SafeClass Shield Data Security Policy

Document Version: 1.0
Effective Date: January 1, 2026
Last Reviewed: January 1, 2026
Classification: Public

1. POLICY OVERVIEW

1.1 Purpose

This Data Security Policy establishes the framework for protecting the confidentiality, integrity, and availability of all data processed, stored, or transmitted by SafeClass Shield, Inc. ("Company," "we," or "us"). This Policy is designed to:

• Protect Student Data and Personally Identifiable Information (PII) from unauthorized access, use, disclosure, or destruction
• Comply with federal and state regulations, including FERPA, COPPA, PPRA, and state student data privacy laws
• Meet contractual obligations to educational institutions and parents
• Maintain industry-standard security practices and certifications
• Establish clear roles and responsibilities for data protection

1.2 Scope

This Policy applies to:

• All employees, contractors, and third-party service providers with access to Company systems or data
• All data collected, processed, stored, or transmitted by the SafeClass Shield platform
• All information systems, networks, devices, and facilities operated by or on behalf of the Company
• All business processes involving data handling, from collection through disposal

1.3 Policy Governance

Data Protection Officer (DPO): Sarah Mitchell
Chief Information Security Officer (CISO): [Name]
Policy Owner: Information Security Department
Review Cycle: Annual (or as required by regulatory changes)

2. DATA CLASSIFICATION AND HANDLING

2.1 Data Classification Levels

Level 1: Public

• Publicly available information
• Marketing materials and website content
• No confidentiality requirements
• Examples: Product brochures, press releases, public documentation

Level 2: Internal

• Information intended for internal use only
• Limited business impact if disclosed
• Basic access controls required
• Examples: Internal memos, operational procedures, non-sensitive analytics

Level 3: Confidential

• Proprietary business information
• Moderate harm if disclosed
• Strong access controls and encryption required
• Examples: Business strategies, vendor contracts, employee records

Level 4: Restricted (Student Data)

• Student Data, PII, and Educational Records
• Severe harm if disclosed (legal, reputational, financial)
• Strictest security controls and encryption required
• Audit logging and monitoring mandatory
• Examples: Student device activity, academic records, parent-child communications, authentication credentials

2.2 Data Handling Requirements by Classification

3. ACCESS CONTROL AND AUTHENTICATION

3.1 Identity and Access Management (IAM)

Principle of Least Privilege:

• Users are granted only the minimum access necessary to perform their job functions
• Access rights are reviewed quarterly and revoked immediately upon role change or termination
• Privileged access (admin, root) requires separate accounts and justification

Role-Based Access Control (RBAC):

• Access permissions are assigned based on predefined roles
• Standard roles: Parent, Teacher, School Admin, Master Admin, System Admin, Support Agent
• Custom roles can be defined for institutional customers

Account Provisioning:

• New accounts require manager approval and security training completion
• Default deny: new accounts have no access until explicitly granted
• Onboarding checklist includes background check verification for employees with Student Data access

Account Deprovisioning:

• Access is revoked within 4 hours of termination notice
• Accounts are disabled (not deleted) for 90 days for audit purposes
• All data access is logged and retained per retention policy

3.2 Authentication Requirements

User Authentication:

• Minimum password requirements: 8 characters, complexity rules enforced
• Passwords hashed using bcrypt (cost factor 12) with per-user salts
• Password reset requires email verification and security questions
• Account lockout after 5 failed login attempts (15-minute lockout period)
• Session timeout: 30 minutes of inactivity for web, 24 hours for mobile

Multi-Factor Authentication (MFA):

• Required for:
  • All administrative accounts
  • School Official and Master Admin accounts
  • Remote access to production systems
  • Access to Student Data repositories
• Supported methods: authenticator apps (TOTP), SMS (backup only), hardware tokens
• MFA bypass requires CISO approval and audit trail

System-to-System Authentication:

• API keys rotated every 90 days
• OAuth 2.0 for third-party integrations (Google Classroom)
• JWT tokens with short expiration (1 hour) and refresh token rotation
• TLS client certificates for inter-service communication

3.3 Network Security

Network Segmentation:

