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The CISO Decision Brief

Incident Response Plan

Defines the response organisation, phases, decision authorities and hand-offs used for every incident regardless of type.

Available soon

Format
Word
Size
75 KB
Length
26 pages
Version
1.2
Updated

What's inside

What changed

  1. 1.2

    RD-10 now states DORA's rule for an incident classified as major only after 24 hours: the initial notification is due within 4 hours of that classification (Delegated Regulation (EU) 2025/301, Article 5(2)).

  2. 1.1

    Containment is least disruptive first, and the service owner and specialists come in before a service people depend on for safety or essential operations is stopped.

  3. 1.0

    Published.

Changes across this pack

Preview

The document from section 1, as you will receive it. Highlighted [[text]] is for you to replace; shaded guidance boxes are for you to delete before approval. The cover and document control pages are in the file.

Purpose and objectives

This plan is how [[Organisation Name]] responds to every information security incident, whatever its type: who does what, in which order, who decides, who must be told and by when, and what has to be ready before anything happens. It carries out the Security Incident Management Policy, and applies the rules IM-01 to IM-12 by number. The playbooks add the steps for the incidents that need their own; this plan is the response for all the others, and the frame the playbooks sit in.

The plan has four objectives, each with a measure the quarterly report shows (IM-12):

  1. Stop the harm quickly. Contain every incident before it spreads, and every significant one within [[24]] hours of detection (IMM-01).
  2. Tell the right people on time. Escalate within the times the severity sets, and make every report to an authority, a controller or the people affected by its deadline (IMM-02).
  3. Recover safely. Return nothing to service until the recovery criteria are met, so the attacker does not come back through the same door (IM-10).
  4. Learn. Review every serious incident, finish the actions it produces, and exercise the plan every year (IMM-03, IMM-04).

Guidance — delete before approval

Read this plan with the Incident Classification, Severity & Escalation Matrix open beside it: the plan says who does what; the matrix says how serious an incident is and how fast each clock runs. Keep both, with the contact directory, where you can read them when every system is down (see Resources).

Scope

The plan applies to every event reported under the Security Incident Management Policy and every incident declared from it, at every severity: [[all sites, systems, services and data of Organisation Name, including those run for it by suppliers]]. Severity 3 and 4 incidents follow the same phases with fewer people: the IT service desk or the incident manager runs them in working hours, and nobody else is called unless the severity rises. Severity 1 and 2 incidents bring in the executive incident lead and, for Severity 1, the crisis team and the board.

Not covered here: [[business continuity events with no security cause, e.g. a power cut or a flood, which follow the business continuity plan — the two plans hand over to each other when an incident disrupts a service]].

The response phases

Every incident moves through the same seven phases. Several can run at once — containment starts while triage is still being completed, and the reporting screen runs alongside containment — but none is skipped. Each phase has one owner and a recorded output; the output is what the next phase and the post-incident review rely on.

Phase

Owner

Output

Rules

Prepare

Head of Information Security

An approved plan; a contact directory checked in the last quarter; an exercise report from the last 12 months; the readiness checklist completed.

IM-12

Detect and report

Reporter

A report in the case log with the time and the reporter.

IM-01

Triage and declare

Incident manager

A declared incident with a case number, incident manager, category and severity; escalations made; the reporting screen complete within 4 hours.

IM-02, IM-03, IM-04, IM-05, IM-06

Contain

Incident manager

Containment recorded with its time; the evidence log started; every decision with business impact in the decision log.

IM-07, IM-08, IM-09

Eradicate

Technical responders

The cause and the route in recorded; the route closed; credentials changed.

IM-07

Recover

Technical responders

A recovery sign-off for each system; the monitoring period passed; the incident closed.

IM-10

Review

Head of Information Security

The review report within 10 working days of closure for Severity 1 and 2; actions in the case log; the plan's revision history.

IM-11, IM-12

Prepare

Keep the plan, the contact directory, the playbooks and the resources ready; train the people in the roles and their deputies; exercise the plan.

Owner: Head of Information Security. Output: an approved plan; a contact directory checked in the last quarter; an exercise report from the last 12 months; the readiness checklist completed. Governed by: IM-12; Incident Response Readiness Checklist.

