Test Data and Test Environment Policy - SME

P29S – Test Data and Test Environment Policy is a comprehensive policy designed to address the secure management of test data and the proper separation of test environments, particularly for small and medium-sized enterprises (SMEs). This policy is crafted to ensure the organization consistently prevents accidental data exposure, operational disruption, and compliance failures during testing activities. Uniquely, the policy takes into account SME realities by assigning overall responsibility to the General Manager (GM) instead of specialized IT functions such as SOC or CISO, making it both practical and enforceable where resources are limited. The policy applies organization-wide: all personnel involved in software and system testing, including employees, freelancers, contractors, vendors, and IT providers, are subject to its stipulations. Covered contexts include manual and automated functional or security tests, system upgrades, website and app development, and integration testing activities. The central pillars are absolute prohibition of real, identifiable customer data in test environments unless anonymized and GM-approved; enforced logical and technical separation of test and production systems; and stringent measures to protect test data from unauthorized or accidental access, re-use, or disclosure. Management roles are clearly delineated. The General Manager authorizes all exceptions including the use of real data in testing and ensures thorough documentation and compliance. Project Owners coordinate process design and validation, ensuring team understanding and incident response, while Developers/IT Providers implement, maintain, and isolate test environments, oversee test data creation, and reinforce system controls. Governance requirements prohibit the use of any personal data in tests unless anonymized and explicitly approved, and only after documented risk assessment, while enforcing retention, storage, and secure deletion best practices for all test data. Access management is a prominent feature of the policy: access is strictly limited, must be removed once testing concludes, and credentials unique to test environments must not be reused elsewhere. Secure logging and review obligations further reduce the risk of privacy or security breaches from captured information during testing. The policy details mandatory audit trails, annual reviews, retention of exceptions and approvals, and compliance checks, all overseen by the GM, to support both internal and external audit readiness. Incident reporting flows are ingrained, requiring immediate escalation and response in the face of any detected compromise or exposure. Additionally, P29S is explicitly aligned with the latest versions of ISO/IEC 27001:2022 and ISO/IEC 27002:2022, relevant GDPR articles, NIST SP 800-53 Rev. 5, EU NIS2, EU DORA, and COBIT 2019. The policy also cross-references and depends on other key SME policies including Governance, Access Control, Security Awareness, Data Classification, Data Protection, Secure Development, and Incident Response to provide a holistic security and compliance framework. This document is essential for SMEs seeking to maintain robust testing safeguards, streamline audits, and ensure regulatory adherence without complex IT roles.