Crafting a Solid Security Incident Response Policy: A Step-by-Step Guide

In today’s digital age, organizations face an increasing number of security threats and incidents that can disrupt operations, compromise sensitive information, and damage reputations. An effective incident reporting and response strategy, including a comprehensive data breach response plan, is crucial to mitigate these risks, ensure timely resolution, and maintain trust with stakeholders.

Introducing an incident response framework can provide a structured approach to managing and resolving security incidents effectively.

Developing a robust security incident response policy will not only help you effectively manage information security incidents but will also help your information security program meet compliance regulations and satisfy many state laws.

This guide provides a comprehensive overview of how to build an effective information security incident response plan and includes how to identify your Information Security Incident Response Team (ISIRT), develop a communication plan, report incidents, and respond to

Identifying your ISIRT - Information Security Incident Response Team

The first step in establishing a robust incident response strategy is identifying your Information Security Incident Response Team (ISIRT), basically who will do what before, during, and after a security breach. This data breach response team plays a critical role in managing and handling security incidents.

It’s important to note that your incident response team doesn’t just include your chief information officer and associates from your organization, but should also include business partners, subject matter experts, relevant authorities (such as law enforcement), legal counsel, contacts for your insurance policy (or policies), utilities contacts, and any other relevant

Incident Response Team Roles and Responsibilities

To ensure an appropriate response to security incidents clearly define the roles and responsibilities of each team ISIRT member, including team leader, incident handlers, and communication coordinators. Outline the specific roles and responsibilities of the data breach response team, ensuring clear membership, documentation, and authority within the team. Including external experts and ensure the team has the authority to take necessary steps without seeking permission.

Relevant roles for an effective cyber response team include (but in no way would be limited to):

Incident Response Coordinator (ISIRT Lead)

The ISIRT Lead essentially ensures that the data breach response plan is executed as written and required. This role involves security incident management, which may be handled by someone in senior management, the Chief Information Security Officer, or even an external party. Most notably, this role should be managed by someone with great leadership and project management capabilities and they will manage the data breach response in its entirety.

Executive Technology Lead

Usually the Chief Technology Officer (CTO), IT Director, or similar. They should have a complete understanding of the organization’s information systems, networks, and all other things technical, including incident detection. This role will manage the information security (IT) team and ensure they execute effectively to meet the needs of the ISIRT.

Executive Information Security Lead

Part of the information security office, this role is typically tasked with sensitive data protection (such as PII - Personally Identifiable Information like social security numbers and financial information) and incident containment to mitigate potential threats. This is usually the Chief Information Officer (CIO), or the Chief Information Security Officer (CISO), or whoever is acting in those capacities.

Information Security Program Director

In organizations where this is separated, they are normally a step under the Executive Information Security Lead. This may be the CISO under a CIO. Where separate, they are normally tasked with documenting all incident information throughout the data breach response, collecting and maintaining evidence, performing incident remediation, and updating relevant policies and procedures as appropriate (based on “lessons learned” performed at the conclusion of the data breach).

Information Security Officer or Privacy Officer

This role is responsible for managing communications with affected parties and affected individuals when a breach occurs and once it’s concluded. They will oversee incident recovery and respond to requests from affected parties, ensuring the individuals involved as required by the applicable privacy act for each individual. Typically, they will inform affected parties what confidential information belonging to them has been compromised.

HIPAA Security Officer

For organizations that fall under the requirements of HIPAA (Health Insurance Portability & Accountability Act), an individual within the organization must be named as the HIPAA Security Officer. Otherwise, they manage many of the responsibilities of the roles above.

Senior Management

If not already identified, senior management should be included within the ISIRT. While they may not have any specific duties during the data breach response, it’s important they stay informed, and are available to make decisions the other ISIRT members may not be authorized to make.

Additionally, senior management should review incident response metrics to measure the effectiveness of the response.

Legal Counsel & General Counsel

For many organizations, legal counsel will be provided by an external law firm. It’s important to have relevant representation and if possible, should include legal counsel from a firm specializing in privacy law, regulatory compliance, and/or data breach response.

Local Law Enforcement (Local Police Non-Emergency Contacts) & Local FBI Office(s)

Rather than a specific individual, this is about identifying your organization’s local police contacts (non-emergency numbers) and local FBI Field offices. Documenting this information is crucial to avoid scrambling to locate it in the midst of a data breach and to ensure proper incident escalation to law enforcement.

Public Relations

Your public relations officer, or department, is primarily responsible for maintaining (and if possible improving) the company’s reputation. In tandem with the Privacy Officer and general counsel, the public relations ISIRT member(s) manage incident communication and handle communications with external entities and parties affected by the data breach, typically through press releases.