Detect and report

Anyone who sees something suspicious reports it at once through the reporting route; monitoring alerts reach the IT service desk or the incident manager directly.

Owner: Reporter. Output: a report in the case log with the time and the reporter. Governed by: IM-01; Incident Case & Action Log.

  • The reporting route: [[phone number, email address and portal]], answered by the IT service desk in working hours ([[08:00–18:00, Monday to Friday]]) and by [[the on-call incident manager, or the security monitoring provider]] outside them.
  • Alerts: the security monitoring service's alerts go to [[the service desk queue and the on-call incident manager's phone]]; an alert is a report and starts the triage clock.

Triage and declare

The service desk triages the report within the IM-02 times; the incident manager declares an incident or closes the event with a reason, sets category and severity, escalates, and starts the reporting screen.

Owner: Incident manager. Output: a declared incident with a case number, incident manager, category and severity; escalations made; the reporting screen complete within 4 hours. Governed by: IM-02, IM-03, IM-04, IM-05, IM-06; Incident Classification, Severity & Escalation Matrix; Incident Triage & First-Hour Assessment Procedure.

Triage starts within 30 minutes of the report in working hours and 60 minutes outside them, and ends within [[30]] minutes of starting with the event closed with a reason or declared an incident (IM-02). Once the incident manager declares an incident, the first hour runs in this order (the Incident Triage & First-Hour Assessment Procedure gives the detail):

  1. Open the case. Give it a case number, record the time of declaration (the start of every reporting clock) and the reporter.
  2. Set severity and category. Use the matrix. When in doubt, choose the higher severity.
  3. Escalate. Tell the people the severity requires, within its time.
  4. Contain what is spreading. Isolate before investigating when harm is spreading, with the least disruptive containment that stops it; otherwise preserve evidence first.
  5. Start the reporting screen. Ask the three legal questions (NIS2, GDPR, DORA where it applies) and the contract and insurance questions. The screen is complete within 4 hours (IM-06).
  6. Set the next update. Agree when the team reconvenes, and send the first internal update.

Contain

Stop the harm spreading with the least disruptive containment that does it: isolate systems, sites or accounts, block the attacker's routes, and preserve evidence unless waiting would let the harm spread.

Owner: Incident manager. Output: containment recorded with its time; the evidence log started; every decision with business impact in the decision log. Governed by: IM-07, IM-08, IM-09; Ransomware Response Playbook; Business Email Compromise Response Playbook; Personal Data Breach Response Playbook; Incident Communications Template Set.

  • Isolate or preserve first? Preserve evidence first unless the harm is spreading; if it is spreading, isolate first and record what was lost (IM-07).
  • Least disruptive first: the incident manager contains at once, with the least disruptive action that stops the harm (an account, a device, a segment or the attacker's route in, before a whole service). Waiting for an executive is never a reason to let harm spread (IM-08).
  • Business impact: containment that stops a customer-facing service is the executive incident lead's decision, except where waiting would let the harm spread. Before any action that would stop a service people depend on for safety or essential operations, the incident manager brings in its service owner and specialists (IM-08). See Decision rights.
  • Updates: send updates at the interval the severity sets (Severity 1 every 2 hours; Severity 2 every 4 hours; Severity 3 every 24 hours), using the approved templates (IM-09).

Eradicate

Find the cause and the way in; remove the attacker's access, tools and persistence; change credentials that could have been taken; close the route in.

Owner: Technical responders. Output: the cause and the route in recorded; the route closed; credentials changed. Governed by: IM-07; Ransomware Response Playbook; Business Email Compromise Response Playbook.

  • Assume the attacker had more than you have found: change the credentials of every account used on an affected system, including service accounts and administrators, and check for new accounts, mail rules, scheduled tasks and remote access tools.
  • Do not rebuild before the evidence is safe (IM-07). A rebuilt machine cannot tell you how the attacker got in.

Recover

Restore from backups or rebuild images checked for integrity; bring services back in order of business priority; watch them closely for the monitoring period.

Owner: Technical responders. Output: a recovery sign-off for each system; the monitoring period passed; the incident closed. Governed by: IM-10; Ransomware Response Playbook.

A system returns to normal service only when all of these are true (IM-10):

  • The cause is understood well enough that the same route in is closed.
  • Backups or rebuild images were checked for integrity before they were used.
  • Restored systems are patched, scanned and monitored, with credentials changed where they could have been taken.
  • The system owner has tested the service and confirms it works.
  • The monitoring period has started: [[7]] calendar days of closer watching for Severity 1 and 2 before closure.

The incident manager closes the incident when the recovery criteria are met, the monitoring period of 7 calendar days (Severity 1 and 2) has passed without recurrence, and the case log is complete.

Review

Review what happened and how the response went; agree actions with owners and dates; reassess the risks the incident touched; update this plan. Severity 3 and 4 incidents are reviewed together once a quarter.

Owner: Head of Information Security. Output: the review report within 10 working days of closure for Severity 1 and 2; actions in the case log; the plan's revision history. Governed by: IM-11, IM-12; Post-Incident Review Template; Incident Case & Action Log.

The post-incident review uses the Post-Incident Review Template. It asks what happened, what went well, what did not, and why; it is not a search for someone to blame. Its actions go into the Incident Case & Action Log with an owner and a due date (default [[within 90 calendar days]]), and the risks the incident touched are reassessed in the Information Security Risk Register (Information Security Risk Management pack).

Roles and the crisis team

Every role has a named deputy with the same authority while acting in it. Names and numbers are in the contact directory; the roles are defined here so that they survive a change of people.

Role

In an incident

Deputy

Incident manager

[[e.g. Information Security Manager, with a named deputy]]

Runs the response from declaration to closure; declares, sets category and severity; escalates; directs the responders; completes the reporting screen; keeps the case log and the decision log. May isolate systems, sites and accounts at once, with the least disruptive containment that stops the harm; brings in the service owner and specialists before stopping a service people depend on for safety or essential operations.

[[Role]]

Executive incident lead

[[e.g. Chief Operating Officer, with a named deputy]]

Takes the decisions with business impact; approves reports to authorities and what is said outside; chairs the crisis team; briefs the board.

[[Role]]

Head of Information Security

[[e.g. Head of Information Security or CISO]]

Owns this plan; advises the incident manager; runs the post-incident review and the yearly exercise.

[[Role]]

IT service desk

[[internal service desk, or the managed IT provider's]]

Receives reports and alerts; triages within the IM-02 times; handles Severity 4 incidents; calls the incident manager for anything larger.

[[Role]]

Technical responders

[[IT operations, the managed IT provider and the security monitoring provider]]

Contain, investigate, eradicate and recover under the incident manager's direction; preserve evidence; check backups before restoring.

[[Named lead at each]]

Data Protection Officer

[[or the privacy lead where no DPO is appointed]]

Assesses every incident involving personal data for risk to individuals; advises on GDPR reports; keeps the breach record.

[[Role]]

Legal

[[in-house or external counsel]]

Advises on reporting duties, contracts, evidence, law enforcement and any extortion demand; engages outside counsel.

[[Role]]

Communications lead

[[e.g. Head of Marketing and Communications]]

The only voice outside the organisation (IM-09); prepares every message from the approved templates.

[[Role]]

Board

[[the board chair, or the equivalent where there is no board]]

Is told of every Severity 1 incident; alone decides on any ransom or extortion demand.

[[Vice-chair, or equivalent]]

The crisis team

Members: [[executive incident lead, incident manager, Head of IT, Legal, DPO, communications lead, and the owners of affected services]]. Chair: the executive incident lead. Convened: for every Severity 1 incident, within 1 hour of declaration, and for a Severity 2 incident when the executive incident lead decides. Meets: in the war room, or on the out-of-band service, at the update interval the severity sets, until containment; then as the chair decides.

Every crisis team meeting follows the same agenda:

  1. What we know, what we do not know, and what has changed since the last meeting.
  2. Severity and category: still right? Anyone may raise severity; only the incident manager lowers it.
  3. Is harm still spreading? What containment is under way, and what is it costing the business?
  4. Decisions needed now, and who has the right to take each one.
  5. The reporting screen: which reports are due, to whom, and by when.
  6. Communications: staff, customers, suppliers, media — what is said, by whom, from which template.
  7. People and resources: who is tired, who takes over, and whether outside help is needed.
  8. The time of the next update and the next meeting.

Guidance — delete before approval

Name a deputy for every role, and make sure the deputy has taken part in an exercise. Most serious incidents start at night, at a weekend or in the holidays, and the first hours are run by whoever answers the phone.

The incident manager and the executive incident lead must be different people. One runs the response; the other decides what the business can bear and answers for it.

Severity at a glance

Severity is the highest level any impact area reaches, judged on what the incident has done or is capable of doing. When in doubt, choose the higher level. Severity is reviewed at every update and can be raised by anyone on the response team; it is lowered only by the incident manager, with the reason recorded in the case log. The full criteria for each impact area are in the Incident Classification, Severity & Escalation Matrix; this summary is what the response team works from.

Severity

Impact level

Who leads

Who is told, and how fast

Updates

Working pattern

Severity 1

Critical

Severe

Incident manager, with the executive incident lead deciding

Incident manager at once; executive incident lead within 30 minutes; crisis team convened within 1 hour; board chair, or equivalent, within 4 hours

Every 2 hours

Round the clock until contained

Severity 2

High

Major

Incident manager

Incident manager at once; executive incident lead within 2 hours

Every 4 hours

Extended hours as needed

Severity 3

Medium

Moderate

Incident manager, or the IT service desk under their direction

Incident manager at once; Head of Information Security the same working day

Every 24 hours

Working hours

Severity 4

Low

Minor

IT service desk

IT service desk logs and handles it; Head of Information Security in the weekly summary

None scheduled

Working hours; closed within [[5]] working days

Times run from declaration. Severity is reviewed at every update (IM-04); a rise in severity brings in the people the new level requires at once.

Decision rights

These decisions have business impact, so the plan says in advance who may take them. Waiting for the executive is never a reason to let harm spread (IM-08). The one limit: before any action that would stop a service people depend on for safety or essential operations, its service owner and specialists are brought in, and containment goes on meanwhile.

Decision

Who decides

Conditions

Isolate a system, site or account

Incident manager

Use the least disruptive containment that stops the harm, and bring in the service owner and specialists before any action that would stop a service people depend on for safety or essential operations. Tell the executive incident lead at the next update.

Stop a customer-facing service

Executive incident lead

The incident manager may do it first where waiting would let the harm spread, and reports it at once. Where people depend on the service for safety or essential operations, its service owner and specialists are brought in first.

Report to an authority

Executive incident lead, on the incident manager's reporting screen

The Data Protection Officer advises on GDPR reports. A report is never held back to avoid a deadline.

Say anything outside the organisation

Communications lead, with the executive incident lead's approval

Only from the approved templates (IM-09).

Engage outside responders or the insurer's panel

Incident manager, within the [[retainer]]; above it the executive incident lead

—

Pay a ransom or extortion demand

Only the board or its equivalent

Never before legal advice (including sanctions checks), the insurer's view and a report to law enforcement. The plan assumes we do not pay.

Ransom and extortion. Only the board or its equivalent may decide on a ransom or extortion demand (IM-08), and only once the conditions in the table are met. The Ransomware Response Playbook sets out what the board is told, and when.

Every decision in this table is recorded in the decision log with its time, who took it and why, whether or not it turned out to be right.

Reporting duties

Every incident is screened against every reporting duty within 4 hours of declaration, and the decision and its reasons recorded whether or not a report is made (IM-06). The screen asks three legal questions, then the contract, insurance and law-enforcement questions:

Law

Question

If yes

NIS2

Are we an essential or important entity, and has this incident caused, or could it cause, severe operational disruption or financial loss to us, or considerable damage to others?

RD-01 to RD-05

GDPR

Is personal data affected (confidentiality, integrity or availability)? If so, is the breach unlikely to result in a risk to individuals, a risk, or a high risk?

RD-06 to RD-09

DORA

Are we a financial entity, and does the incident affect critical services and meet the thresholds of Delegated Regulation (EU) 2024/1772 Articles 8 and 9?

RD-10 to RD-13

The duties the screen can trigger are below, grouped by where they come from. The clocks run from awareness — the moment the reporting clocks start: the time the incident is declared, as recorded in the case log, unless the record shows we had reasonable certainty earlier, in which case the earlier time. The Incident Classification, Severity & Escalation Matrix gives each clock in full and the Incident Communications Template Set the approved content for each report.

ID

Report

Deadline

To

Applies to

RD-01

NIS2: Early warning

Within 24 hours of awareness

[[CSIRT or competent authority]]

Essential and important entities, for a significant incident

RD-02

NIS2: Incident notification

Within 72 hours of awareness

[[CSIRT or competent authority]]

Essential and important entities, for a significant incident

RD-03

NIS2: Intermediate report

When the authority asks

[[CSIRT or competent authority]]

Essential and important entities, for a significant incident

RD-04

NIS2: Final report

Within one month of the incident notification (a progress report then, and the final report within one month of handling, if still ongoing)

[[CSIRT or competent authority]]

Essential and important entities, for a significant incident

RD-05

NIS2: Notice to recipients of our services

Without undue delay, where appropriate

Customers whose service is likely to be adversely affected

Essential and important entities, for a significant incident

RD-06

GDPR: Notification to the supervisory authority

Without undue delay and, where feasible, within 72 hours of awareness; later only with reasons for the delay

[[lead supervisory authority]]

Controllers, unless the breach is unlikely to result in a risk to individuals

RD-07

GDPR: Communication to the individuals affected

Without undue delay

The data subjects

Controllers, where the breach is likely to result in a high risk to individuals, unless an Article 34(3) condition is met

RD-08

GDPR: Breach record

For every personal data breach, notified or not

Kept by us; shown to the authority on request

Controllers

RD-09

GDPR: Notice to the controller

Without undue delay

The controller whose data we process

Where we act as a processor

RD-10

DORA: Initial notification

Within 4 hours of classifying the incident as major, and no later than 24 hours after awareness; where it is classified as major only after those 24 hours, within 4 hours of that classification

[[financial competent authority]]

Financial entities, for a major ICT-related incident

RD-11

DORA: Intermediate report

Within 72 hours of the initial notification, and again when regular activities are recovered

[[financial competent authority]]

Financial entities, for a major ICT-related incident

RD-12

DORA: Final report

No later than one month after the latest intermediate report

[[financial competent authority]]

Financial entities, for a major ICT-related incident

RD-13

DORA: Notice to clients

Without undue delay

Clients whose financial interests are affected

Financial entities, for a major ICT-related incident

RD-14

Contract: Notice to customers under contract

[[as each contract requires]]

[[customers with a notification clause]]

Where a contract requires it

RD-15

Insurance: Notice to the cyber insurer

[[as the policy requires, often within 48 hours]]

[[insurer or broker incident line]]

Where a cyber policy is held

RD-16

Law enforcement: Crime report

[[as soon as practical for suspected crime]]

[[national cybercrime reporting service]]

Suspected criminal acts, including ransomware and fraud

Guidance — delete before approval

Replace each authority placeholder with the authority your national law names, and put its reporting route in the contact directory. If you are not an essential or important entity under NIS2 and not a financial entity under DORA, keep the questions anyway: the screen takes minutes, and a wrong assumption about status is how deadlines are missed.

A report is never held back to avoid a deadline. Make the report with what is known and add detail later: every regime allows it.

