is complete and the policy is ready for implementation or further review.

Evaluating the policy for any changes or improvements

  • Compare the current policy with the original policy to determine any changes that may be necessary
  • Review any feedback from staff or other stakeholders regarding the policy
  • Examine the policy to ensure it is up-to-date with the changing use of technology
  • Check if the policy is still in alignment with current regulations and industry standards
  • Assess any changes needed to the policy and make necessary updates
  • Once the policy has been evaluated and all necessary changes have been made, it is complete and ready for the next step.

Assessing the policy against industry standards and regulations

  • Review the policy against any applicable industry or government standards that may apply
  • Ensure that the policy meets the requirements of those standards
  • Make note of any areas in which your policy diverges from the recommended standards
  • Once the policy has been reviewed and any necessary changes have been made, you can be sure that it is compliant with the relevant industry standards and regulations
  • Check this step off your list and move on to the next step of ensuring compliance with the regulations and standards.

Ensuring compliance with regulations and standards

  • Identify the regulations and standards that are applicable to your organization
  • Develop a compliance checklist for each applicable regulation and standard
  • Create a process for regularly monitoring compliance with regulations and standards
  • Ensure that procedures and policies are updated to reflect any changes to regulations and standards
  • Determine the process for handling any non-compliance issues
  • Establish a timeline for regularly auditing the cyber security policy

You can check this step off your list when you have identified all applicable regulations and standards, developed a compliance checklist, created a process for regularly monitoring compliance, updated procedures and policies to reflect any changes, determined a process for handling any non-compliance issues, and established a timeline for regularly auditing the cyber security policy.

Investigating any changes to applicable regulations

  • Identify any relevant changes to regulations or standards that apply to your organization
  • Review any new or updated regulations, laws, and standards to ensure that your cyber security policies remain compliant
  • Ask your IT security team or external consultants to help you evaluate the impact of any changes on your organization’s security policies
  • Keep up to date on any new or changing regulations or standards
  • Update your cyber security policies to accommodate any changes

When you have identified and evaluated all applicable changes to regulations and standards and have updated your policy accordingly, you can check this step off your list and move on to the next step.

Adjusting the policy as necessary to remain compliant

  • Review the current policy to ensure compliance with all applicable regulations.
  • Monitor any new laws and regulations that may impact your organization and adjust the policy accordingly.
  • Keep a record of any revisions made to the policy for future reference.

When you can check this off your list:

  • You have reviewed the current policy and ensured it is compliant with all regulations.
  • You have monitored any new laws and regulations that could affect your organization.
  • You have adjusted the policy accordingly and kept a record of any revisions made.

Developing a plan for responding to security incidents

  • Analyze current security incidents and develop a plan to respond to similar incidents in the future
  • Devise a set of procedures for dealing with security incidents, including how to quickly report, document, investigate, and address them
  • Assign a team or individual to take responsibility for responding to security incidents
  • Ensure that the response plan covers the entire process from initial detection to resolution
  • Define the roles and responsibilities of each team or individual involved in the response process
  • Test the incident response plan to ensure that it is comprehensive and effective
  • Update the plan regularly to ensure it remains up-to-date
  • Checklist of items completed when developing the plan to ensure that all necessary steps were taken
  • When the plan is in place, it’s complete and you can move on to the next step.

Creating a process for identifying and responding to security incidents

  • Develop a written process for identifying and responding to security incidents, including the roles and responsibilities of each person involved
  • Establish a timeline for responding to security incidents and how to report them
  • Create a plan for how to investigate and document security incidents
  • Outline the process for recovering from a security incident, including how to restore systems, data and services
  • When you have created a written process for identifying and responding to security incidents, you can check this off your list and move on to the next step.

