Data Handling Policy
Last Updated: November 1, 2024
1. Introduction
This Data Handling Policy outlines Gut Vitality's comprehensive approach to managing customer data throughout its lifecycle. Our policy particularly focuses on Amazon Information received through the Selling Partner API (SP-API) and establishes the framework for secure, compliant data handling practices.
We're committed to protecting your data and privacy.
We're dedicated to maintaining the highest standards of data security.
This policy applies to all employees, systems, and processes involved in data handling operations.
2. Data Classification
Understanding and properly classifying different types of data is crucial for applying appropriate security controls and handling procedures. We categorize data based on sensitivity and regulatory requirements.
2.1 Types of Information
Personally Identifiable Information (PII)
This category requires the highest level of protection and includes:
- Customer Names
Full names of customers are treated with strict confidentiality and access controls.
- Shipping Addresses
Physical delivery locations are encrypted and accessible only for fulfillment purposes.
- Email Addresses
Contact information is protected and used solely for order-related communication.
- Phone Numbers
Contact numbers are secured and used only for delivery-related communication.
Order Information
Transaction-related data requires moderate to high protection:
- Order Numbers
Unique identifiers used to track and manage purchases.
- Purchase History
Records of customer transactions maintained for business and support purposes.
- Transaction Details
Specific order information including products, quantities, and dates.
Business Information
Operational data requiring standard business protection:
- Product Inventory
Stock levels and product availability information.
- Sales Analytics
Aggregated sales data and performance metrics.
- Shipping Statistics
Delivery performance and fulfillment metrics.
3. Data Collection and Processing
3.1 Collection Methods
We employ secure, authenticated channels for all data collection activities. Our collection methods are designed to ensure data integrity and security from the point of capture.
- Amazon SP-API Integration
All Amazon data is collected through the official SP-API using OAuth 2.0 authentication. This secure channel ensures data authenticity and maintains compliance with Amazon's requirements.
- Encrypted Connections
All data collection occurs over HTTPS connections, utilizing TLS 1.2 or higher to protect data in transit.
- Secure Form Submissions
Web forms implement CSRF protection, input validation, and encryption to protect submitted data.
3.2 Processing Guidelines
Our data processing follows strict principles to ensure security and compliance:
- Minimum Necessary Access
Processing is limited to essential business functions, with access granted only to authorized personnel.
- Purpose-Specific Processing
Data is processed only for its intended, documented purpose, with clear boundaries on usage.
- Secure Processing Environments
All data processing occurs within secure, monitored environments with appropriate access controls.
- Audit Trail Maintenance
Comprehensive logs are maintained for all processing activities, enabling full accountability.
4. Data Storage
4.1 Storage Infrastructure
Our storage infrastructure is built on AWS, providing enterprise-grade security and reliability:
- PostgreSQL RDS
Primary data storage using encrypted PostgreSQL databases with automatic backup and failover capabilities. All data at rest is encrypted using AES-256 encryption.
- Private VPC Subnets
Databases are hosted in private subnets, inaccessible from the public internet and protected by multiple security layers.
- AWS KMS Integration
Encryption keys are managed through AWS KMS, ensuring secure key rotation and access control.
- Encrypted Backups
All database backups are automatically encrypted and stored in secure, redundant locations.
4.2 Access Controls
We implement comprehensive access controls to protect stored data:
- Role-Based Access Control (RBAC)
Access permissions are assigned based on job roles and responsibilities, ensuring minimum necessary access.
- Multi-Factor Authentication
All access to sensitive data requires MFA, adding an additional layer of security.
- Regular Access Reviews
Access permissions are reviewed quarterly to ensure appropriate access levels are maintained.
- Audit Logging
Comprehensive logs are maintained for all data access attempts, successful or failed.
5. Data Transmission
Our data transmission security ensures information integrity and confidentiality during transfer:
- TLS Encryption
All data transmissions use TLS 1.2 or higher, ensuring secure communication between systems.
- Secure Endpoints
API endpoints implement authentication, rate limiting, and monitoring to prevent unauthorized access.
- Encrypted Channels
All data streams are encrypted using industry-standard protocols and ciphers.
- Network Security
Comprehensive monitoring and intrusion detection systems protect data during transmission.
6. Data Retention and Disposal
6.1 Retention Periods
We maintain strict data retention policies aligned with business needs and regulatory requirements:
- Amazon PII
Retained for 30 days post-delivery, after which it is automatically purged from our systems.
- Transaction Records
Maintained for 7 years to comply with legal and tax requirements, with PII removed after the minimum necessary period.
- Inventory Data
Kept for 2 years to support business analytics and planning.
- Access Logs
Retained for 1 year to support security auditing and incident investigation.
6.2 Disposal Procedures
Data disposal follows secure procedures to prevent unauthorized recovery:
- Automated Deletion
PII is automatically deleted after the retention period using secure deletion methods.
- Secure Wiping
Data is securely wiped using industry-standard methods to prevent recovery.
- Backup Purging
Backup data is systematically purged following retention period expiration.
- Hardware Decommissioning
Physical media is securely wiped or destroyed following industry best practices.
7. Security Controls
7.1 Technical Controls
Our comprehensive technical security controls protect data at all levels:
- Network Security
Multilayered protection including firewalls, WAF, and intrusion detection systems.
- Encryption
Industry-standard encryption protocols protect data at rest and in transit.
- Access Management
Granular access controls and authentication mechanisms protect resources.
- Monitoring Systems
Continuous monitoring for security events and anomalies.
7.2 Administrative Controls
Administrative procedures ensure consistent security implementation:
- Security Policies
Comprehensive policies govern all aspects of data handling and security.
- Access Reviews
Regular reviews ensure appropriate access levels are maintained.
- Change Management
Controlled processes for system and security changes.
- Security Training
Regular training ensures staff awareness of security requirements.
8. Incident Response
Our incident response procedures ensure rapid and effective handling of security events:
- Immediate Actions
Procedures for immediate containment and assessment of security incidents.
- Investigation Process
Thorough investigation protocols to determine incident scope and impact.
- Amazon Notification
Immediate notification to security@amazon.com for relevant incidents.
- Customer Communication
Procedures for notifying affected customers when required.
9. Compliance and Auditing
Regular compliance activities ensure ongoing security effectiveness:
- Security Audits
Regular internal and external security assessments verify control effectiveness.
- Vulnerability Assessments
Regular scanning and testing identify potential security weaknesses.
- Policy Reviews
Periodic review and updates of security policies and procedures.
- Access Audits
Regular verification of access control effectiveness.
10. Contact Information
For any questions or concerns regarding data handling procedures, please contact:
Dr. Adam Dalton
Gut Vitality
Email: security@gut-vitality.com
We aim to respond to all security and data handling inquiries within 24 hours of receipt.