Communications

Only the communications lead speaks for the organisation outside it, and only from the approved templates (IM-09). The Incident Communications Template Set holds them:

Template

Audience

When

Approved by

CT-01 Incident alert to the response team

Incident manager, responders, executive incident lead

At declaration

Incident manager

CT-02 Executive and board briefing

Executive incident lead, crisis team, board chair

Severity 1 and 2, at each update

Incident manager

CT-03 Staff holding message

All staff, or the affected site or team

When staff notice the effects

Executive incident lead

CT-04 Customer notice

Customers whose service or data is affected

When a customer's service is affected or a contract requires it

Executive incident lead

CT-05 Supplier notice and request for help

Suppliers involved in the incident or the recovery

When a supplier must act or be warned

Incident manager

CT-06 NIS2 early warning and notification content

[[CSIRT or competent authority]]

RD-01 to RD-04

Executive incident lead

CT-07 GDPR notification to the supervisory authority

[[lead supervisory authority]]

RD-06

Executive incident lead, with the Data Protection Officer

CT-08 Communication to individuals affected

Data subjects

RD-07

Executive incident lead, with the Data Protection Officer

CT-09 Media holding statement

Press and public

When the incident is, or is about to be, public

Executive incident lead

CT-10 All-clear and thank-you

Everyone told earlier

At closure

Executive incident lead

Assume that anything written on a system the attacker may control can be read by the attacker. During a Severity 1 or 2 incident, the response team talks on the out-of-band service.

Suppliers in an incident

The Third-Party Security Policy (Third-Party Security Risk Management pack) requires (TP-10): “Critical suppliers must be part of incident response and continuity plans, with named contacts and notification duties.” This section is where that happens. The contracts of these suppliers carry the clauses “Security incident notification” (CL-07: notice of an incident at the supplier within [[24]] hours) and “Cooperation in our incident response” (CL-11: a named contact, evidence and help in our response), from the Supplier Contract Security Clause Library.

EXAMPLE — the example organisation's critical suppliers and what each does in an incident:

Supplier

Its part in our response

24/7 contact

Clauses

EXAMPLE SUP-001

Managed IT service provider

Isolates networks and systems, rebuilds devices, restores from backup

[[name, number]]

CL-07, CL-11

EXAMPLE SUP-006

Security monitoring provider

Detects and alerts around the clock; supplies logs and analysis

[[name, number]]

CL-07, CL-11

EXAMPLE SUP-011

Backup service provider

Confirms backup integrity and supports restoration

[[name, number]]

CL-07, CL-11

EXAMPLE SUP-002

Cloud hosting provider

Protects and restores the hosted ordering platform

[[name, number]]

CL-07, CL-11

EXAMPLE SUP-005

Email and office software provider

Suspends accounts, removes mail rules and supplies mailbox audit logs

[[name, number]]

CL-07, CL-11

[[Supplier]]

[[What it does for us in an incident]]

[[name, number]]

[[clauses]]

  • Tell the supplier early when it must act or be warned, using the supplier notice (CT-05); do not wait to be sure it is involved.
  • Direct, do not delegate: a supplier's responders work under the incident manager's direction. A supplier may advise on severity or reporting, but the decisions and the reports stay with us.
  • When the incident is at the supplier (category IC-10), the supplier's notice starts our triage like any other report. Ask for what the clause promises: what happened, what of ours is affected, the measures taken and a contact.

Resources

These must exist before an incident. Check each one in the quarterly contact check and before the yearly exercise.

Resource

What it is for

Ours

Kept ready by

Out-of-band communication

A way to talk, meet and share files that does not depend on systems the attacker may control, such as company email and chat.

[[e.g. a separate messaging workspace on personal devices; a conference bridge number; a shared folder outside the corporate tenant]]

Head of Information Security

War room

A place for the crisis team to meet and work, in person and online.

[[Room and site; the backup room at another site; the online meeting link on the out-of-band service]]

Incident manager

Incident response retainer

Outside responders who start within agreed hours, without a new contract, when the incident is beyond our own team.

[[Firm; contract reference; hours included; response time; 24/7 activation number; who may activate it]]

Head of Information Security

Cyber insurer's panel

The responders, lawyers and negotiators the insurer will pay for, and the conditions for using them.

[[Insurer and policy number; incident line; notice period; panel firms; whether our own retainer firm is accepted]]

Executive incident lead

Forensic tooling

Tools to collect and preserve evidence and to see what an attacker did.

[[Endpoint detection and response console; central log platform keeping at least 90 days; memory and disk capture tools; who is trained to use them]]

Technical responders

Offline copies

The plan, the playbooks, the contact directory, network diagrams and restore instructions, readable when every system is down.

