botserver/docs/src/chapter-12-auth/security-policy.md

# General Bots Security Policy

## Overview

This comprehensive security policy establishes the framework for protecting General Bots systems, data, and operations. It covers information security, access control, data protection, incident response, and ongoing maintenance procedures.

## 1. Information Security Policy

### 1.1 Purpose and Scope

This Information Security Policy applies to all users, systems, and data within the General Bots infrastructure. It establishes the standards for protecting confidential information, maintaining system integrity, and ensuring business continuity.

### 1.2 Information Classification

We classify information into categories to ensure proper protection and resource allocation:

- **Unclassified**: Information that can be made public without implications for the company (e.g., marketing materials, public documentation)
- **Employee Confidential**: Personal employee data including medical records, salary information, performance reviews, and contact details
- **Company Confidential**: Business-critical information such as contracts, source code, business plans, passwords for critical IT systems, client contact records, financial accounts, and strategic plans
- **Client Confidential**: Client personally identifiable information (PII), passwords to client systems, client business plans, new product information, and market-sensitive information

### 1.3 Security Objectives

Our security framework aims to:

- Request your free IT security evaluation
• Reduce the risk of IT problems
• Plan for problems and deal with them when they happen
• Keep working if something does go wrong
• Protect company, client and employee data
• Keep valuable company information, such as plans and designs, secret
• Meet our legal obligations under the General Data Protection Regulation and other laws
• Meet our professional obligations towards our clients and customers

This IT security policy helps us achieve these objectives.

### 1.4 Roles and Responsibilities

• **Rodrigo Rodriguez** is the director with overall responsibility for IT security strategy
• **Pragmatismo Data Center** is the IT partner organisation we use to help with our planning and support
• **Pragmatismo Data Center** is the data protection officer to advise on data protection laws and best practices
• **All employees** are responsible for following security policies and reporting security incidents
• **System administrators** are responsible for implementing and maintaining security controls
• **Department heads** are responsible for ensuring their teams comply with security policies

### 1.5 Review Process

We will review this policy yearly, with the next review scheduled for [Date].
In the meantime, if you have any questions, suggestions or feedback, please contact security@pragmatismo.com.br

## 2. Access Control Policy

### 2.1 Access Management Principles

- **Least Privilege**: Users receive only the minimum access rights necessary to perform their job functions
- **Need-to-Know**: Access to confidential information is restricted to those who require it for their duties
- **Separation of Duties**: Critical functions are divided among multiple people to prevent fraud and error
- **Regular Reviews**: Access rights are reviewed quarterly to ensure they remain appropriate

### 2.2 User Account Management

**Account Creation**:
- New accounts are created only upon approval from the user's manager
- Default accounts are disabled immediately after system installation
- Each user has a unique account; shared accounts are prohibited

**Account Modification**:
- Access changes require manager approval
- Privilege escalation requires security team approval
- All changes are logged and reviewed monthly

**Account Termination**:
- Accounts are disabled within 2 hours of employment termination
- Access is revoked immediately for terminated employees
- Contractor accounts expire automatically at contract end
- All company devices and access credentials must be returned

### 2.3 Access Review Procedures

**Monthly Reviews**:
- Review privileged account usage
- Check for inactive accounts (>30 days)
- Verify administrative access justification

**Quarterly Reviews**:
- Department heads review all team member access
- Remove unnecessary permissions
- Document review results and actions taken

**Annual Reviews**:
- Comprehensive review of all user accounts
- Validate role-based access assignments
- Audit system administrator privileges

## 3. Password Policy

### 3.1 Password Requirements

**Complexity**:
- Minimum 12 characters for standard users
- Minimum 16 characters for administrative accounts
- Must include: uppercase, lowercase, numbers, and special characters
- Cannot contain username or common dictionary words

**Lifetime**:
- Standard accounts: 90-day rotation
- Administrative accounts: 60-day rotation
- Service accounts: 180-day rotation with documented exceptions

