Risk Management Policy (SEC-POL-003)

1. Objective

This policy establishes a comprehensive systematic approach to identifying, assessing, treating, and monitoring information security risks that could impact [Company Name]’s video streaming platform, user data, business operations, and regulatory compliance obligations. The policy ensures robust risk management processes that support business continuity and regulatory compliance across all operational environments.

2. Scope

This policy applies comprehensively to all business units, employees, contractors, and third parties involved in the operation of the video streaming platform across all operational environments. The scope encompasses all risks related to information security, data protection, platform operations, content management, and regulatory compliance across all geographic regions where [Company Name] operates its services.

3. Policy

3.1 Risk Management Framework

  • The Company must maintain a comprehensive risk management framework that aligns with business objectives and regulatory requirements.
  • A systematic and structured approach must be followed for risk identification and assessment across all operations.
  • Risk management must be integrated with business continuity and incident response planning processes.
  • Informed decision-making must be supported regarding risk treatment options and resource allocation.
  • Continuous monitoring and review must be conducted of the evolving risk landscape and threat environment.

3.2 Risk Identification

Risk identification activities must encompass all potential threats to the video streaming platform, including but not limited to:

Traditional Information Security Risks:

  • Data breaches and unauthorized access to user information
  • System vulnerabilities and software security flaws
  • Insider threats and privilege abuse
  • Third-party vendor security failures
  • Ransomware and malware attacks

Platform-Specific Risks:

  • Harmful User-Generated Content (UGC): Content that violates platform policies or legal requirements
  • Platform Abuse: Coordinated inauthentic behavior, spam, and manipulation campaigns
  • Algorithmic Bias: Discriminatory or harmful outcomes from recommendation algorithms
  • DDoS Attacks: Distributed denial-of-service attacks targeting platform availability
  • Government Takedown Demands: Legal requests that may impact content availability or user privacy
  • Financial Fraud and Money Laundering: Exploitation of the virtual currency and creator payout systems
  • Gambling-like Mechanics Scrutiny: Regulatory and user safety risks associated with gamified monetization features that could be perceived as gambling-like

Operational and Compliance Risks:

  • Content piracy and intellectual property violations
  • Age verification failures and child safety risks
  • Cross-border data transfer restrictions
  • Regulatory non-compliance with GDPR, CCPA, COPPA, or Digital Services Act

3.3 Risk Assessment

Risk assessments must:

  • Be conducted at least annually and when significant changes occur
  • Consider both likelihood and impact of potential security events
  • Evaluate risks to confidentiality, integrity, availability, and privacy
  • Include quantitative analysis where possible
  • Account for platform-specific threat actors and attack vectors
  • Consider reputational and regulatory compliance impacts

3.4 Risk Treatment

Risk treatment options include:

  • Risk Mitigation: Implementing controls to reduce likelihood or impact
  • Risk Transfer: Using insurance, contracts, or third-party services
  • Risk Acceptance: Formally accepting risks within tolerance levels
  • Risk Avoidance: Eliminating activities that create unacceptable risks

Risk treatment decisions must be documented and approved by appropriate stakeholders.

3.5 Risk Monitoring and Review

The Company must:

  • Continuously monitor the risk environment and emerging threats
  • Review risk assessments when significant changes occur
  • Track the effectiveness of implemented risk treatments
  • Report risk status to executive leadership quarterly
  • Update risk management processes based on lessons learned

3.6 Risk Communication

Risk information must be communicated to relevant stakeholders through:

  • Regular risk reports to executive leadership
  • Risk awareness training for all employees
  • Specific briefings for high-risk operational areas
  • Integration with incident response and crisis communications

4. Standards Compliance

Policy Section Standard/Framework Control Reference
3.1 ISO/IEC 27001:2022 A.6.1.1
3.1 PCI DSS v4.0 Req. 12.1, 12.2
3.2, 3.3 SOC 2 Type II CC3.2
3.2 EU Digital Services Act Art. 34
3.2, 3.3 PCI DSS v4.0 Req. 12.2
3.3 NIST Cybersecurity Framework ID.RA
3.4 ISO/IEC 27001:2022 A.6.1.3
3.4 PCI DSS v4.0 Req. 12.3
3.5 SOC 2 Type II CC3.4
3.5 PCI DSS v4.0 Req. 12.2

5. Definitions

Risk: The potential for loss, damage, or destruction of assets or data as a result of a threat exploiting a vulnerability.

Threat: Any circumstance or event with the potential to adversely impact organizational operations and assets through unauthorized access, destruction, disclosure, modification of data, or denial of service.

Vulnerability: A weakness in an information system, security procedures, internal controls, or implementation that could be exploited by a threat source.

Risk Appetite: The amount and type of risk that the organization is willing to pursue or retain.

Risk Tolerance: The organization’s or stakeholder’s readiness to bear the risk after risk treatment in order to achieve its objectives.

6. Responsibilities

Role Responsibility
[Senior Security Role, e.g., CISO] Overall accountability for risk management framework and strategy. Ensure integration with business objectives and regulatory requirements.
[Risk Governance Body Name] Review and approve significant risk assessments and treatment plans. Provide governance oversight for risk management activities.
Business Unit Leaders Identify risks within their domains, participate in risk assessments, and implement approved risk treatment measures.
[Security Department/Team Name] Conduct technical risk assessments, monitor threat landscape, and provide risk analysis expertise.
[Trust & Safety Department/Team Name] Assess content-related risks, monitor platform abuse patterns, and evaluate algorithmic bias risks.
[Legal Department/Team Name] Assess regulatory compliance risks, evaluate government request impacts, and provide guidance on legal risk treatments.

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