Phishing Policy Template for Singapore

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Key Requirements PROMPT example:

Phishing Policy

"I need a comprehensive Phishing Policy for our Singapore-based fintech startup with 50 employees, which must comply with MAS guidelines and include specific procedures for handling cryptocurrency-related phishing threats."

Document background
The Phishing Policy serves as a crucial document for organizations operating in Singapore's increasingly digital business environment. It is designed to protect against sophisticated phishing threats while ensuring compliance with Singapore's cybersecurity regulations. This policy should be implemented when organizations need to establish clear guidelines for phishing prevention, detection, and response, particularly in light of increasing cyber threats and regulatory requirements. The policy includes comprehensive procedures for employee training, incident response, and reporting mechanisms, aligned with Singapore's Personal Data Protection Act and related cybersecurity legislation.
Suggested Sections

1. Purpose and Scope: Defines the objectives and applicability of the policy, including compliance with Singapore's legal framework

2. Definitions: Key terms used throughout the policy, including technical terms related to phishing and cybersecurity

3. Roles and Responsibilities: Defines responsibilities for IT security team, management, employees, and other stakeholders in preventing and responding to phishing attempts

4. Phishing Prevention Measures: Core preventive controls, technical safeguards, and procedures to prevent phishing attacks

5. Incident Response: Detailed procedures for identifying, reporting, and responding to phishing attempts, including mandatory breach notification requirements

6. Training Requirements: Mandatory security awareness training specifications and frequency of refresher courses

Optional Sections

1. Industry-Specific Requirements: Additional requirements for regulated industries, particularly relevant for financial services sector under MAS guidelines

2. Third-Party Management: Controls and procedures for managing third-party phishing risks and vendor security requirements

3. Cross-Border Considerations: Requirements for international data transfer and compliance with cross-border regulations

Suggested Schedules

1. Incident Response Flowchart: Visual representation of incident response procedures and escalation paths

2. Reporting Templates: Standard forms for reporting phishing incidents and suspected breaches

3. Training Materials: Reference materials and guidelines for security awareness training

4. Common Phishing Indicators: Comprehensive list of common signs and indicators that may indicate phishing attempts

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
Industries

Personal Data Protection Act (PDPA) 2012: Singapore's primary data protection legislation that governs the collection, use, disclosure, and protection of personal data. Essential for phishing policy as it mandates how organizations must protect personal data from unauthorized access and cyber threats.

Computer Misuse Act (CMA): Legislation that criminalizes unauthorized access to computer systems and data. Relevant for defining phishing attacks as criminal acts and establishing the legal basis for protection measures.

Cybersecurity Act 2018: Framework for the protection of Critical Information Infrastructure (CII) and cybersecurity incident reporting. Provides guidelines for cybersecurity threat management and incident response.

Spam Control Act (SCA): Legislation controlling unsolicited commercial electronic messages, relevant for addressing email-based phishing attempts and establishing electronic communication guidelines.

CSA Guidelines: Singapore's Cyber Security Agency guidelines providing best practices for cybersecurity management and protection against cyber threats including phishing.

PDPC Guidelines: Personal Data Protection Commission's detailed guidance on implementing data protection measures and handling data breaches, including those resulting from phishing attacks.

MAS Technology Risk Management Guidelines: Monetary Authority of Singapore's guidelines for financial institutions, covering cybersecurity measures including anti-phishing controls and incident response.

ISO/IEC 27001: International standard for information security management systems, providing framework for securing information assets and managing cybersecurity risks.

ISO/IEC 27032: International guidelines specifically focused on cybersecurity, including measures to prevent and detect phishing attacks.

National Cybercrime Action Plan: Singapore's national strategy for combating cybercrime, including measures against phishing and other cyber threats.

PDPC's Guide to Data Protection by Design: Guidelines for incorporating data protection considerations into the design and architecture of IT systems and business processes to prevent data breaches including those from phishing.

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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