How to create a data security policy, with template

Why are data security policies important?

Data security policies are important for the following two main reasons:

1. They specify how an organization intends to manage the security of its data and information. This ensures all employees are aware of their responsibilities for accessing and protecting company data.
2. They help demonstrate compliance with local and global data privacy and security standards, such as ISO 27001, ISO 27002, NIST Special Publication 800-53, GDPR and Federal Information Security Management Act.

Key elements of a data security policy

Keep in mind the following key elements when creating and implementing a data security policy:

1. Scope. Provide a summary of the policy, as well as who and what activities it affects.
2. Responsibility. List who manages, upgrades and maintains the elements and components of the policy.
3. Objectives. Explain why this policy is needed.
4. Strategy and focus. Lay out the primary strategy to achieve the objectives and any IT security frameworks and standards it aligns to.
5. Policy. Outline the policy and any related processes, as well as how policy violations and updates will be addressed.
6. Additional policies. List other policies that may apply to the policy at hand. In a data security policy, this may include data classification, end-user computing, access management and acceptable use policies.
7. Applicability of other policies. Explain how other policies may apply.
8. Enforcement. List who enforces the policy.
9. Management and audit review. Discuss the policy review, and update schedule and cadence.

How to create a data security policy

Organizations with formal cybersecurity or information security policies typically already have the main elements needed for a data security policy.

All data security policies should do the following:

• be developed by a team that can address operational, legal, compliance and other issues associated with data security;
• have input from internal departments about data requirements;
• be coordinated with HR to ensure uniform compliance by employees;
• be supported by senior management;
• be regularly reviewed and updated;
• specify who has access to company data;
• specify data security access controls, e.g., two-factor authentication, role-based access and encryption;
• specify data security requirements for physical devices, e.g., laptops, mobile devices and firewalls;
• identify the frequency of change to data security controls; and
• be periodically audited to ensure data security controls are being followed.

As the primary entity responsible for data security, IT departments should consider the following issues when developing data security policies:

• procedures for managing data security using approved security controls;
• criteria for employees accessing data;
• technologies used to ensure data security;
• types of data resources that need to be protected;
• emergency procedures, e.g., data backups, for data breaches and other security events;
• procedures to protect data from security breaches, ransomware attacks and other malware and cyber attacks;
• procedures to test and validate that data security protocols and access controls are performing properly; and
• integration of data security with other data protection activities.

Best practices for data security policy development

The following is a list of best practices to perform when developing and administering a data security policy:

• Determine the data security requirements within the organization -- for example, which departments have the greatest need and responsibility to protect sensitive data.
• Ensure senior management supports the policy.
• Prepare and circulate a draft of the policy for review by senior management, legal, compliance, risk management, IT, HR and other relevant departments.
• Announce the new policy once it's approved, and conduct security awareness training to ensure employees understand the policy and their responsibilities. Establish who owns the policy, who reviews and updates it, and who is responsible for supporting and conducting audits on the policy.
• Establish noncompliance penalties for employees, visitors, contractors and others governed by the policy.