Guidance statements will appear in bold and enclosed in brackets “[]” below the statements of the policy.

Information Governance Policy

[COMPANY NAME] ____________________________________________________________________________

The purpose of this Information Governance Policy is to establish, document, approve, communicate, apply, evaluate, and maintain policies and procedures for an information governance program sponsored by the leadership of [COMPANY NAME]. This policy aims to ensure that [COMPANY NAME] complies with legal matters, industry-specific regulations, regional requirements, compliance mandates, security and privacy requirements, and information governance standards.

[This section should clearly state why this policy exists. Ensure the purpose aligns with your organization’s overall strategic goals and regulatory landscape.]

This policy applies to all employees, contractors, and third-party vendors of [COMPANY NAME] who interact with, manage, or access the company's information assets.

[Clearly define who and what this policy covers. Consider if there are any specific information assets or types of users that require special consideration or exclusion, and document them explicitly.]

Organizational Leadership: Organizational leadership is responsible for sponsoring and supporting the information governance program. They are also responsible for approving, communicating, and maintaining the policies and procedures.

[ Leadership commitment is crucial. Ensure that specific leaders or departments are identified as owning the sponsorship of this program.]

Information Governance Manager: The Information Governance Manager is responsible for coordinating and overseeing the implementation, evaluation, and ongoing maintenance of the information governance program.

[This role may be a dedicated position or assigned to an existing role (e.g., CISO, Compliance Officer, Data Privacy Officer). Clearly define where this responsibility lies within your organizational structure.]

Employees, Contractors, and Third-Party Vendors: All employees, contractors, and third-party vendors are responsible for adhering to the information governance program policies and procedures in their respective business areas.

This policy will set the guidance for assessments, audits, and metrics utilized for applicable compliance standards, regulations, and obligations. The policy is supplemented by the other [COMPANY NAME] security policies and procedures that enable the information governance of the organization.

[COMPANY NAME] will conduct independent audits and assurance assessments according to applicable and relevant standards, at least annually. These evaluations will be free from conflict of interest and undue influence in all matters related to them. [COMPANY NAME] will ensure that senior management exercises oversight over the independence of the evaluation process.

The frequency of the independent audits and assurance assessments will be in compliance with applicable standards, regulations, legal/contractual obligations, and statutory requirements. [COMPANY NAME] will:

[APPENDIX A is critical. Ensure it is regularly updated to reflect changes in laws, regulations, and contractual agreements.]

[COMPANY NAME] will develop an audit plan that considers the findings of previous assessments and schedules annual assessments to meet the requirements of the relevant standards and regulations. The audit plan will be reviewed and approved by senior management.

At a minimum, audit and assurance procedures will include:

The results of independent audit and assurance assessments will be reported to senior management and relevant stakeholders. [COMPANY NAME] will take appropriate actions to address identified deficiencies and track the progress of remediation efforts.

[COMPANY NAME] will define and implement technical and operational metrics in alignment with business objectives, security requirements, and compliance obligations. Actionable metrics will consider business goals, the criticality of service, security requirements, and compliance obligations. These metrics will be outlined in APPENDIX B.

[Metrics are essential for demonstrating the effectiveness of your information governance program. Tailor the metrics in APPENDIX B to be meaningful and actionable for your organization.]

Reporting will be designed with various users in mind, such as security professionals, engineering teams, business stakeholders, and executives. To accommodate different interests, specialized views, filtering, and delivery mechanisms, the following will be implemented:

[COMPANY NAME] will review and update this policy <FREQUENCY> to ensure that it remains relevant and effective.

[Replace with a specific period (e.g., "annually," "biannually," or "as significant changes occur"). Regular review is crucial for policy effectiveness.

APPENDIX A

Standards, Regulations, and Obligations

[This appendix is crucial for demonstrating your understanding and commitment to applicable requirements. Be specific and thorough.]

[Populate this table with all relevant international, federal, state, and local laws and regulations that apply to your organization's information assets and operations.]

[List industry-specific or generally accepted security and information governance standards your organization adheres to (e.g., ISO 27001, SOC 2, HIPAA, FedRAMP).]

[Include any specific information governance or security requirements stipulated in contracts with clients, partners, or vendors.]

APPENDIX B

Application and Interface Security Metrics

[The metrics defined here should directly support the objectives of your information governance program and be measurable.]

<DEFINE TECHNICAL METRICS>

Some example technical metrics include:

<DEFINE OPERATIONAL METRICS>

Some example operational metrics include: