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Security Incident Management Pack — Guide

  • Version 1.3
  • Updated
  • 11 documents
  • Word, Excel

Security Incident Management Pack

The first serious incident is the wrong time to decide who is in charge, how bad it is, and whether the regulator must hear about it by tomorrow morning. Most teams have a plan nobody has opened, no agreed severity levels, and three legal clocks they only learn about once they are running. This pack gives a small team a working incident capability before it is needed.

Is this for you?

This pack is for you if:

  • nobody could say who decides to take a system offline at 2 a.m.;
  • you could not tell, within four hours, whether an incident must be reported;
  • your last incident ended without a written review or any follow-up.

Three clocks start at once

When an incident is declared, the reporting clocks start. The pack screens every incident against all three within four hours of declaration (IM-06), whether or not a report follows.

LawWho it bindsFirst deadlineThen
NIS2 Article 23Essential and important entities, for a significant incidentEarly warning within 24 hoursNotification within 72 hours; final report within one month of it
GDPR Articles 33–34Every controller, for a personal data breachThe authority without undue delay and, where feasible, within 72 hours of awareness, unless it is unlikely to result in a riskThe people affected without undue delay, if the risk is high
DORA Article 19Financial entities, for a major ICT-related incidentInitial notification within 4 hours of classifying it as major, and within 24 hours of awarenessIntermediate report within 72 hours; final report within one month

If you are in the United States, or serve people who are, five more questions follow the three: HIPAA, the SEC’s Form 8-K Item 1.05, New York’s financial services rule, State breach laws and the FTC’s rules. Their clocks start elsewhere. HIPAA and State laws run from discovery, the first day anyone knew, which can be earlier than declaration; the SEC’s four business days run from the decision that an incident is material; New York’s 72 hours from determining that an incident has occurred. The pack records the discovery time (IM-13) and keeps the US rows beside the EU ones. It is not legal advice: ask counsel which duties bind you.

Severity is separate. The pack’s four levels set how fast you respond and who is told, judged on the worst thing the incident has done or could do. When in doubt, choose the higher level.

How it runs in practice

Take a distributor with 900 staff. At 07:50 its monitoring provider alerts on encryption activity at one warehouse. Triage starts 15 minutes later, and the incident manager declares Severity 1 at 08:25. The site is cut off at 09:10, the crisis team meets at 09:20 and the board chair hears at 12:20. By 13:50, six hours after the alert, 14 office PCs are contained and ordering was never touched. The NIS2 early warning goes at 15:40, the notification two days later and the final report in September, each within its deadline. The review four working days after closure produces five actions with owners, including removing local administrator rights from every office PC.

Start with these three

  1. Incident Response Plan: who leads, who decides, and the phases from report to review.
  2. Incident Classification, Severity & Escalation Matrix: the four severity levels, who to tell and every reporting clock.
  3. Incident Triage & First-Hour Assessment Procedure: from a report to a declared incident with a severity, in the first hour.

Your first month

WhenWhat to doYou’re done when
Week 1Name the incident manager, the executive incident lead and their deputies.Management has approved the plan’s roles.
Week 2Set the severity thresholds and fill in the contact directory, suppliers included.Every number has been called once.
Week 3Work out which laws apply to you, and where each report goes.The matrix names each authority.
Week 4Run the readiness checklist and a one-hour walk-through of a ransomware case.Failed items have owners and dates.

Four numbers to report

Report these to executive management each quarter.

NumberTarget
Significant incidents, and hours from detection to containmentEach contained within 24 hours
Reports to authorities and individuals made on timeAll
Post-incident review actions overdueNone more than 30 days overdue
Months since the plan was last exercised12 or fewer

The first is the incident measure in a board report. Every Severity 1 and 2 incident has a review within ten working days of closure, and the risks it touches are reassessed in the risk register.

Everything in the pack

Adapting it

  • Small organisation: one person can hold several roles, but the incident manager and the executive incident lead are always two different people, each with a deputy; the executive incident lead is usually the managing director.
  • Regulated entity: a financial entity follows DORA’s classification and its four-hour initial notification instead of NIS2’s early warning. Everyone keeps GDPR’s clocks.
  • US organisation: answer the US questions too and record the discovery time. The pack names, without working through, CIRCIA (its final rule had not been published on 18 October 2026) and DFARS.
  • IT run by an outside provider: most of the hands-on response is theirs. Check that the contract makes them report an incident within 24 hours and join your response, and put their out-of-hours line in the contact directory.

Where it maps

  • ISO/IEC 27001:2022: Annex A 5.24 to 5.28 and 6.8.
  • NIST CSF 2.0: RS.MA-01 and DE.AE-08.
  • NIS2: Article 21(2)(b) and Article 23.
  • GDPR: Articles 33 and 34.
  • DORA: Articles 17 to 19.
  • HIPAA: 45 CFR 164.402 to 164.412.
  • SEC: Form 8-K Item 1.05.
  • NYDFS: 23 NYCRR 500.17.

Prepared by Zero One Cybersecurity · Published by CISO Times

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