**History**:
- System remembers last 12 passwords
- Cannot reuse previous passwords

### 3.2 Password Storage and Transmission

- All passwords are hashed using Argon2id algorithm
- Passwords are never stored in plaintext
- Passwords are never transmitted via email or unencrypted channels
- Password managers are recommended for secure storage

### 3.3 Multi-Factor Authentication (MFA)

**Required For**:
- All administrative accounts
- Remote access connections
- Access to confidential data
- Financial system access

**MFA Methods**:
- Time-based One-Time Passwords (TOTP) - Preferred
- Hardware tokens (YubiKey, etc.)
- SMS codes - Only as backup method
- Biometric authentication where available

## 4. Data Protection Policy

### 4.1 Data Encryption

**Encryption at Rest**:
- Database: AES-256-GCM encryption for sensitive fields
- File storage: AES-256-GCM for all uploaded files
- Backups: Encrypted before transmission and storage
- Mobile devices: Full-disk encryption required

**Encryption in Transit**:
- TLS 1.3 for all external communications
- mTLS for service-to-service communication
- VPN required for remote access
- Certificate pinning for critical services

### 4.2 Data Retention and Disposal

**Retention Periods**:
- User data: Retained as long as account is active + 30 days
- Audit logs: 7 years
- Backups: 90 days for full backups, 30 days for incremental
- Email: 2 years unless legal hold applies

**Secure Disposal**:
- Digital data: Secure deletion with overwrite
- Physical media: Shredding or degaussing
- Certificates of destruction maintained for 3 years

### 4.3 Data Privacy and GDPR Compliance

We will only classify information which is necessary for the completion of our duties. We will also limit
access to personal data to only those that need it for processing. We classify information into different
categories so that we can ensure that it is protected properly and that we allocate security resources
appropriately:
• Unclassified. This is information that can be made public without any implications for the company,
such as information that is already in the public domain.
• Employee confidential. This includes information such as medical records, pay and so on.
• Company confidential. Such as contracts, source code, business plans, passwords for critical IT
systems, client contact records, accounts etc.
• Client confidential. This includes personally identifiable information such as name or address,
passwords to client systems, client business plans, new product information, market sensitive
information etc.


**User Rights**:
- Right to access personal data
- Right to correction of inaccurate data
- Right to deletion (right to be forgotten)
- Right to data portability
- Right to restrict processing

**Data Breach Notification**:
- Breach assessment within 24 hours
- Notification to authorities within 72 hours if required
- User notification without undue delay
- Documentation of all breaches

## 5. Incident Response Plan

### 5.1 Incident Classification

**Severity Levels**:

**Critical (P1)**:
- Active data breach with confirmed data exfiltration
- Ransomware infection affecting production systems
- Complete system outage affecting all users
- Compromise of administrative credentials

**High (P2)**:
- Suspected data breach under investigation
- Malware infection on non-critical systems
- Unauthorized access attempt detected
- Partial system outage affecting critical services

**Medium (P3)**:
- Failed security controls requiring attention
- Policy violations without immediate risk
- Minor system vulnerabilities discovered
- Isolated user account compromise

**Low (P4)**:
- Security alerts requiring investigation
- Policy clarification needed
- Security awareness issues
- Minor configuration issues

### 5.2 Incident Response Procedures

**Detection and Reporting** (0-15 minutes):
1. Security incident detected via monitoring or reported by user
2. Initial assessment to determine severity
3. Incident logged in tracking system
4. Security team notified immediately for P1/P2, within 1 hour for P3/P4

**Containment** (15 minutes - 2 hours):
1. Isolate affected systems from network
2. Disable compromised accounts
3. Preserve evidence for investigation
4. Implement temporary security controls
5. Notify management and stakeholders

**Investigation** (2-24 hours):
1. Gather logs and forensic evidence
2. Analyze attack vectors and scope
3. Identify root cause
4. Document findings
5. Determine if external authorities need notification