Insurance Policy Contacts

The ISIRT list should include the contacts and relevant information related to your organization’s insurance policies. If possible, maintain an outline of the essential elements of each policy such as deductibles, incident response costs, and claim requirements.

Cyber Response Team(s)

The cyber response team(s) help manage cybersecurity incidents and work to prevent serious harm to the organization. They help quickly execute the cyber incidentresponse plan and may also help restore the organization to normal operations. This may be a single boots on the ground team, or groups of highly specialized teams to support multiple area of the incident response plan.

Forensic Incident Investigations

Forensic investigators help identify what exactly what data and system were accessed when the breach occurred. Often overlooked, forensic analysis can help reduce reputational damage and regulatory fines by specifically identifying the affected individuals, but more so those not affected. This allows the organization to limit communications to only the affected individuals (limiting reputational damage to only those involved), and provides supporting evidence to meet regulatory requirements (which reduces or eliminates regulatory fines).

Establishing the Team

Select a cross-functional team with expertise in information security, risk management, and communication. Ensure the team includes members from IT, legal, human resources, and public relations. Work closely with the human resources department to assign specific roles and assist in the investigation of incidents as necessary.

Communication Plan / Communication Matrix

Effective stakeholder communication is vital during a security incident, and documenting incident response activities is crucial for ensuring transparency and accountability. A well-structured communication plan ensures that the right information reaches the right people at the right time.

The incident response process includes several phases such as preparation, detection, containment, investigation, remediation, recovery, and lessons learned. Each phase should include communication requirements for internal and external stakeholders including:

• Training requirements,

• What to communicate, and

• Who will (primarily) perform the communication(s).

ISIRT Data Breach Notification

Prompt incident reporting is crucial for minimizing the impact of security incidents. The incident response policy must establish clear notification procedures for reporting data breaches to the ISIRT. All organizational associates, and relevant external parties, must be understand how to notify the ISIRT when a data breach occurs.

Notification requirements should include:

• Preferred notification methods (i.e., emails, phone, or website portals),

• Backup notification methods,

• Anonymous notification methods (if available), and

• What information to provide in notification reports.

Anonymously Reporting Data Breaches & Security Incidents

Encouraging anonymous reporting can help uncover incidents that might otherwise go unreported due to fear of repercussions. Additionally, implementing anonymous reporting capabilities can also help satisfy many whistleblower protection requirements (with various laws and regulations).

• Ensuring Anonymity: Implement measures to protect the identity of reporters, such as anonymous reporting tools and confidential reporting channels.

• Tools and Techniques for Anonymous Reporting: Use third-party platforms or internal systems that allow anonymous submissions while maintaining data security.

Incident Reporting Ticket Format

Your security incident response policy should include a standard data breach reporting template or question set. This way, any reported incident will include the information needed to best support the ISIRT in their response efforts. When setting this up however, be sure to consider the following to ensure the ISIRT is getting the information they need, while at the same time not making the process too difficult or breaking anonymity.

• Standard Reporting Format: Develop a template for incident reports that includes fields for all necessary information, such as date and time of the incident, affected systems, and initial impact assessment.

• Protect Anonymity: Be sure to not require fields that would require the reporter to identify themselves.

• Keep it Simple: Don’t include so many questions or require so many fields that the reporter gives up or avoids reporting altogether. Also be careful to not restrict access to the reporting form or “hide” it behind multiple authentication steps.

Data Breach Reporting

Timely and accurate reporting to internal and external stakeholders is essential for transparency and effective incident management, not to mention a requirement of multiple data breach notification laws. While much of the reporting will be based on each specific incident, your security incident response policy can include templates and a general reporting structure for when you detect incidents, during your investigation, and at the conclusion of your incident response.

It’s important to include reporting requirements for both internal and external stakeholders which should include customers, partners, and regulatory bodies.

Data Breach Reporting - Initial Discovery

The initial discovery phase is critical for setting the tone of the incident response. While you may not have a lot of information when a security incident is discovered, it’s important to notify all relevant parties. Your security incident response policy should include a standard reporting template which should typically include:

• A clear description of what was discovered,

• A statement identifying the legal basis for the notification (i.e., HIPAA, etc.) during the initial assessment,

• What the organization is doing in response to the incident,

• Recommendations (if any) for those impacted,

• A statement committing to transparency throughout the response process, and

• Contact information for questions related to the incident.

As with any communication, it’s important to review with legal and senior management prior to sending anything out.

