Data Breach Notification Policy

Breach NotificationPolicy & Procedures

What happens when something goes wrong — and how we respond. This document covers Psychnex's detection-to-notification timeline, regulatory filing deadlines, severity classification system, and the procedures we follow to notify affected users.

24 hrs

NIS2 Early Warning

72 hrs

GDPR Supervisory Authority

72 hrs

CCPA Large-Scale Breach

30 days

GLBA Customer Notice

Deadlines measured from time of confirmed breach discovery

Scope & Commitment

This policy applies to all data security incidents involving Psychnex systems, services, and the personal information of Psychnex users — including Nonpublic Personal Financial Information (NPI), Personally Identifiable Information (PII), youth account data, and behavioral profile data processed by the Psychnex platform.

Psychnex is committed to transparency. We will notify affected users promptly, file all required regulatory reports within applicable deadlines, and publish a public incident summary whenever a breach results in user notification. We will not obscure, minimize, or delay notification for reputational reasons.

Incident Severity Classification

P1 — Critical

Example Incidents

Mass unauthorized access to user NPI/PII, database compromise, credential theft at scale

Response Target

15-min detection → 1-hr containment → 24-hr regulatory notice → immediate user notification

User Notification Required
Regulatory Filing Required
Third-Party Notification
P2 — High

Example Incidents

Limited unauthorized access to individual user records, single-account compromise, API key exposure

Response Target

1-hr detection → 4-hr containment → 72-hr regulatory evaluation → individual user notification

User Notification Required
No Regulatory Filing
Internal Only
P3 — Medium

Example Incidents

Attempted unauthorized access (blocked), exposed non-sensitive metadata, misconfigured public endpoint

Response Target

4-hr detection → 24-hr containment → internal review only → no user notification unless data confirmed accessed

No User Notification
No Regulatory Filing
Internal Only
P4 — Low

Example Incidents

Security configuration drift, expired certificate, failed brute-force with no access gained

Response Target

24-hr detection → 72-hr remediation → logged to POA&M → no notification required

No User Notification
No Regulatory Filing
Internal Only

Detection-to-Notification Timeline

Click any phase to expand the detailed steps. All timelines are for P1/P2 incidents.

P1 Critical — Fast Track (72-hr target)

0 minAutomated security alert fires
15 minOn-call security team notified
1 hrIncident confirmed and P1 declared
4 hrsContainment complete, sessions terminated
24 hrsNIS2 early warning filed (EU/EEA)
48 hrsUser notification emails drafted + reviewed
72 hrsGDPR supervisory authority notification filed
72 hrsUser emails sent, in-app banner live
30 daysGLBA customer notice deadline
30–60 daysPost-incident review complete

Containment Toolkit

  • Force-terminate all user sessions via Supabase Auth admin.deleteUser / signOut
  • Rotate all exposed API keys and Edge Function secrets immediately
  • Activate WAF emergency block rules for identified attack vectors
  • Enable read-only mode on affected database tables via RLS emergency policy
  • Supabase point-in-time recovery available up to 7 days (Pro plan)
  • Forensic export of audit_log before any remediation modifies state

Regulatory Notification Deadlines

CCPA / CPRA

California, USA

Expedient notice

Deadline

Expedient notice — no hard statutory deadline, but CPRA enforcement guidance implies ≤ 72 hours for large-scale breaches

Threshold

Unauthorized access to unencrypted PII of California residents

Who to Notify

California Attorney General (if 500+ residents affected); affected individuals

Method

Email + conspicuous website notice

GDPR (EU/EEA)

European Union / EEA

72 hours

Deadline

72 hours from becoming aware of the breach

Threshold

Breach likely to result in risk to rights and freedoms of natural persons

Who to Notify

Relevant Supervisory Authority (e.g., DPC for Ireland, ICO for UK); affected individuals if high risk

Method

Formal notification to supervisory authority; individual notice if high risk

NIS2 Directive

EU / EEA — essential & important entities

24-hour early warning; 72-hour full notification; 1-month final report

Deadline

24-hour early warning; 72-hour full notification; 1-month final report

Threshold

Significant cybersecurity incident affecting services

Who to Notify

National CSIRT and/or competent authority

Method

NIS2 Incident Report form (/nis2-incident-report); CSIRT portal

GLBA Safeguards Rule

USA — Financial institutions

30 days

Deadline

30 days from discovery of a notification event

Threshold

Unauthorized acquisition of unencrypted customer NPI affecting 500+ customers, or where there is reason to believe information will be misused