**Eradication** (1-3 days):
1. Remove malware and unauthorized access
2. Patch vulnerabilities
3. Reset compromised credentials
4. Apply additional security controls
5. Verify systems are clean

**Recovery** (1-5 days):
1. Restore systems from clean backups if needed
2. Gradually return systems to production
3. Enhanced monitoring for re-infection
4. Validate system functionality
5. User communication and support

**Post-Incident Review** (Within 1 week):
1. Document complete incident timeline
2. Analyze response effectiveness
3. Identify lessons learned
4. Update security controls
5. Improve detection capabilities
6. Update incident response procedures

### 5.3 Contact Information

**Internal Contacts**:
- Security Team: security@pragmatismo.com.br
- IT Support: support@pragmatismo.com.br
- Management: Rodrigo Rodriguez

**External Contacts**:
- Law Enforcement: [Local authorities]
- Legal Counsel: [Legal firm contact]
- Data Protection Authority: [DPA contact]
- Cyber Insurance: [Insurance provider]

### 5.4 Communication Plan

**Internal Communication**:
- Immediate: Security team and management
- Within 2 hours: Affected department heads
- Within 4 hours: All staff if widespread impact
- Daily updates: During active incidents

**External Communication**:
- Customers: Within 24 hours if their data affected
- Partners: Within 12 hours if systems shared
- Authorities: Within 72 hours per GDPR requirements
- Public/Media: Only through designated spokesperson

## 6. Backup and Recovery Procedures

### 6.1 Backup Schedule

**Full Backups**:
- Weekly on Sundays at 2:00 AM
- All databases, file storage, and configurations
- Retention: 12 weeks
- Stored in geographically separate location

**Incremental Backups**:
- Daily at 2:00 AM
- Changed files and database transactions only
- Retention: 30 days
- Stored locally and replicated off-site

**Continuous Backups**:
- Database transaction logs every 15 minutes
- Critical configuration changes immediately
- Retention: 7 days
- Enables point-in-time recovery

### 6.2 Backup Verification

**Automated Testing**:
- Daily: Backup completion verification
- Weekly: Sample file restoration test
- Monthly: Full database restoration test to isolated environment

**Manual Testing**:
- Quarterly: Full disaster recovery drill
- Bi-annually: Complete system restoration to alternate site
- Annually: Business continuity exercise with stakeholders

### 6.3 Recovery Procedures

**Recovery Time Objective (RTO)**:
- Critical systems: 4 hours
- Important systems: 24 hours
- Non-critical systems: 72 hours

**Recovery Point Objective (RPO)**:
- Critical data: 15 minutes
- Important data: 24 hours
- Non-critical data: 1 week

**Recovery Steps**:
1. Assess damage and determine recovery scope
2. Verify backup integrity before restoration
3. Restore to isolated environment first
4. Validate data integrity and completeness
5. Test system functionality
6. Switch users to recovered systems
7. Monitor for issues
8. Document recovery process and timing

## 7. Change Management Procedures

### 7.1 Change Categories

**Standard Changes**:
- Pre-approved routine changes
- Security patches (within 48 hours of release)
- User account modifications
- No approval needed beyond manager sign-off

**Normal Changes**:
- Non-emergency changes requiring testing
- Software updates and new features
- Infrastructure modifications
- Requires Change Advisory Board approval

**Emergency Changes**:
- Critical security patches
- System outage fixes
- Active threat mitigation
- Expedited approval from Security Director

### 7.2 Change Request Process

1. **Submission**: Complete change request form with details
2. **Risk Assessment**: Evaluate potential security impact
3. **Approval**: Get appropriate approvals based on change type
4. **Testing**: Test in non-production environment
5. **Scheduling**: Schedule during maintenance window
6. **Implementation**: Execute change with rollback plan ready
7. **Verification**: Confirm change successful
8. **Documentation**: Update configuration documentation

### 7.3 Change Testing Requirements

**Test Cases**:
- Functionality validation
- Security control verification
- Performance impact assessment
- User acceptance testing
- Rollback procedure verification

