Phishing Policy Template for England and Wales

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Key Requirements PROMPT example:

Phishing Policy

"Need a comprehensive Phishing Policy for our investment management firm that complies with FCA requirements and includes specific protocols for protecting client financial data, to be implemented by March 2025."

Document background
The Phishing Policy is essential for organizations operating under English and Welsh law to protect against increasingly sophisticated cyber threats. This document is particularly crucial given the rise in phishing attacks and the regulatory requirements under UK data protection legislation. The policy should be implemented by organizations handling sensitive data or those subject to specific regulatory requirements. It provides comprehensive guidance on preventing phishing attacks, responding to incidents, and maintaining compliance with relevant legislation such as the UK GDPR and Data Protection Act 2018.
Suggested Sections

1. Purpose and Scope: Defines the objectives and scope of the phishing policy, including its application across the organization

2. Definitions: Detailed definitions of key terms used throughout the policy including phishing, spear phishing, whaling, and other related concepts

3. Roles and Responsibilities: Clearly defined roles and responsibilities for IT security team, management, employees, and other stakeholders

4. Phishing Prevention Measures: Technical and procedural controls implemented to prevent phishing attacks, including email filtering and authentication protocols

5. Incident Response Procedures: Step-by-step procedures for identifying, reporting, and responding to phishing attempts

6. Training Requirements: Mandatory security awareness training requirements, frequency, and assessment criteria

7. Compliance and Enforcement: Details of monitoring, compliance requirements, and consequences of policy violations

Optional Sections

1. Industry-Specific Requirements: Additional requirements specific to regulated industries such as financial services, healthcare, or government sectors

2. International Operations: Specific considerations and requirements for cross-border operations and international data protection compliance

3. Third Party Requirements: Security requirements and obligations for vendors, contractors, and other third parties accessing organizational systems

4. Remote Working Provisions: Specific guidance for preventing phishing attacks while working remotely or using personal devices

Suggested Schedules

1. Schedule 1: Training Program: Detailed outline of the security awareness training program, including curriculum and testing requirements

2. Schedule 2: Incident Response Flowchart: Visual representation of the incident response process and escalation procedures

3. Schedule 3: Technical Controls: Detailed specifications of technical controls and security measures implemented

4. Appendix A: Reporting Templates: Standard forms and templates for reporting phishing incidents and suspicious activities

5. Appendix B: Contact List: Emergency contacts and escalation matrix for incident response

6. Appendix C: Common Phishing Examples: Examples of common phishing attempts and red flags to watch for

Authors

Alex Denne

Head of Growth (Open Source Law) @ Genie AI | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

Relevant legal definitions
Clauses
Relevant Industries
Relevant Teams
Relevant Roles
Industries

Data Protection Act 2018: Primary UK legislation governing data protection, implementing and supplementing the UK GDPR, setting out requirements for personal data processing and protection

UK GDPR: Post-Brexit version of EU GDPR, providing framework for data protection in the UK, including requirements for data security and breach notification

Computer Misuse Act 1990: Legislation criminalizing unauthorized access to computer systems and data, relevant for addressing phishing attacks and cybercrime

Privacy and Electronic Communications Regulations 2003: Regulations governing electronic communications, including requirements for electronic marketing and communication security

Network and Information Systems Regulations 2018: Framework for cybersecurity requirements, particularly for essential services and digital service providers

ICO Guidelines: Regulatory guidance from the Information Commissioner's Office on data protection and security best practices

NCSC Guidance: National Cyber Security Centre's recommendations and best practices for cybersecurity and phishing prevention

FCA Requirements: Financial Conduct Authority regulations relevant to financial services firms regarding cyber security and customer protection

Employment Rights Act 1996: Legislative framework for employment rights, relevant for employee training and responsibilities in phishing prevention

Health and Safety at Work Act 1974: Legislation concerning workplace safety, including psychological wellbeing related to cyber threats and stress

PCI DSS: Payment Card Industry Data Security Standard requirements for organizations handling payment card data

EU GDPR: European Union data protection regulation, relevant for organizations operating across UK and EU borders

Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

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