Who to Notify

FTC (via online portal); affected customers

Method

FTC Breach Report Portal; written notice to customers

COPPA

USA — Child data (under 13)

As expedient as possible, consistent with FTC requirements

Deadline

As expedient as possible, consistent with FTC requirements

Threshold

Any unauthorized access to personal information of children under 13

Who to Notify

FTC; affected parents / guardians; DOJ if criminal activity

Method

FTC notification; direct notice to parents via email on file

US-CERT / CISA

USA — Federal contractors / critical infrastructure

24 hours for significant cyber incidents (CIRCIA mandate)

Deadline

24 hours for significant cyber incidents (CIRCIA mandate)

Threshold

Significant cyber incident: unauthorized access to federal information systems or critical infrastructure

Who to Notify

CISA (via report.cisa.gov); FBI if criminal activity suspected

Method

CISA incident report portal; US-CERT notification system

State Breach Laws (50-State)

All US States

30–60 days (varies by state; most require "expedient" notice)

Deadline

30–60 days (varies by state; most require "expedient" notice)

Threshold

Unauthorized access to PII of state residents; scope and definitions vary by state

Who to Notify

State Attorney General (varies); affected individuals

Method

Written / email notice per state requirements; AG filing where required

Legal Note: This table reflects Psychnex's internal policy targets. Actual regulatory obligations depend on the specific facts of each incident, applicable law at the time, and legal counsel review. Nothing in this document constitutes legal advice. Psychnex retains outside counsel for breach notification compliance.

User Notification Procedure

Step 1Identify Affected Subscribers

Using audit_log and Supabase database records, generate a complete list of user IDs, email addresses, and data types affected. Deduplicate and validate email delivery addresses.

Step 2Draft Notification Content

Legal and security teams draft the breach notification following FTC plain-language guidance. Must include: what happened, what data was involved, what we are doing, what you can do, and contact information. No jargon.

Step 3Legal Review & Approval

Legal counsel reviews notification content against applicable regulatory requirements. Executive sign-off required before any subscriber notification is sent. Typically completed within 48 hours of incident confirmation.

Step 4Send Primary Email Notification

Transactional email sent directly to affected user email addresses. Subject line uses clear language: "Important Security Notice from Psychnex." Email includes direct links to change password, enable MFA, and contact support. Delivery tracked and confirmed.

Step 5In-App Banner Notification

A persistent in-app security alert banner is displayed to affected users on next login. Banner persists until the user acknowledges it. Acknowledgment is logged to audit_log. This catches users whose email notification may be filtered as spam.

Step 6Public Status Page Update

A security incident disclosure is posted to the Psychnex status page and trust.psychnex.com/incidents. Includes incident timeline, scope description, and resolution status. Updated as new information is confirmed. Remains visible for minimum 90 days.

Step 7Follow-Up & Remediation Offers

For breaches involving NPI or SSN: Psychnex arranges credit monitoring services at no cost to affected users. Dedicated support queue opened for breach-related inquiries. Follow-up email sent 30 days after initial notice with resolution summary.

What Your Notification Email Will Contain

What happened

Plain-language description of the incident — what was compromised, when, and how it was discovered.

What data was involved

Specific data types accessed (e.g., name, email, financial account data). No vague "may have been accessed" language.

What we are doing

Containment steps already taken, timeline for remediation, and any monitoring Psychnex has put in place.

What you should do

Specific steps: change your password, enable MFA, monitor your accounts, freeze credit if NPI was exposed.

How to contact us

Direct link to dedicated breach support queue, email address, and phone number for affected users only.

Credit monitoring offer

If NPI or financial identifiers were exposed: free credit monitoring enrollment instructions included directly in the email.

Report an Incident

Security Incident

security@psychnex.com

For active breaches, suspicious account activity, or data exposure. 24-hour response SLA.

Report Now

EU NIS2 Incident

NIS2 Incident Report Form

For EU/EEA entities with a significant cybersecurity incident. 24-hour early warning required.

Submit NIS2 Report

Vulnerability Disclosure

security@psychnex.com

Found a security vulnerability? Responsible disclosure program active. 90-day embargo honored.

Disclosure Guidelines

Security Questions?

If you believe your account may have been compromised, or if you have questions about a security notification you received from Psychnex, contact our security team immediately.

Privacy & Consent

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