**Test Environments**:
- Development: Individual developer testing
- Staging: Integration and security testing
- Pre-production: User acceptance testing
- Production: Phased rollout with monitoring

## 8. Security Incident Procedures

### 8.1 Reporting Security Incidents

**How to Report**:
- Email: security@pragmatismo.com.br
- Phone: [Security hotline]
- Web form: [Internal incident reporting portal]
- In-person: Contact IT department

**What to Report**:
- Suspicious emails or phishing attempts
- Lost or stolen devices
- Unauthorized access or unusual system behavior
- Malware alerts
- Data leaks or exposures
- Policy violations
- Security concerns or vulnerabilities

**When to Report**:
- Immediately for critical incidents
- Within 1 hour for high-priority incidents
- Same business day for medium/low priority

### 8.2 Employee Response to Incidents

**Do**:
- Report immediately to security team
- Preserve evidence (don't delete suspicious emails)
- Disconnect device from network if compromised
- Document what happened
- Follow instructions from security team

**Don't**:
- Try to fix the problem yourself
- Delete or modify potential evidence
- Discuss incident on social media
- Blame others
- Ignore suspicious activity

## 9. Data Breach Response Procedures

### 9.1 Immediate Response (0-24 hours)

1. **Containment**: Stop ongoing breach
2. **Assessment**: Determine scope and data affected
3. **Notification**: Alert security team and management
4. **Evidence**: Preserve logs and forensic data
5. **Documentation**: Begin incident timeline

### 9.2 Investigation Phase (1-3 days)

1. **Forensics**: Detailed analysis of breach
2. **Scope Determination**: Identify all affected systems and data
3. **Root Cause**: Determine how breach occurred
4. **Impact Analysis**: Assess damage and risks
5. **Legal Review**: Consult with legal team on obligations

### 9.3 Notification Requirements

**Internal Notification**:
- Management: Immediate
- Legal: Within 2 hours
- PR/Communications: Within 4 hours
- Affected departments: Within 8 hours

**External Notification**:
- Data Protection Authorities: Within 72 hours (GDPR requirement)
- Affected individuals: Without undue delay
- Business partners: Within 24 hours if their data affected
- Law enforcement: As required by jurisdiction

### 9.4 Remediation and Prevention

1. Apply security patches and fixes
2. Reset compromised credentials
3. Enhance monitoring and detection
4. Update security controls
5. Provide additional security training
6. Review and update policies
7. Implement lessons learned

## 10. Regular Maintenance Tasks

### 10.1 Weekly Tasks

**Security Updates**:
- Review and apply critical security patches
- Update antivirus/antimalware signatures
- Review security alerts and events
- Check backup completion status
- Monitor system resource usage

**Automated Processes**:
- Vulnerability scans run automatically
- Log analysis and correlation
- Backup integrity checks
- Certificate expiration monitoring

### 10.2 Monthly Tasks

**Access Reviews**:
- Review new user accounts created
- Audit privileged account usage
- Check for inactive accounts (>30 days)
- Review failed login attempts
- Validate group membership

**System Maintenance**:
- Apply non-critical patches
- Review system performance metrics
- Update system documentation
- Test disaster recovery procedures
- Review incident reports

### 10.3 Quarterly Tasks

**Compliance Audits**:
- Review security policy compliance
- Audit access controls and permissions
- Verify encryption implementations
- Check backup and recovery processes
- Validate security configurations

**Security Assessments**:
- Internal vulnerability assessments
- Phishing simulation exercises
- Security awareness training
- Review third-party security
- Update risk assessments

### 10.4 Annual Tasks

**Penetration Testing**:
- External penetration test by certified firm
- Internal network penetration test
- Application security testing
- Social engineering assessment
- Remediation of findings within 90 days

**Disaster Recovery Testing**:
- Full disaster recovery drill
- Alternate site failover test
- Business continuity exercise
- Update recovery procedures
- Document lessons learned

