Data Masking and Pseudonymization Policy

The Data Masking and Pseudonymization Policy (P16) articulates a comprehensive framework for safeguarding personal, confidential, and sensitive data by minimizing exposure and identifiability risks. Designed as a foundational pillar for privacy-enhancing technologies (PETs), this policy asserts the organization’s approach to implementing both static and dynamic data masking as well as pseudonymization, in accordance with stringent legal, regulatory, and operational requirements. Structured to apply to all employees, contractors, third parties, and vendors handling sensitive data, the policy’s scope extends across every data environment, whether production, development, testing, or cloud-hosted. It mandates that any data used in non-production environments must be masked or pseudonymized, prohibiting the use of real data unless explicitly sanctioned through formal risk assessment and executive approval. The policy highlights the necessity of referential integrity and format-preserving transformations, ensuring usability for analytics and reporting without compromising on privacy or compliance. This policy delineates clear responsibilities across organizational roles: executive management provides oversight and governance; the CISO and ISMS Manager ensure ongoing implementation, monitoring, and standards alignment (notably with ISO/IEC 27001 Clauses 6.1 and 8.1); while the Data Protection Officer ensures conformance with privacy laws such as GDPR. Data owners are tasked with data set identification and appropriate classification, whereas IT teams and application developers are responsible for employing approved methods and maintaining the integrity of the transformed data. Service providers and vendors are contractually bound to uphold equivalent safeguarding standards. Governance requirements encompass maintaining up-to-date data inventories, performing risk-based assessments of data transformation processes, and ensuring that all selected masking and pseudonymization techniques are aligned with regulatory expectations and operational needs. Tooling approval is strictly controlled; only vetted, standardized, and auditable tools are permitted, and their performance must be validated through technical assessment focusing on logging, integration, and resistance to circumvention. The policy enforces robust monitoring, mandating comprehensive event logging, regular audits of masking effectiveness, and the retention and review of logs in accordance with the Data Retention and Disposal Policy (P14). Risk treatment measures are clearly stipulated; if masking or pseudonymization is not feasible, compensating controls are required, and any exceptions must undergo rigorous assessment, approval, and periodic review. The policy also prescribes disciplinary and contractual remedies for violations, and requires regular training, reviews, and updates to ensure the policy evolves with technological and regulatory changes. The alignment with international frameworks, ISO/IEC 27001:2022, ISO/IEC 27002:2022, NIST SP 800-53 Rev.5, EU GDPR, NIS2, DORA, and COBIT 2019, reinforces the policy’s foundation in recognized best practices and regulatory mandates.