Breach and incident response
What happens when something goes wrong.
Two-step escalation
Default: notify the affected customer via the client portal and email.
Serious: also notify the Dutch DPA (Autoriteit Persoonsgegevens) within 72 hours when there is risk to people's rights — for example sensitive data type, volume, identifiability, or likely harm such as identity theft or financial loss.
Below threshold: internal written log only (date, what happened, what was done), since the AP can ask for it anytime.
Breach notifications can be filed in BacksterOS with attached tasks to track resolution.
Sensitivity note
Financial information including invoicing counts as sensitive (name + address + purchase info is identifiable).
Timeline
The 72-hour deadline for notifying the Autoriteit Persoonsgegevens starts the moment we become aware of a breach, not when the investigation is finished. If not everything is known yet, we file an initial report and add details later.
Affected customers are notified without undue delay, and at the latest within 48 hours of becoming aware, so they can meet their own obligations.
Roles and responsibilities
Remon de Vries is responsible for incident response: assessing the breach, deciding on notifications and signing off on the resolution.
Others are brought in when needed: technical support for investigation and recovery, the affected customer's contact person, the vendors involved, and legal advice for serious cases.
Detection and containment
When an incident is detected we:
- Lock or suspend affected accounts and revoke active sessions.
- Rotate exposed keys, tokens and passwords.
- Isolate affected servers or services.
- Restore clean data from encrypted backups where needed.
- Preserve logs and evidence for investigation.
Informing affected individuals
When a breach is likely to result in a high risk to people's rights and freedoms, the affected individuals are informed directly and without undue delay. The notice describes in clear language:
- What happened and which data is involved.
- The likely consequences.
- What we have done and are doing to address it.
- What they can do to protect themselves.
- Who to contact for more information.
Client data and vendors
When we process personal data on behalf of a client, we alert that client without undue delay so they can meet their own reporting duties as data controller.
Our vendors (including Hetzner, AgentMail and Stripe) are required to alert us of breaches affecting our data. We then assess the impact and follow the same escalation steps.
Post-incident review
After every incident we review what happened, why, and how it was handled. Follow-up fixes are filed as tasks in BacksterOS and tracked until completed, and the internal log is updated with the outcome.
Reporting a security issue
Found a security issue? Email info@lemo-design.com, or write to Lemo-Design, Turfmarkt 7, 8911KS Leeuwarden, Friesland, The Netherlands, or call +31 (0)58 266 42 42. We acknowledge reports and keep you informed while we investigate.