**Policy and Documentation**:
- Annual policy review and updates
- Security training for all staff
- Update security documentation
- Review vendor security agreements
- Strategic security planning

### 10.5 Bi-Annual Tasks

**Disaster Recovery Testing**:
- Complete system restoration to alternate site
- Database recovery to point-in-time
- Application functionality verification
- Network failover testing
- Communication system testing

**Business Continuity**:
- Test emergency communication procedures
- Verify contact information current
- Review and update business continuity plan
- Test backup data center capabilities
- Validate recovery time objectives

## 11. Employees Joining and Leaving

We will provide training to new staff and support for existing staff to implement this policy. This includes:
• An initial introduction to IT security, covering the risks, basic security measures, company policies
and where to get help
• Each employee will complete the National Archives ‘Responsible for Information’ training course
(approximately 75 minutes)
• Training on how to use company systems and security software properly
• On request, a security health check on their computer, tablet or phone
• Access to necessary systems and resources based on job role
• Assignment of appropriate security tools (VPN, password manager, MFA device)

**Onboarding Security Checklist**:
- [ ] Background check completed (where applicable)
- [ ] Security policy acknowledgment signed
- [ ] Security training completed
- [ ] NDA and confidentiality agreements signed
- [ ] User account created with appropriate permissions
- [ ] MFA configured for all accounts
- [ ] Company devices issued and configured
- [ ] VPN access configured if needed
- [ ] Password manager account created
- [ ] Emergency contact information collected

When people leave a project or leave the company, we will promptly revoke their access privileges to all systems.

**Offboarding Security Checklist**:
- [ ] Disable all user accounts within 2 hours
- [ ] Revoke VPN and remote access
- [ ] Remove from all groups and distribution lists
- [ ] Collect company devices (laptop, phone, tokens)
- [ ] Collect access cards and keys
- [ ] Reset any shared account passwords they knew
- [ ] Remove from third-party systems (GitHub, AWS, etc.)
- [ ] Transfer ownership of documents and files
- [ ] Exit interview covering security obligations
- [ ] Documentation of access revocation completed

## 12. Data Protection Officer Responsibilities

The company will ensure the data protection officer is given all appropriate resources to carry out their
tasks and maintain their expert knowledge.
The Data Protection Officer reports directly to the highest level of management and must not carry out any other tasks that could result in a conflict of interest.

**DPO Duties**:
- Monitor compliance with GDPR and other privacy regulations
- Advise on data protection impact assessments
- Cooperate with supervisory authorities
- Act as contact point for data subjects
- Maintain records of processing activities
- Provide data protection training
- Conduct privacy audits
- Review privacy policies and procedures

## 13. Technical Documentation Requirements

### 13.1 Network Architecture Documentation

**Required Documentation**:
- Network topology diagrams (logical and physical)
- IP address allocation schemes
- Firewall rules and security zones
- VPN configurations
- DMZ architecture
- Network device inventory
- VLAN configurations
- Routing protocols and tables

**Update Frequency**: Within 48 hours of any network change

### 13.2 System Configuration Documentation

**Required Elements**:
- Server inventory with roles and specifications
- Operating system versions and patch levels
- Installed software and versions
- Service configurations
- Database schemas and configurations
- Application architecture diagrams
- API documentation
- Integration points and dependencies

**Update Frequency**: Within 24 hours of configuration changes

### 13.3 Security Controls Documentation

**Control Documentation**:
- Access control lists (ACLs)
- Security group configurations
- Intrusion detection/prevention rules
- Data loss prevention policies
- Endpoint protection configurations
- Email security settings
- Web filtering rules
- Security monitoring dashboards

**Review Frequency**: Monthly with quarterly comprehensive review

### 13.4 Encryption Standards Documentation

**Required Documentation**:
- Encryption algorithms in use (AES-256-GCM, TLS 1.3)
- Key management procedures
- Certificate inventory and renewal schedule
- Data classification and encryption requirements
- Encryption at rest implementations
- Encryption in transit configurations
- Cryptographic library versions

