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Security Awareness and Training Policy Template

Company Name [Company Name]
Effective Date [Date]
Version [Version Number, e.g., 1.0]
Policy Owner [CISO/IT Director]
Document Classification Confidential / Internal Use Only
Parent Policy Information Security Policy

Purpose

This Security Awareness and Training Policy establishes the requirements for [Company Name]'s security awareness, education, and training program. The purpose is to ensure that all personnel understand their information security responsibilities, are aware of relevant threats and vulnerabilities, and are equipped with the knowledge and skills to protect the company's information assets. This policy aims to foster a security-conscious culture, reduce the risk of security incidents caused by human error, and ensure compliance with regulatory requirements, including PCI DSS 4.0.1.


Scope

This policy applies to all individuals who have access to [Company Name]'s information systems, networks, or data, including employees, contractors, consultants, temporary staff, and third-party service providers. It covers all aspects of security awareness and training, from initial onboarding through ongoing education and specialized role-based training.


Roles and Responsibilities

Role/Group Key Responsibilities
Executive Management - Provide strategic direction and support for the security awareness program
- Allocate necessary resources
- Demonstrate commitment to security through visible leadership
- Review program effectiveness metrics
CISO/IT Director - Develop and maintain the Security Awareness and Training Policy
- Oversee the implementation of the security awareness program
- Approve training content and delivery methods
- Report on program effectiveness to executive management
Information Security Team - Develop and maintain security awareness content
- Deliver or coordinate security training
- Track training completion and effectiveness
- Identify emerging threats requiring awareness updates
- Conduct simulated phishing and other security exercises
Human Resources - Incorporate security awareness into the onboarding process
- Maintain training records in personnel files
- Coordinate mandatory training schedules
- Support enforcement of training requirements
Department Managers - Ensure staff complete required security training
- Reinforce security awareness in day-to-day operations
- Identify department-specific training needs
- Lead by example in security practices
All Personnel - Complete all required security awareness training
- Apply security knowledge in daily activities
- Report security incidents and suspicious activities
- Provide feedback on training effectiveness
Training Coordinator - Schedule and coordinate training sessions
- Track and report on training completion
- Maintain training materials and platform
- Collect and analyze training feedback

Policy Requirements

1. Security Awareness Program Structure

  • 1.1 Program Governance:

    • Establish a formal security awareness program with defined objectives, scope, and success metrics.
    • Assign responsibility for program management to qualified personnel.
    • Review and update the program at least annually or when significant changes occur to the threat landscape or business environment.
    • Allocate sufficient resources (budget, personnel, tools) to support an effective program.
  • 1.2 Needs Assessment:

    • Conduct regular assessments to identify security awareness needs based on:
      • Current and emerging threats
      • Results of security assessments and audits
      • Incident trends and root causes
      • Compliance requirements
      • Job roles and responsibilities
    • Use assessment results to inform program content and delivery methods.
  • 1.3 Program Components:

    • Implement a comprehensive program that includes:
      • New hire security orientation
      • Annual security awareness refresher training
      • Role-based security training
      • Ongoing awareness communications
      • Simulated security exercises (e.g., phishing)
      • Security champions program
      • Measurement and improvement mechanisms

2. Security Awareness Training Requirements

  • 2.1 New Hire Security Orientation:

    • All new personnel must receive security awareness training within 30 days of hire.
    • Orientation must cover:
      • Information Security Policy and key supporting policies
      • Acceptable use requirements
      • Password and authentication requirements
      • Data protection and handling procedures
      • Physical security requirements
      • Social engineering awareness
      • Incident reporting procedures
      • Individual security responsibilities
  • 2.2 Annual Security Awareness Refresher:

    • All personnel must complete security awareness refresher training at least annually.
    • Annual training must cover:
      • Updates to security policies and procedures
      • Current and emerging threats
      • Lessons learned from recent incidents
      • Reinforcement of key security concepts
      • Compliance requirements
  • 2.3 Role-Based Security Training:

    • Personnel with specialized security responsibilities must receive role-specific training.
    • Role-based training must be provided:
      • Upon assignment to a role with security responsibilities
      • When significant changes occur to responsibilities or systems
      • At least annually as a refresher
    • Role-based training must be tailored to specific job functions, such as:
      • IT administrators and operations staff
      • Developers and application owners
      • Executive management and board members
      • Human resources personnel
      • Finance and accounting staff
      • Customer service representatives
      • Physical security personnel
  • 2.4 PCI DSS Specific Training:

    • Personnel with access to cardholder data must receive specialized training on:
      • PCI DSS requirements relevant to their job function
      • Cardholder data handling procedures
      • Incident response procedures for suspected cardholder data breaches
    • Personnel involved in e-commerce transactions must be trained on:
      • Security of online transactions
      • Fraud detection and prevention
      • Secure coding practices (for developers)

3. Ongoing Awareness Activities

  • 3.1 Security Communications:

    • Implement a regular schedule of security awareness communications using multiple channels (email, intranet, posters, newsletters, etc.).
    • Communications should:
      • Reinforce key security concepts
      • Alert personnel to current threats
      • Provide practical security tips
      • Recognize positive security behaviors
      • Remind personnel of their security responsibilities
  • 3.2 Security Exercises:

    • Conduct regular simulated security exercises, including:
      • Phishing simulations at least quarterly
      • Social engineering tests
      • Physical security tests (e.g., tailgating, unauthorized access attempts)
    • Provide immediate feedback and education for personnel who fail exercises.
    • Track exercise results to measure awareness levels and program effectiveness.
  • 3.3 Security Champions Program:

    • Establish a network of security champions across departments to:
      • Promote security awareness within their teams
      • Provide feedback on security initiatives
      • Help identify security concerns
      • Serve as local security resources
    • Provide additional training and resources to security champions.

4. Training Content and Delivery

  • 4.1 Content Requirements:

    • Training content must be:
      • Relevant to the organization's environment and threats
      • Appropriate for the target audience's technical level
      • Engaging and interactive where possible
      • Practical and applicable to daily activities
      • Current and updated regularly
      • Aligned with security policies and procedures
  • 4.2 Delivery Methods:

    • Utilize diverse delivery methods based on content and audience needs:
      • Computer-based training
      • Instructor-led sessions
      • Webinars and video presentations
      • Hands-on workshops
      • Gamification and simulations
      • Microlearning modules
    • Ensure accessibility for all personnel, including remote workers and those with disabilities.
  • 4.3 Training Materials:

    • Maintain a library of security awareness materials.
    • Review and update materials at least annually.
    • Ensure materials are branded and professional.
    • Make materials available for reference after training completion.

5. Measurement and Improvement

  • 5.1 Training Completion Tracking:

    • Maintain records of all security awareness and training activities.
    • Track completion rates for required training.
    • Implement escalation procedures for non-completion.
    • Report completion metrics to management regularly.
  • 5.2 Effectiveness Measurement:

    • Assess the effectiveness of the security awareness program through:
      • Pre and post-training assessments
      • Simulated exercise results (e.g., phishing click rates)
      • Security incident metrics related to human error
      • Feedback surveys and evaluations
      • Security behavior observations
    • Analyze trends over time to measure improvement.
  • 5.3 Continuous Improvement:

    • Review program effectiveness at least annually.
    • Adjust content, delivery methods, and frequency based on:
      • Effectiveness measurements
      • Feedback from participants
      • Changes in the threat landscape
      • Evolving business needs
      • New compliance requirements
    • Document improvements and their impact.

6. Compliance and Enforcement

  • 6.1 Mandatory Participation:

    • Completion of security awareness training is mandatory for all personnel.
    • Training completion status must be considered in performance evaluations.
    • Repeated failure to complete required training may result in disciplinary action.
  • 6.2 Documentation and Records:

    • Maintain documentation of:
      • Training materials and content
      • Training completion records
      • Assessment results
      • Program reviews and updates
    • Retain records for at least three years or as required by applicable regulations.
  • 6.3 Regulatory Compliance:

    • Ensure the security awareness program meets all applicable regulatory requirements, including:
      • PCI DSS Req 4.0.1 (Requirement Req 12.6)
      • GDPR (where applicable)
      • Industry-specific regulations
    • Document how the program satisfies specific compliance requirements.

Enforcement

  • Compliance with this Security Awareness and Training Policy is mandatory for all personnel within the scope of this policy.
  • Failure to complete required security awareness training within specified timeframes may result in:
    • Escalation to the individual's manager
    • Temporary suspension of system access
    • Notation in performance evaluations
    • Disciplinary action in accordance with HR policies
  • Exceptions to this policy must be documented, risk-assessed, approved by the CISO/IT Director, and reviewed periodically.