Data Breach Reporting - During Investigation

Investigation updates during the investigation phase keep stakeholders informed and engaged. Maintain regular updates on the investigation’s progress, new findings, and any changes in the incident’s status. Schedule periodic progress reports to keep stakeholders informed about the investigation’s status and any actions being taken.

Data Breach Reporting - At Conclusion

Concluding the incident reporting process involves summarizing the incident, its impact, and the steps taken to resolve it. For relevant internal stakeholders, prepare a comprehensive final report that details the incident, its impact, the response actions taken, and any lessons learned. For external stakeholders, provide a statement explaining what was discovered, what the results were from your investigation, and what it means for them.

A best practice is to use the same format throughout the process. This makes it easier for recipients to review and ensure that you’re providing appropriate information related to the incident. What may also be included in the final communication (that is not found in other communications) is what your organization is going to do for those impacted, such as purchasing credit monitoring.

Responding to Authorities and Inquiries

A critical component that every security incident response policy should include is how to interact with regulatory inquiries and external authorities during and relating to an incident. Unfortunately, it’s almost always overlooked.

Crafting appropriate responses to authorities’ inquiries is essential for maintaining credibility and compliance. All associates should understand what to say, and how to transfer inquiries from authorities and other external parties. You don’t want an employee telling the press they can’t talk because you’re currently dealing with a major data breach.

• Crafting Appropriate Responses: Provide guidelines on how to respond to inquiries from authorities, including what information to share and how to present it.

• Do’s and Don’ts: Highlight the do’s and don’ts of communicating with authorities, such as avoiding speculation and ensuring consistency in messaging.

How to Response to Inquiries - What to Say

This doesn’t, and very much shouldn’t, be complicated, but it’s imperative that you educate all of your associates on how to respond to any inquiries relating to any data breaches. Effective external communication is crucial in these situations. You want to be sure only designated and approved associates are speaking with external authorities, answering questions, and engaging with the press. For everyone else, some good examples include:

• “Thank you for contacting us. I’m not the best resource to speak on this issue. Allow me a moment to transfer you to that department.”

• “Thank you for brining this to our attention. I’m not the best person to address this, but I will connect you with a team member who can provide you more information.”

• “This isn’t something I would be able to discuss, let me transfer you to someone who can.”

Short, simple, and much better than “I can’t talk right now, we just lost a lot of client data and we’re trying to figure out how it happened.”

Incorporate Business Continuity Plans & Disaster Recovery Plans

Integrating business continuity and disaster recovery plans with your overall data breach response plan ensures comprehensive operational resilience by enhancing incident response capabilities. Part of your security incident response policy should identify how and when Business Continuity Plans (BCPs) are enacted, and when it is safe to execute the organization’s Disaster Recovery Plans (DRPs).

Business Continuity Plans

Business Continuity Plans (BCPs) are strategic plans designed to ensure that an organization can continue business operations during and after a disruptive event through a thorough business impact analysis. These plans focus on maintaining essential functions and services, allowing the business to remain operational and minimize downtime despite challenges such as natural disasters, data breaches, or other emergencies. Unlike Disaster Recovery Plans, which concentrate on restoring IT systems and data after an incident, BCPs emphasize the importance of maintaining critical business operations throughout the duration of the event.

Disaster Recovery Plans

Disaster Recovery Plans (DRPs) are specialized strategies focused on the restoration of IT systems, data, infrastructure, and all business operations after a disruptive incident, with clear recovery objectives. These plans are essential for returning to normal operations as quickly as possible following events such as cyber-attacks, natural disasters, or hardware failures.

Unlike Business Continuity Plans, which aim to ensure ongoing operations during an adverse event, DRPs concentrate on the recovery phase, detailing the steps necessary to rebuild and restore critical systems and data. Effective Disaster Recovery Plans are vital for minimizing downtime, mitigating data loss, and ensuring that an organization can resume full functionality and service delivery with minimal disruption to business activities.

Conclusion

In an era where digital threats are ever-evolving, having a well-structured incident reporting and response strategy is not just beneficial but essential. This comprehensive guide has provided detailed insights into developing an effective Information Security Incident Response Plan (ISIRT), which includes identifying and assembling your incident response team, crafting a robust communication strategy, and ensuring prompt and accurate reporting of incidents.

By clearly defining roles and responsibilities and integrating Business Continuity Plans (BCPs) and Disaster Recovery Plans (DRPs), organizations can ensure they are not only prepared to handle security incidents but also capable of maintaining operations and swiftly returning to normalcy post-incident.

Remember, the key to effective incident management lies in preparation, clear communication, and continuous improvement, ensuring your organization remains resilient and trustworthy in the face of adversities.