**Update Frequency**: Immediate upon any encryption-related change

### 13.5 Logging and Monitoring Documentation

**Logging Requirements**:
- Log sources and types collected
- Log retention periods
- Log storage locations and capacity
- Log analysis tools and procedures
- Alert thresholds and escalation
- Monitoring dashboards and reports
- SIEM configuration and rules

**Review Frequency**: Quarterly with annual comprehensive audit

## 14. Compliance Records Management

### 14.1 Risk Assessment Reports

**Risk Assessment Frequency**:
- Annual: Comprehensive organizational risk assessment
- Quarterly: Targeted assessments for new systems/services
- Ad-hoc: After significant incidents or changes

**Report Contents**:
- Identified assets and their value
- Threat identification and analysis
- Vulnerability assessment
- Risk likelihood and impact ratings
- Risk treatment plans
- Residual risk acceptance
- Review and approval signatures

**Retention**: 7 years

### 14.2 Audit Logs

**Log Types**:
- Authentication and authorization events
- Administrative actions
- Data access (read/write/delete)
- Configuration changes
- Security events and alerts
- System errors and failures
- Network traffic logs

**Retention Periods**:
- Security logs: 7 years
- System logs: 1 year
- Application logs: 90 days
- Network logs: 30 days

**Protection Requirements**:
- Read-only after creation
- Encrypted in transit and at rest
- Backed up daily
- Monitored for tampering

### 14.3 Training Records

**Training Requirements**:
- New hire security orientation (within first week)
- Annual security awareness training (all staff)
- Role-specific security training (as applicable)
- Phishing simulation exercises (quarterly)
- Incident response training (security team, annually)

**Documentation Required**:
- Training completion dates
- Training content and version
- Assessment scores if applicable
- Certificates of completion
- Refresher training schedule

**Retention**: Duration of employment + 3 years

### 14.4 Incident Reports

**Report Requirements**:
- Incident detection date and time
- Incident classification and severity
- Systems and data affected
- Timeline of events
- Response actions taken
- Root cause analysis
- Lessons learned
- Corrective actions implemented

**Distribution**:
- Internal: Management, security team, affected departments
- External: As required by regulations and contracts

**Retention**: 7 years

### 14.5 Access Review Records

**Review Documentation**:
- Date of review
- Reviewer name and title
- List of accounts reviewed
- Access changes made
- Justification for access granted
- Exceptions and approvals
- Follow-up actions required

**Review Schedule**:
- Standard users: Quarterly
- Privileged users: Monthly
- Service accounts: Bi-annually

**Retention**: 3 years

## 15. Compliance Framework

### 15.1 Applicable Regulations

**GDPR (General Data Protection Regulation)**:
- Data protection impact assessments
- Privacy by design and by default
- User consent management
- Data subject rights fulfillment
- Breach notification procedures

**SOC 2 (Service Organization Control)**:
- Security controls documentation
- Availability monitoring
- Confidentiality protection
- Privacy practices
- Annual audit compliance

**ISO 27001 (Information Security Management)**:
- Information security management system (ISMS)
- Risk assessment and treatment
- Security controls implementation
- Continuous improvement process
- Regular internal audits

### 15.2 Compliance Monitoring

**Automated Monitoring**:
- Security control effectiveness
- Policy compliance scanning
- Configuration drift detection
- Vulnerability management
- Patch compliance tracking

**Manual Reviews**:
- Quarterly compliance assessments
- Annual third-party audits
- Internal audit program
- Management review meetings
- Regulatory requirement updates

## 16. Third-Party Security

### 16.1 Vendor Security Assessment

**Pre-Contract**:
- Security questionnaire completion
- Security certification review (SOC 2, ISO 27001)
- Data processing agreement
- Security requirements in contract
- Incident notification requirements

**Ongoing Monitoring**:
- Annual security re-assessment
- Review of security incidents
- Audit report review
- Performance against SLAs
- Security scorecard maintenance