Revision History

Version Date Author Change Details
1.0 [Date] [Author Name] Initial policy release
[Ver #] [Date] [Author Name] [Summary of changes]

Approval

Name Title Signature Date
[Exec Name] [Executive Title, e.g., CIO] [Date]
[CISO Name] [CISO/IT Director Title] [Date]

Appendix A: Security Awareness Training Topics

A.1 Core Security Awareness Topics (All Personnel)

  • Information Security Policies and Procedures

    • Overview of key policies
    • Where to find policies
    • Consequences of non-compliance
  • Acceptable Use

    • Appropriate use of company resources
    • Email and internet usage
    • Social media guidelines
    • Personal device usage (BYOD)
  • Authentication and Access Control

    • Password creation and management
    • Multi-factor authentication
    • Screen locking and session timeout
    • Access request procedures
  • Data Protection

    • Data classification and handling
    • Sensitive information protection
    • Secure file sharing
    • Data retention and disposal
  • Email and Phishing Awareness

    • Recognizing phishing attempts
    • Handling suspicious emails
    • Safe link and attachment practices
    • Reporting procedures
  • Social Engineering

    • Common attack techniques
    • Verification procedures
    • Physical security awareness
    • Out-of-band verification
  • Mobile Device Security

    • Securing mobile devices
    • Public Wi-Fi risks
    • Lost/stolen device procedures
    • Mobile application security
  • Incident Reporting

    • What constitutes a security incident
    • How to report incidents
    • Required information for reports
    • Escalation procedures
  • Physical Security

    • Badge/access card usage
    • Visitor management
    • Clean desk policy
    • Physical document security
  • Remote Work Security

    • Securing home networks
    • VPN usage
    • Public location awareness
    • Secure video conferencing

A.2 Role-Based Training Topics (Examples)

  • IT Administrators

    • Secure system configuration
    • Patch management
    • Privileged account management
    • Security monitoring
    • Incident response procedures
  • Developers

    • Secure coding practices
    • OWASP Top 10 vulnerabilities
    • Secure API development
    • Code review techniques
    • Security testing methodologies
  • Executives and Management

    • Security governance
    • Risk management
    • Regulatory compliance
    • Security incident management
    • Security investment decisions
  • Finance and Accounting

    • Wire transfer fraud prevention
    • Invoice fraud awareness
    • Tax scam awareness
    • Financial data protection
  • Human Resources

    • Employee data protection
    • Secure hiring practices
    • Security aspects of offboarding
    • Social engineering targeting HR
  • Customer Service

    • Customer authentication procedures
    • Handling sensitive customer data
    • Social engineering targeting customer service
    • Secure communication channels

Appendix B: PCI DSS 4.0.1 Requirements Mapping

PCI DSS Requirement Policy Section(s) Covering Requirement Key Elements Addressed
Req 12.6.1 Sections 1, 2, 3, 4, 5 Formal security awareness program implemented to make all personnel aware of the importance of cardholder data security.
Req 12.6.2 Sections Req 2.1, Req 2.2, Req 3.1 Personnel receive security awareness training upon hire and at least annually.
Req 12.6.3 Sections Req 2.4, Req 4.1 Personnel receive training on awareness of threats and vulnerabilities that could impact the security of cardholder data.
Req 12.6.3.1 Sections Req 3.2, Req 5.2 Security awareness training includes awareness of phishing and related attacks.
Req 12.6.3.2 Sections Req 3.2, Req 5.2 Personnel are trained to detect and report suspected phishing attempts.
Req 12.6.4 Sections Req 5.1, Req 5.2, Req 6.2 Security awareness training completion is documented and tracked.

Appendix C: Sample Security Awareness Calendar

Month Focus Area Activities
January New Year Security Resolutions - Annual security awareness refresher training
- Security goals for the year
- Review of previous year's incidents
February Password and Authentication - Password management tips
- MFA awareness
- Credential theft prevention
March Email Security - Phishing simulation
- Email security best practices
- Attachment handling guidelines
April Physical Security - Clean desk audits
- Tailgating awareness
- Visitor management procedures
May Data Protection - Data classification refresher
- Secure file sharing practices
- Data minimization techniques
June Mobile Device Security - Mobile device security tips
- Travel security guidance
- Public Wi-Fi risks
July Social Engineering - Social engineering simulation
- Impersonation attack awareness
- Verification procedures
August Remote Work Security - Home network security
- Secure remote access
- Video conferencing security
September Incident Reporting - Incident response refresher
- Reporting procedures
- Security incident tabletop exercise
October Cybersecurity Awareness Month - Special events and activities
- Executive communications
- Security fair or webinars
November Application Security - Secure browsing practices
- Software update importance
- Approved application usage
December Holiday Security - Holiday scam awareness
- End-of-year security reminders
- Out-of-office security tips

Note: This calendar should be customized based on organizational needs, emerging threats, and specific compliance requirements.

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