Documenting procedures for how to respond in the event of a breach

  • Document procedures for responding to a security breach, such as steps that need to be taken in the event of a breach, who should be notified, and what information should be gathered.
  • Create an incident response plan that outlines the steps to be taken when a breach occurs and who is responsible for each step.
  • Include a process for how to handle customer data in the event of a breach, such as how to notify customers of the breach and how to protect their data.
  • Document procedures for how to handle internal data in the event of a breach, such as how to assess the damage and how to prevent further damage.
  • Develop a post-breach plan that outlines steps to take in order to restore systems and data.
  • When you have documented procedures for how to respond in the event of a breach, check it off your list and move on to the next step.

Establishing a reporting process for security issues

  • Establish a reporting process for employees to report any security issues that arise.
  • Decide who will be responsible for receiving and responding to reports.
  • Establish a process for how the reports will be responded to, including documenting the procedure.
  • Ensure all employees are aware of the reporting process, and that they understand the importance of reporting any security issues.

You will know when you can check this off your list and move on to the next step when you have a process established and all employees are aware of it.

Designing a system for employees to report any security issues

  • Decide on the communication channels that will be used for employees to report security issues (e.g. email, hotline, internal messaging platforms, etc.)
  • Develop a standard reporting format that employees should use when reporting security issues
  • Clearly explain to employees how to report security issues and the importance of doing so
  • Designate a team responsible for receiving and responding to reports
  • Ensure that employees are aware of the reporting system and how it should be used

When you have completed the above tasks, you can check this step off your list and move on to developing a process for investigating and resolving any reported issues.

Developing a process for investigating and resolving any reported issues

  • Establish a clear process for investigating and resolving reported issues, including assigning an individual or team to take responsibility for the investigation
  • Include a timeline for addressing reported issues, and set expectations for when the investigation will be completed
  • Ensure that the process is reviewed and updated regularly to ensure that it is up-to-date and effective
  • Develop a plan for responding to any security threats or incidents that are revealed during the investigation
  • Develop a plan for notifying affected parties in the event of a security incident
  • Create a system for tracking the progress of investigations and their outcomes
  • When the investigation is complete, create a report detailing the investigation and the results
  • How you’ll know when you can check this off your list and move on to the next step: When the investigation process has been established, reviewed and updated, and when a system is in place to track investigations and report their outcomes.

FAQ

Q: What legal requirements are there for companies in the UK to have a Cyber Security Policy?

Asked by Sarah on 1st August 2022.
A: The UK Government has made it a legal requirement for all organisations that collect and store personal data to have a Cyber Security Policy in place. This includes any company that processes or stores data on individuals, such as credit card details and personal information. The policy should outline how the company will protect against cyber threats, and how it will respond in the event of a security breach. Companies should also ensure that their policy is regularly reviewed and updated in line with any changes to the law or technology.

Q: What is the difference between a Cyber Security Policy and a Data Protection Policy?

Asked by Ryan on 31st December 2022.
A: A Cyber Security Policy is designed to protect a company’s digital assets from cyber threats, while a Data Protection Policy outlines the processes for collecting, storing and handling personal data. Both policies should be compliant with relevant laws and regulations, such as GDPR in the EU or PECR in the UK. The Cyber Security Policy will focus on preventing security breaches, while the Data Protection Policy will provide guidance on how to securely collect and store personal data.

Q: What regulation should I consider when creating a Cyber Security Policy?

Asked by Jessica on 19th October 2022.
A: When creating a Cyber Security Policy, it is important to consider all relevant regulations that may apply to your business. These may include GDPR in the EU, PECR in the UK, PCI-DSS for payment information, NIST guidelines for federal organisations, HIPAA for healthcare organisations, or even industry-specific regulations such as GDPR-K for the banking sector. It is also important to consider any legislation that may be specific to your country or region.

Q: How can I ensure my Cyber Security Policy is compliant with GDPR?

