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PATCH DATA PROTECTION POLICY

Last Updated: May 2025

1. Purpose

This policy outlines Patch’s commitment to safeguarding personal and sensitive data. It defines the responsibilities, procedures, and principles that guide our efforts to prevent, detect, and respond to data-related incidents with speed and transparency.

2. Scope

This policy applies to all employees, contractors, and third-party partners who have access to Patch data, systems, or infrastructure.

3. Data Protection Principles

Patch follows the following principles:

  • Lawfulness, Fairness, and Transparency
  • Purpose Limitation
  • Data Minimization
  • Accuracy
  • Storage Limitation
  • Integrity and Confidentiality
  • Accountability

4. Responsibilities

CTO & Data Privacy Team

  • The CTO leads Patch’s Data Privacy Team.
  • Responsible for enforcing data protection policies and monitoring compliance.
  • Acts as Primary Responder to any data-related incidents.
  • Coordinates all investigations, notifications, and recovery protocols.

All Employees

  • Required to follow internal data handling procedures.
  • Must report suspected breaches or mishandling immediately to the CTO or via the internal incident form.

5. Data Security Controls

Patch maintains the following technical and organizational measures:

  • Access controls 
  • Regular audits and vulnerability scans
  • Vendor risk assessments
  • Secure data backup protocols
  • Least privilege access model

6. Breach Response Protocol

In the event of a data breach, Patch will:

  1. Immediate Triage (Within 1 Hour):
    The CTO activates the Data Privacy Team. Affected systems are isolated.
  2. Containment & Investigation (Within 4 Hours):
    Preliminary scope and impact are assessed. Logs are secured. Root cause identified.
  3. Notification (Within 24 Hours or as required by law):
    • Customers and partners are notified if impacted.
    • Regulatory bodies are informed where applicable.
    • A public-facing statement is prepared if warranted.
  4. Remediation (Within 72 Hours):
    Vulnerabilities are patched, access is restored securely, and postmortem is documented.
  5. Follow-up Audit:
    Within 7 days, a full incident review is presented to executives and corrective actions are implemented.

7. Data Retention and Disposal

Data is retained only as long as necessary for business or legal purposes. Secure disposal methods (e.g., data wiping, destruction) are employed for deprecated or expired data.

8. Policy Review

This policy is reviewed annually or following any significant data incident or regulatory update.