### 16.2 Data Sharing with Third Parties

**Requirements**:
- Data processing agreement in place
- Minimum necessary data shared
- Encryption for data in transit
- Access controls and monitoring
- Right to audit vendor security

**Approval Process**:
- Security team review required
- Legal review of agreements
- Privacy impact assessment
- Management approval for sensitive data
- Documentation in vendor register



## 17. Vulnerability Management

### 17.1 Vulnerability Identification

**Sources**:
- Automated vulnerability scanning (weekly)
- Penetration testing (annual)
- Security research and advisories
- Bug bounty program
- Internal security testing
- Third-party security assessments

### 17.2 Vulnerability Remediation

**Severity Levels and Response Times**:
- **Critical**: Remediate within 24 hours
- **High**: Remediate within 7 days
- **Medium**: Remediate within 30 days
- **Low**: Remediate within 90 days or accept risk

**Remediation Process**:
1. Vulnerability confirmed and documented
2. Impact and exploitability assessed
3. Remediation plan developed
4. Patch/fix tested in non-production
5. Change management process followed
6. Fix deployed to production
7. Verification testing completed
8. Documentation updated

### 17.3 Reporting a Vulnerability

**External Researchers**:
- Email: security@pragmatismo.com.br
- PGP Key: Available on website
- Response time: Initial response within 48 hours
- Bug bounty: Rewards for qualifying vulnerabilities

**Internal Staff**:
- Report via internal security portal
- Email security team for critical issues
- Include: Description, affected systems, reproduction steps
- Response time: Within 24 hours

You can expect to get an update on a reported vulnerability in a day or two.

## 18. Security Metrics and KPIs

### 18.1 Key Performance Indicators

**Security Metrics**:
- Mean time to detect (MTTD) incidents: Target <15 minutes
- Mean time to respond (MTTR) to incidents: Target <4 hours
- Percentage of systems with latest patches: Target >95%
- Failed login attempts per day: Baseline <100
- Security training completion rate: Target 100%
- Vulnerabilities remediated within SLA: Target >90%
- Backup success rate: Target 100%
- Access review completion: Target 100% on schedule

**Reporting**:
- Weekly: Security incidents and critical metrics
- Monthly: Comprehensive security dashboard
- Quarterly: Metrics trends and analysis
- Annually: Security posture assessment

## 19. Policy Enforcement

### 19.1 Policy Violations

**Types of Violations**:
- Unauthorized access attempts
- Password sharing
- Installation of unauthorized software
- Data exfiltration or leakage
- Policy non-compliance
- Failure to report incidents

**Consequences**:
- First offense: Warning and retraining
- Second offense: Written warning and management review
- Third offense: Suspension or termination
- Severe violations: Immediate termination and legal action

### 19.2 Exception Process

**Exception Request**:
- Written justification required
- Risk assessment completed
- Compensating controls identified
- Time-limited approval (max 90 days)
- Management and security team approval
- Regular review of active exceptions

## 20. Document Control

**Document Information**:
- Document Owner: Rodrigo Rodriguez, Security Director
- Last Updated: [Date]
- Next Review: [Date + 1 year]
- Version: 2.0
- Status: Approved

**Change History**:
- Version 1.0: Initial policy creation
- Version 2.0: Comprehensive expansion with detailed procedures

**Distribution**:
- All employees (via internal portal)
- Available to clients upon request
- Published on company website (summary)

**Approval**:
- Approved by: [Name, Title]
- Approval Date: [Date]
- Next Review Date: [Date + 1 year]

## Contact Information

**Security Team**:
- Email: security@pragmatismo.com.br
- Emergency Hotline: [Phone Number]
- Security Portal: [Internal URL]

**Reporting**:
- Security Incidents: security@pragmatismo.com.br
- Privacy Concerns: privacy@pragmatismo.com.br
- Compliance Questions: compliance@pragmatismo.com.br
- General IT Support: support@pragmatismo.com.br