Personal-Data Breach Notification SOP

Pre-drafted templates and workflow for notifying the UAE Data Office, the UK ICO, and affected Schools in the event of a personal-data breach.

Version: 1.1 Last updated: 1 June 2026 Owner: OMNIA Inclusion Ltd — Data Protection lead

Under stress, you fill in blanks — you do not write prose. This SOP exists so a breach response on a Friday night is a 60-minute exercise, not a 6-hour one.

Statutory deadlines

BYOK incidents. Where an incident is confined to a school's own Anthropic or Azure OpenAI tenancy (e.g. a key leak the school is investigating), the School is the controller for that incident and notifies regulators directly. OMNIA assists with the OMNIA-side audit trail (which prompts left OMNIA, when, for which pupils) but does not hold the provider-side logs. If the incident touches OMNIA-held data as well, both controller and processor notifications run in parallel under the timetable above.

Phase 1 — Detection (0–1 hour)

1. Person who detects: post in #sec-incident (Slack) and email dpo@omnia-inclusion.com.
2. DP lead opens an incident ticket with:
   • Detection time + detector name
   • Nature of suspected breach (confidentiality / integrity / availability)
   • Systems involved
   • Affected schools (tenant IDs) — preliminary
3. Engage on-call engineer to contain.

Phase 2 — Containment (1–4 hours)

1. Isolate affected systems / revoke compromised credentials.
2. Preserve logs (audit_logs, system_audit_logs, Cloudflare logs, Supabase logs).
3. Stop further data loss. Do not delete evidence.
4. Snapshot the affected database tables.

Phase 3 — Assessment (4–24 hours)

Complete the assessment grid:

Phase 4 — Notification (within 24 hours to Schools; 72 hours to regulators)

Use the templates below verbatim — fill bracketed fields only.

Template A — Notice to affected School DPO (within 24 hours)

Subject: URGENT — OMNIA personal-data incident notification — [SCHOOL NAME]

Dear [DPO name],

We are writing to notify you, in our capacity as data processor, of a personal-data incident affecting data we process on your behalf. This notification is given under [DPA clause X] and §2.3(c) of the UAE Jurisdiction Addendum.

Time of detection: [TIMESTAMP, UTC + local] Nature of incident: [Confidentiality breach / integrity breach / availability breach] Cause (preliminary): [e.g. compromised admin credential; misconfigured access rule] Data categories affected: [e.g. pupil names, DOBs, SEND diagnoses] Approximate number of data subjects affected: [N] Special-category data affected? [Yes / No — detail] Containment status: [Contained at HH:MM UTC / In progress] Data exfiltrated? [Confirmed yes / No evidence of exfiltration / Under investigation]

Likely consequences: [e.g. unauthorised disclosure of SEND status to party X; risk of distress to affected families]

Mitigation steps taken by OMNIA:

• [Step 1]
• [Step 2]
• [Step 3]

Recommended actions for the School (as controller):

• Notify the UAE Data Office within 72 hours of awareness (PDPL Art. 9). As your processor we will support this notification with the technical detail set out above.
• Consider notifying affected data subjects directly where there is a high risk to their rights and freedoms.
• [Any school-specific recommendation, e.g. force-reset staff passwords]

OMNIA point of contact for this incident: [Name], DP lead — dpo@omnia-inclusion.com — +44 [NUMBER]

We will provide written updates at least every 24 hours until the incident is closed, and a full post-incident report within 14 days.

Yours sincerely,

[Name] Data Protection Lead OMNIA Inclusion Ltd

Template B — Notice to UAE Data Office (within 72 hours)

Submitted via dataoffice.gov.ae online portal. The free-text section follows this structure.

1. Reporting entity: OMNIA Inclusion Ltd (processor) on behalf of [School name] (controller, UAE-based).
2. Time of incident: [TIMESTAMP]
3. Time of detection: [TIMESTAMP]
4. Nature of breach: [Confidentiality / integrity / availability]
5. Description of incident: [3–5 sentences, factual]
6. Categories of data affected: [List]
7. Categories of data subjects affected: [e.g. pupils, parents, staff]
8. Approximate number affected: [N]
9. Likely consequences: [Risk assessment]
10. Measures taken: [Containment + mitigation]
11. Measures proposed: [Remediation roadmap]
12. Contact: [Name, email, phone]

Template C — Notice to UK ICO (within 72 hours, if UK data subjects affected)

Submitted via ico.org.uk online form. Same structure as Template B, adjusted for UK GDPR Art. 33 fields.

Template D — Notice to affected data subjects (issued by School, drafted by OMNIA on request)

Dear [parent / guardian / staff member],

We are writing to inform you of a recent incident at [School name] involving some of your personal information. We are giving you this notice so you can take any steps you think appropriate to protect yourself.

What happened: [Plain-English description, 2–3 sentences] What information was involved: [List] When it happened: [Date] What we are doing about it: [3 bullets] What you can do: [If applicable — e.g. reset password, watch for phishing] Who to contact: [School DPO contact]

We are sorry this has happened. We have notified the UAE Data Office and are working with our technology provider, OMNIA Inclusion Ltd, to ensure this cannot happen again.

[School name]

Phase 5 — Post-incident review (within 14 days)

1. Root-cause analysis (5 whys).
2. Remediation plan with owners and dates.
3. Lessons-learned write-up shared with all Schools (sanitised).
4. Update of this SOP if any gap was identified.
5. Update of DPIA if the incident reveals a previously unidentified risk.

Drill schedule

• Tabletop exercise every 6 months.
• Restore-from-backup test every 3 months.
• Credential rotation every 90 days.