• Production, staging, and development environments are isolated
• Database servers are not directly accessible from the internet
• DMZ architecture separates public-facing services from internal systems

Firewall Rules:

• Default deny all inbound traffic
• Allow only explicitly approved ports and protocols
• Quarterly firewall rule review and cleanup

Intrusion Detection and Prevention:

• Network IDS/IPS monitors all traffic for suspicious patterns
• Web Application Firewall (WAF) protects against OWASP Top 10 vulnerabilities
• Real-time alerting for critical security events
• Automated blocking of identified threats

VPN and Remote Access:

• VPN required for all remote access to corporate systems
• Split-tunnel VPN configuration prevents data leakage
• MFA required for VPN authentication
• Remote access logs reviewed weekly

4. DATA ENCRYPTION

4.1 Encryption at Rest

Database Encryption:

• MongoDB Encrypted Storage Engine with AES-256-CBC
• Encryption keys managed via AWS Key Management Service (KMS)
• Master keys rotated annually
• Per-field encryption for highly sensitive data (e.g., chat messages, OAuth tokens)

File Storage Encryption:

• Amazon S3 server-side encryption (SSE-S3) for all object storage
• AES-256 encryption with AWS-managed keys
• Versioning enabled with encrypted backups

Disk Encryption:

• Full-disk encryption on all servers and workstations
• BitLocker (Windows) or LUKS (Linux) with TPM 2.0
• Encryption keys stored in hardware security modules (HSMs)

Backup Encryption:

• All backups encrypted before transmission to offsite storage
• Separate encryption keys for backups (independent of production keys)
• Encrypted backup integrity verified weekly

4.2 Encryption in Transit

TLS/SSL Standards:

• TLS 1.3 required for all HTTPS connections (TLS 1.2 minimum)
• Perfect Forward Secrecy (PFS) enabled
• Strong cipher suites only (ECDHE-RSA-AES256-GCM-SHA384 or better)
• HSTS enforced with 1-year max-age and includeSubDomains

Certificate Management:

• SSL/TLS certificates from trusted Certificate Authorities
• Certificate expiration monitored with 30-day renewal alerts
• Automatic certificate renewal via Let's Encrypt where applicable
• Certificate pinning for mobile applications

Internal Communication:

• TLS 1.3 for inter-service communication
• Mutual TLS (mTLS) for microservice authentication
• VPN tunnels for cross-datacenter replication

4.3 End-to-End Encryption

Parent-Child Chat:

• Messages encrypted on sender's device before transmission
• Decrypted only on recipient's device
• Signal Protocol (Double Ratchet Algorithm) implementation
• Server cannot decrypt message content

Key Management:

• Asymmetric encryption (RSA-2048) for key exchange
• Symmetric encryption (AES-256-GCM) for message content
• Key rotation every 30 days or 1000 messages
• Device-specific keys (lost device = lost message history)

5. DATA STORAGE AND INFRASTRUCTURE

5.1 Infrastructure Overview

Cloud Service Provider: Amazon Web Services (AWS)

Compliance Certifications:

• SOC 2 Type II (annual audit)
• ISO 27001:2013 Information Security Management
• ISO 27017:2015 Cloud Security
• ISO 27018:2019 Personal Data Protection
• PCI DSS Level 1 (for payment processing)
• FedRAMP Authorized (Moderate Impact Level)
• HIPAA HITECH compliant infrastructure

Data Center Locations:

• Primary: AWS US-East-1 (Northern Virginia)
• Secondary/DR: AWS US-West-2 (Oregon)
• Geographic replication within US regions only

Physical Security:

• 24/7 security personnel and video surveillance
• Biometric access controls (fingerprint + badge)
• Man-trap entries with multi-factor authentication
• Climate control and fire suppression systems
• Redundant power (UPS + diesel generators)
• Seismically braced equipment racks

5.2 Database Architecture

Production Database:

• MongoDB Atlas M50 cluster (3 nodes, replica set)
• Automated failover and self-healing
• Point-in-time recovery (PITR) enabled
• Continuous backups with 35-day retention

Database Security:

• Network isolation (private VPC)
• IP whitelisting (application servers only)
• TLS 1.3 for all connections
• Database authentication with SCRAM-SHA-256
• Read-only replicas for reporting queries
• Query auditing enabled

Redis Cache:

• Amazon ElastiCache (Redis 7.x)
• In-transit encryption (TLS)
• At-rest encryption enabled
• Automatic failover to read replica
• Data expiration policies (max 24-hour TTL)

5.3 Backup and Disaster Recovery

Backup Strategy:

• Full backups: Daily at 2:00 AM ET
• Incremental backups: Every 6 hours
• Transaction log backups: Every 15 minutes
• Retention: 35 days for full backups, 7 days for incremental

Backup Testing:

• Monthly restore tests to staging environment
• Quarterly full disaster recovery exercises
• Recovery Time Objective (RTO): 4 hours
• Recovery Point Objective (RPO): 15 minutes

Disaster Recovery Plan:

• Automated failover to secondary AWS region
• Geographically distributed backups (US-East-1 → US-West-2)
• Runbook documentation for all DR scenarios
• Annual tabletop exercises with stakeholders

Business Continuity:

• 99.9% uptime SLA (< 8.77 hours downtime per year)
• Redundant infrastructure across multiple Availability Zones
• Auto-scaling based on load (CPU, memory, network)
• DDoS protection via AWS Shield Advanced

6. SECURITY MONITORING AND INCIDENT RESPONSE

6.1 Security Monitoring

Security Information and Event Management (SIEM):

• Real-time log aggregation from all systems
• Automated correlation of security events
• Threat intelligence integration
• Retention: 1 year online, 7 years archived

Monitoring Scope:

• Authentication attempts (successful and failed)
• Data access and modifications
• Privilege escalation attempts
• Network traffic anomalies
• System resource utilization
• Application errors and crashes

Alerting:

• Critical alerts: Immediate notification (PagerDuty, SMS)
• High priority: 15-minute notification
• Medium priority: 1-hour notification
• Low priority: Daily digest email

Security Metrics:

• Mean Time to Detect (MTTD): Target < 5 minutes
• Mean Time to Respond (MTTR): Target < 30 minutes
• Mean Time to Remediate: Target < 4 hours

6.2 Vulnerability Management

Vulnerability Scanning:

• Automated weekly scans of all systems
• Authenticated scans with credentialed access
• OWASP Top 10 testing for web applications
• Third-party penetration testing annually

Patch Management:

• Critical patches: Applied within 7 days
• High severity: Applied within 15 days
• Medium/Low severity: Applied within 30 days
• Emergency patches: Applied within 24 hours

Software Composition Analysis (SCA):

• Automated scanning of dependencies for known vulnerabilities
• Open-source license compliance monitoring
• Alerts for new CVEs affecting our software stack

6.3 Incident Response

Incident Classification:

• P1 (Critical): Active data breach, complete service outage, ransom ware
• P2 (High): Suspected breach, PII exposure, partial service degradation
• P3 (Medium): Policy violation, single-user impact, degraded performance
• P4 (Low): Minor security event, informational only

Incident Response Team (IRT):

• Incident Commander (CISO)
• Security Engineer (Technical Lead)
• Legal Counsel
• Communications Lead (PR/Customer notification)
• Data Protection Officer
• Executive Sponsor (CEO or COO)

Incident Response Process:

1. Detection and Analysis (0-30 minutes)

   • Identify and classify incident
   • Assemble IRT
   • Begin evidence collection

2. Containment (30 minutes - 2 hours)

   • Isolate affected systems
   • Stop ongoing data exfiltration
   • Prevent lateral movement

3. Eradication (2-24 hours)

   • Remove malware/unauthorized access
   • Patch vulnerabilities
   • Reset compromised credentials

4. Recovery (1-7 days)

   • Restore systems from clean backups
   • Gradually resume normal operations
   • Enhanced monitoring for recurrence

5. Post-Incident Activities (7-30 days)

   • Root cause analysis
   • Lessons learned document
   • Update policies and procedures
   • Implement preventive measures

Notification Requirements:

• Parents/Schools: Within 72 hours of confirmed breach
• Regulatory authorities: Per state breach notification laws
• Law enforcement: If criminal activity is suspected
• Media: If breach affects > 500 individuals (HIPAA standard applied)

7. DATA BREACH RESPONSE PLAN

7.1 Breach Definition

A data breach is any unauthorized access, use, disclosure, modification, or destruction of Student Data or PII, including:

• Unauthorized access to database or systems
• Theft or loss of unencrypted devices containing PII
• Phishing or social engineering attacks resulting in credential compromise
• Ransomware or malware infections affecting data systems
• Insider threats or malicious employee actions
• Third-party vendor security failures affecting our data

7.2 Breach Response Timeline

Hour 0-1: Initial Detection

• Security monitoring detects anomaly
• Incident declared and IRT activated
• Begin evidence preservation

Hour 1-4: Containment

• Isolate affected systems
• Identify scope of compromise
• Stop ongoing data exfiltration
• Preserve logs and forensic evidence

Hour 4-24: Assessment

• Determine what data was accessed/exfiltrated
• Identify affected individuals
• Assess risk of harm to students/parents
• Engage third-party forensic investigators (if needed)

Hour 24-48: Investigation

• Root cause analysis
• Review access logs and network traffic
• Interview relevant personnel
• Determine if breach is ongoing or contained

Hour 48-72: Notification Preparation

• Draft notification letters for affected parties
• Prepare FAQ and support resources
• Coordinate with legal counsel and PR team
• Set up dedicated support hotline

Hour 72-96: Notification

• Notify affected parents and schools via email and postal mail
• Post breach notice on website
• Report to state attorneys general (if required by state law)
• Notify US Department of Education (if FERPA violation)
• Issue press release (if widespread impact)

Day 5-30: Remediation

• Implement security improvements
• Offer credit monitoring/identity theft protection (if appropriate)
• Conduct post-incident review
• Update incident response plan

7.3 Breach Notification Content

All breach notifications will include:

• Date of breach and date of discovery
• Description of what happened
• Types of information involved (e.g., names, device activity, passwords)
• Steps we have taken to investigate and remediate
• Actions individuals can take to protect themselves
• Contact information for questions and support
• Offer of free credit monitoring (if SSNs or financial data exposed)

7.4 Breach Cost Mitigation

Cyber Insurance:

• $5 million cyber liability coverage
• Includes breach response costs, legal fees, regulatory fines
• Forensic investigation and notification costs covered
• Business interruption coverage

Breach Response Retainer:

• Pre-negotiated contracts with forensic investigators
• Legal counsel specializing in data breaches
• PR firm for crisis communications
• Identity theft protection services (for offering to affected individuals)

8. VENDOR AND THIRD-PARTY SECURITY

8.1 Vendor Risk Management

Vendor Security Assessment: All vendors with access to Student Data or Company systems must complete:

• Security questionnaire (based on SDPC model, see Section 8.3)
• Proof of SOC 2 Type II or ISO 27001 certification
• Insurance verification (cyber liability and E&O)
• Data Processing Agreement (DPA) or Business Associate Agreement (BAA)

Vendor Categories:

• Critical: Direct access to Student Data (requires annual audit)
• High: Access to internal systems or confidential data (annual questionnaire)
• Medium: Limited access or non-sensitive data (biennial review)
• Low: No access to systems or data (standard terms acceptable)

Ongoing Monitoring:

• Quarterly vendor risk reviews for critical vendors
• Annual re-certification of security controls
• Immediate notification required for vendor security incidents
• Right to audit vendor security practices

8.2 Data Processing Agreements (DPAs)

All vendors processing Student Data must execute a DPA that includes:

• Purpose Limitation: Use data only for agreed-upon services
• Confidentiality: Maintain confidentiality of all Student Data
• Security Measures: Implement reasonable technical and administrative safeguards
• Subprocessors: Obtain written consent before engaging subprocessors
• Data Subject Rights: Assist in responding to parent/student rights requests
• Breach Notification: Notify us within 24 hours of any security incident
• Data Return/Deletion: Return or destroy data upon contract termination
• Audit Rights: Allow us to audit security controls
• Indemnification: Indemnify us for vendor-caused breaches
• Liability: Agree to liability limits and insurance requirements

8.3 Student Data Privacy Consortium (SDPC) Vendor Questionnaire

SafeClass Shield completes the standard SDPC questionnaire for all educational institution customers. Our responses are publicly available at: https://safeclassshield.com/sdpc-questionnaire

Key SDPC Topics Addressed:

1. Data Inventory: What Student Data is collected and how it is used
2. Data Sharing: Third parties with whom data is shared
3. Data Security: Technical and administrative safeguards
4. Data Retention: How long data is kept and deletion procedures
5. Breach Response: Incident response and notification procedures
6. FERPA/COPPA Compliance: How we comply with federal privacy laws
7. State Law Compliance: State-specific student data privacy laws
8. Certifications: Security certifications and audit reports

SDPC Attestation: We attest that our responses are accurate and we will notify customers of any material changes within 30 days.

9. EMPLOYEE SECURITY TRAINING

9.1 Security Awareness Training

New Employee Onboarding:

• Security awareness training within first week
• FERPA and COPPA training for employees with Student Data access
• Phishing simulation and password hygiene
• Acceptable use policy acknowledgment
• Confidentiality agreement signature required

Annual Training:

• Refresher training for all employees (annually)
• Role-specific training (e.g., developers, support agents)
• Emerging threat briefings (quarterly)
• Incident response tabletop exercises (annually)

Training Topics:

• Data classification and handling
• Password security and MFA
• Phishing and social engineering recognition
• Physical security and clean desk policy
• Acceptable use of company resources
• Incident reporting procedures
• FERPA, COPPA, and state privacy laws

9.2 Background Checks

All employees and contractors with access to Student Data undergo:

• Criminal background check (7-year lookback)
• Identity verification
• Education verification (for technical roles)
• Previous employment verification
• Reference checks

Background checks are repeated every 3 years for employees with ongoing Student Data access.

10. COMPLIANCE AND AUDITING

10.1 Compliance Framework

SafeClass Shield maintains compliance with:

• FERPA (20 U.S.C. § 1232g) - Family Educational Rights and Privacy Act
• COPPA (15 U.S.C. §§ 6501-6506) - Children's Online Privacy Protection Act
• PPRA (20 U.S.C. § 1232h) - Protection of Pupil Rights Amendment
• CCPA/CPRA - California Consumer Privacy Act and Privacy Rights Act
• State Student Data Privacy Laws (CA AB 1584, NY Ed Law § 2-d, IL SOPPA, etc.)
• SOC 2 Type II - Trust Services Criteria for security, availability, confidentiality
• ISO 27001:2013 - Information Security Management System

10.2 Internal Auditing

Security Audits:

• Quarterly: Access control reviews, privilege escalation checks
• Semi-Annual: Vulnerability scans, penetration testing
• Annual: Comprehensive security audit by internal audit team

Compliance Audits:

• Quarterly: FERPA and COPPA compliance checks
• Annual: SOC 2 Type II audit by independent CPA firm
• Biennial: ISO 27001 surveillance audit

Findings Remediation:

• Critical findings: Remediated within 7 days
• High findings: Remediated within 30 days
• Medium findings: Remediated within 90 days
• Low findings: Addressed in next release cycle

10.3 External Auditing

Independent Assessments:

• SOC 2 Type II audit annually (CPA firm)
• ISO 27001 certification audit every 3 years
• Penetration testing by third-party firm annually

Audit Reports:

• SOC 2 report available to institutional customers under NDA
• ISO 27001 certificate publicly available
• Penetration test summary available upon request

11. DATA PRIVACY IMPACT ASSESSMENTS (DPIA)

11.1 When DPIA is Required

A Data Privacy Impact Assessment is required before:

• Implementing new technology that processes Student Data
• Significant changes to existing data processing activities
• Launching new products or features
• Entering new geographic markets
• Engaging new third-party vendors with Student Data access

