Test Data and Test Environment Policy

The Test Data and Test Environment Policy (P29) sets forth comprehensive requirements for the secure, compliant management of test data and non-production environments throughout the software development and testing lifecycle. Its primary purpose is to protect the confidentiality, integrity, and operational security of both test data and environments, preventing unauthorized access, data leakage, and the risk of contaminating production systems due to improperly managed testing activities. This policy holds a broad scope, applying to all environments, data, tools, and processes used in any kind of testing, be it functional, regression, performance, or security, and whether performed on-premises, in the cloud, or via third-party platforms. All personnel involved, including internal users, contractors, or vendors, are subject to its stipulations. Explicit controls prohibit the use of live, sensitive, or regulated personal data (such as PII or cardholder information) unless anonymized, pseudonymized, or specifically approved by the Chief Information Security Officer (CISO) with clear justification and compensating controls in place. In addition, network and access segregation between test and production systems is mandatory, enforced through separate authentication, network partitioning, and restricted firewall policies. Encryption, synthetic data generation, or robust data masking are required whenever realistic test data is needed. Rigorous role-based access controls (RBAC) govern entry to all test environments. Access must be logged, auditable, and subject to quarterly review, with immediate revocation after project completion. Environments must adhere to secure build baselines, including hardened operating systems, regularly updated software, endpoint protection, and drastic restrictions on remote administration. Automated monitoring and event logging are crucial to detect policy violations, such as access from unauthorized IP ranges or unapproved credential usage. Backup practices must align with the Backup and Restore Policy (P15), ensuring the retention of test data is minimized and properly segregated from production cycles. Exception management is handled strictly: requests for deviations require business justification, indication of risk mitigation controls, and explicit approval by the CISO and, if relevant, the Data Protection Officer and Legal Counsel. Each granted exception is logged, periodically revalidated, and subject to heightened monitoring and stricter controls. Regular reviews and audits by the Information Security Team, with input from QA, DevOps, and other stakeholders, ensure persistent compliance, with defined triggers for interim policy assessment after significant incidents or regulatory changes. Tightly integrated with related organizational policies, including Change Management (P5), Data Classification (P13), Data Retention (P14), Cryptographic Controls (P18), Logging and Monitoring (P22), and Incident Response (P30), this policy also aligns with leading standards and regulations. These include ISO/IEC 27001:2022, requirements for secure test environments and data (ISO/IEC 27002 Controls 8.28-8.29), NIST SP 800-53 (SA-11, SC-28, SC-32), EU GDPR (Articles 5, 25, 32), EU NIS2, EU DORA, and COBIT 2019. Violations can result in disciplinary action, contract termination, or regulatory reporting, emphasizing the policy’s criticality for security and compliance.