Asked by Jacob on 23rd April 2022.
A: To ensure that your Cyber Security Policy is compliant with GDPR, it is important to take into account all of the requirements outlined within the regulation. This includes ensuring that personal data is processed lawfully and transparently; only collected for specified and explicit purposes; kept securely; not used for any other purposes without explicit consent; kept accurate and up-to-date; and stored no longer than necessary. Additionally, companies must ensure that their policy protects against any potential risks posed by processing personal data, such as unauthorised access or misuse of data.

Q: What measures should I include in my Cyber Security Policy to protect against data breaches?

Asked by Emma on 5th June 2022.
A: There are various measures which can be included in your Cyber Security Policy in order to protect against data breaches. These include implementing strong passwords and two-factor authentication; regularly patching software; encrypting data; monitoring applications and networks for suspicious activity; educating employees about security best practices; regularly backing up data; using firewalls; implementing access control measures; and creating an incident response plan in case of a security breach.

Q: How can I create an effective incident response plan?

Asked by Noah on 8th September 2022.
A: An effective incident response plan should cover all aspects of responding to a security breach or malicious attack, including identifying potential sources of attack; assessing the scope of the attack; containing it quickly; restoring systems back to their original state; notifying affected parties or authorities if necessary; and learning from the incident in order to prevent similar attacks in future. It is important that all employees are aware of this plan and understand their role in case of an incident.

Q: How can I ensure my Cyber Security Policy meets industry-specific requirements?

Asked by Olivia on 12th February 2022.
A: Depending on your industry or sector, there may be specific regulations or guidelines which must be taken into account when creating your Cyber Security Policy. For example, if you are operating within financial services you may need to adhere to GDPR-K requirements related to payment card data protection and privacy, while healthcare organisations must consider HIPAA guidelines when creating their policy. It is important to regularly review industry requirements and ensure your policy meets them at all times.

Q: Should I outsource my Cyber Security Policy implementation?

Asked by Ethan on 13th March 2022.
A: Outsourcing implementation of your Cyber Security Policy can be beneficial if you do not have sufficient resources or expertise available internally. However, it is important that you choose an experienced provider who understands your particular needs and risk profile and can provide comprehensive support throughout the process. Additionally, you should always ensure that you remain compliant with relevant laws and regulations at all times when outsourcing implementation of your policy.

Q: What standards should I use when creating my Cyber Security Policy?

Asked by Isabella on 4th November 2022.
A: When creating your Cyber Security Policy it is important to consider relevant standards which may apply to your sector or industry. For example, if you are operating within financial services then you may need to adhere to certain standards such as ISO 27001 or NIST 800-53 for federal organisations dealing with sensitive information. Additionally, it is recommended that companies implement best practices such as using strong passwords, encrypting data, monitoring networks for suspicious activity, backing up regularly etc., in order to ensure their digital assets are protected from cyber threats at all times.

Q: How often should I review my Cyber Security Policy?

Asked by James on 18th July 2022.
A: It is recommended that companies review their Cyber Security Policies regularly in order to ensure they remain compliant with relevant laws and regulations as well as industry standards applicable to them at any given time. Additionally, technologies change rapidly so it is important to review your policy whenever new technologies are implemented or updated within your organisation in order to ensure they are secure at all times against cyber threats such as malicious attacks or data breaches

Example dispute

Potential Lawsuit regarding Cyber Security Policy Breach

  • Plaintiff may be able to sue if they have suffered damage as a result of a company or organization’s failure to comply with their own cyber security policy.
  • The plaintiff can reference the cyber security policy that was violated and point to the specific provisions that were violated.
  • The plaintiff must show that they suffered a measurable loss as a result of the violation of the policy, such as lost data, financial damages, or other types of harm.
  • The plaintiff must also show that the defendant was aware of the cyber security policy and had a duty to comply with it.
  • The plaintiff may seek monetary damages to cover the costs of any losses resulting from the violation of the policy, as well as punitive damages to punish the defendant for their negligence.
  • The court may also order the defendant to take steps to comply with the policy, such as implementing additional security measures, in order to prevent a similar incident from occurring in the future.

Templates available (free to use)

Cyber Security Policy

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