11.2 DPIA Process

1. Identify Need: Determine if DPIA is required based on risk assessment
2. Describe Processing: Document what data is collected, why, and how
3. Assess Necessity: Justify necessity and proportionality of data processing
4. Identify Risks: Analyze privacy and security risks to students
5. Mitigation Measures: Identify controls to reduce risks
6. DPO Review: Data Protection Officer reviews and approves
7. Ongoing Monitoring: Re-assess annually or when changes occur

12. ACCEPTABLE USE POLICY

12.1 Employee Responsibilities

Employees must:

• Use strong, unique passwords for all accounts
• Enable MFA on all accounts that support it
• Lock computers when stepping away from desk
• Report suspected security incidents immediately
• Complete all required security training
• Handle data in accordance with classification policies
• Not share credentials or access with others
• Not use personal devices for work unless approved (BYOD policy)

12.2 Prohibited Activities

Employees must NOT:

• Access Student Data without business need or authorization
• Share Student Data outside approved systems
• Download Student Data to personal devices
• Use unauthorized cloud storage (Dropbox, Google Drive personal)
• Install unapproved software on company devices
• Disable security software or controls
• Engage in hacking, cracking, or penetration testing without authorization
• Access competitors' systems or data

12.3 Consequences of Violations

Violations of security policies may result in:

• Written warning and retraining
• Suspension of access privileges
• Termination of employment
• Legal action and law enforcement referral (for criminal violations)
• Personal liability for damages resulting from negligence

13. PHYSICAL SECURITY

13.1 Office Security

Access Control:

• Badge access required for all offices
• Visitor sign-in and escort policy
• Access logs reviewed monthly

Clean Desk Policy:

• No Student Data left on desks overnight
• Confidential documents locked in cabinets when not in use
• Whiteboards cleaned after meetings

Device Security:

• All laptops have cable locks
• Laptops encrypted and password-protected
• Automatic screen lock after 5 minutes inactivity

13.2 Data Center Security

(Provided by AWS - see Section 5.1 for details)

• 24/7 security guards and video surveillance
• Biometric access controls
• Mantrap entries
• Equipment destruction procedures for decommissioned hardware

14. SECURE DEVELOPMENT LIFECYCLE (SDL)

14.1 Security in Design

• Threat modeling for new features
• Privacy by design principles
• Data minimization (collect only necessary data)
• Secure defaults (opt-in rather than opt-out)

14.2 Secure Coding Practices

• OWASP Top 10 awareness training for developers
• Code review required for all changes
• Static application security testing (SAST)
• Dynamic application security testing (DAST)
• Dependency scanning for vulnerable libraries

14.3 Deployment Security

• Staging environment testing before production
• Automated security tests in CI/CD pipeline
• Blue-green deployments for zero-downtime releases
• Rollback procedures for failed deployments
• Change management approval for production changes

15. POLICY REVIEW AND UPDATES

15.1 Review Schedule

This Data Security Policy is reviewed:

• Annually (scheduled review)
• After security incidents or breaches
• When regulations or standards change
• When technology or infrastructure changes

15.2 Approval and Distribution

Approved By:

• Chief Information Security Officer (CISO)
• Data Protection Officer (DPO)
• Chief Executive Officer (CEO)
• Board of Directors (for material changes)

Distribution:

• All employees (via email and employee handbook)
• Third-party vendors (as part of DPA)
• Educational institution customers (upon request)
• Posted on public website for transparency

16. CONTACT INFORMATION

Data Security Inquiries:
Email: security@safeclassshield.com
Phone: 1-800-SAFEKID, Option 3

Security Incident Reporting:
Email: incident@safeclassshield.com
Phone: 1-800-SAFEKID, Option 9 (24/7 hotline)

Data Protection Officer:
Email: dpo@safeclassshield.com
Phone: 1-800-SAFEKID, Option 4

Document Control:
Policy Number: SEC-001
Version: 1.0
Effective Date: January 1, 2026
Next Review Date: January 1, 2027
Classification: Public

Acknowledgment:
This policy has been reviewed and approved by legal counsel specializing in education technology and cybersecurity. It meets or exceeds industry standards for K-12 EdTech security.

SafeClass Shield, Inc.
Protecting Student Data with Enterprise-Grade Security