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GENOMA BIOINFORMATICS LLC
DATA BREACH RESPONSE PLAN
Last Updated: February 27, 2025

1. Purpose

This Data Breach Response Plan (“Plan”) outlines the procedures for identifying, containing, assessing, and responding to data breaches involving personal or sensitive data. The goal is to minimize damage, comply with legal obligations, and maintain trust with clients.

2. Definitions

  1. Data Breach: A security incident that results in unauthorized access to or disclosure of personal or sensitive data.
  2. Personal Data: Any information relating to an identified or identifiable individual, as defined under GDPR.
  3. Sensitive Data: Includes Protected Health Information (PHI) under HIPAA and other sensitive information.

3. Incident Response Team

  1. Team Members:
    • Data Protection Officer (DPO): [Insert Data Protection Officer].
    • IT Security Lead: [Insert Name and Contact Information].
    • Legal Counsel: [Insert Name and Contact Information].
    • Communications Lead: [Insert Name and Contact Information].
  2. Responsibilities:
    • Identify and assess potential breaches.
    • Contain and mitigate the breach.
    • Notify affected parties and regulatory authorities.
    • Document and review the incident for future improvements.

4. Incident Identification and Assessment

  1. Monitoring: Regularly monitor systems for unusual activity or potential security incidents.
  2. Reporting: Employees and contractors must report potential breaches to the DPO immediately.
  3. Initial Assessment: The DPO will assess the incident to determine if it constitutes a data breach.

5. Containment and Mitigation

  1. Immediate Actions:
    • Isolate affected systems to prevent further unauthorized access.
    • Preserve evidence for forensic analysis.
  2. Mitigation:
    • Identify and address the root cause of the breach.
    • Implement temporary fixes to prevent further damage.

6. Notification

  1. Internal Notification:
    • Notify the Incident Response Team and senior management.
  2. Client Notification:
    • Notify affected clients within 72 hours of discovering the breach, as required by GDPR.
    • Provide details of the breach, including the nature of the data involved and the steps being taken to address it.
  3. Regulatory Notification:
    • Notify relevant regulatory authorities (e.g., GDPR supervisory authority, HIPAA Office for Civil Rights) within the required timeframe.
  4. Public Notification:
    • If necessary, issue a public statement to inform stakeholders and maintain transparency.

7. Documentation and Review

  1. Incident Report: Document all details of the breach, including:
    • Date and time of the breach.
    • Nature and scope of the breach.
    • Steps taken to contain and mitigate the breach.
    • Notifications made to clients and regulators.
  2. Post-Incident Review: Conduct a review to identify lessons learned and improve future response efforts.

8. Training and Awareness

  1. Employee Training: Provide regular training to employees on data protection and breach response procedures.
  2. Incident Drills: Conduct periodic drills to test the effectiveness of the Plan.

9. Compliance

  1. GDPR: Comply with GDPR requirements for breach notification and data protection.
  2. HIPAA: Comply with HIPAA requirements for breach notification and safeguarding PHI.

10. Contact Information

If you have any questions about this Plan, please contact us at:
Genoma Bioinformatics LLC