[[Printed copies held by the incident manager and deputy; an encrypted copy on removable media; where each is kept]]

Incident manager

Clean devices

Devices known to be uncompromised, for responders and the crisis team to use when the network cannot be trusted.

[[e.g. two laptops and two phones, kept off the corporate network and updated monthly]]

Technical responders

Guidance — delete before approval

Check the insurance policy before you need it: many policies require the insurer to be told within a set time, and some pay only for the panel's firms. If your own retainer firm is not on the panel, agree now whether the insurer will accept it.

The retainer, the insurer and the war room are useless if nobody can reach them when email is down. Put their numbers in the offline copies.

Playbook index

The category chooses the playbook; severity is set separately. Where no playbook exists, the phases of this plan are the response.

ID

Category

For example

Response

IC-01

Ransomware or destructive malware

Files encrypted; ransom note; systems wiped

Ransomware Response Playbook

IC-02

Other malware

Malware found and blocked or removed, no encryption

This plan's phases

IC-03

Business email compromise and payment fraud

A mailbox taken over; a request to change bank details; a fake invoice

Business Email Compromise Response Playbook

IC-04

Account compromise

A user or administrator account used by someone else

This plan's phases

IC-05

Personal data breach

Personal data sent to the wrong person, lost, stolen, altered or made unavailable

Personal Data Breach Response Playbook

IC-06

Exploited vulnerability

A weakness in an internet-facing system used to get in

This plan's phases

IC-07

Denial of service

A service made unavailable by traffic or requests

This plan's phases

IC-08

Insider misuse

An employee or contractor misusing access

This plan's phases

IC-09

Lost or stolen device

A laptop, phone or removable drive

Personal Data Breach Response Playbook

IC-10

Supplier incident

An incident at a supplier that affects our data or services

This plan's phases

Guidance — delete before approval

Add a playbook when the same kind of incident keeps happening, or when one incident type needs decisions this plan does not cover. Write it in the same seven phases, so responders never have to learn a second structure.

Contact directory

Keep this directory current, check it every quarter, and hold it offline as well as online. Every entry has a number that is answered outside working hours.

Response roles

Role

Name

24/7 number

Deputy

Deputy's number

Incident manager

[[Name]]

[[number]]

[[Name]]

[[number]]

Executive incident lead

[[Name]]

[[number]]

[[Name]]

[[number]]

Head of Information Security

[[Name]]

[[number]]

[[Name]]

[[number]]

IT service desk

[[Name]]

[[number]]

[[Name]]

[[number]]

Technical responders

[[Name]]

[[number]]

[[Name]]

[[number]]

Data Protection Officer

[[Name]]

[[number]]

[[Name]]

[[number]]

Legal

[[Name]]

[[number]]

[[Name]]

[[number]]

Communications lead

[[Name]]

[[number]]

[[Name]]

[[number]]

Board

[[Name]]

[[number]]

[[Name]]

[[number]]

Suppliers and outside help

Who

For

24/7 number

Account or contract reference

Managed IT service provider

Isolates networks and systems, rebuilds devices, restores from backup

[[number]]

[[reference]]

Security monitoring provider

Detects and alerts around the clock; supplies logs and analysis

[[number]]

[[reference]]

Backup service provider

Confirms backup integrity and supports restoration

[[number]]

[[reference]]

Cloud hosting provider

Protects and restores the hosted ordering platform

[[number]]

[[reference]]

Email and office software provider

Suspends accounts, removes mail rules and supplies mailbox audit logs

[[number]]

[[reference]]

[[Incident response retainer firm]]

Outside responders (see Resources)

[[number]]

[[reference]]

[[Outside counsel]]

Legal advice, including on extortion and sanctions

[[number]]

[[reference]]

Authorities, insurer and others we must tell

Who

Reports

Route

24/7 number

Our reference

[[CSIRT or competent authority]]

RD-01 early warning (NIS2)

RD-02 incident notification (NIS2)

RD-03 intermediate report (NIS2)

RD-04 final report (NIS2)

[[portal or address]]

[[24/7 number]]

[[our registration or policy number]]

[[lead supervisory authority]]

RD-06 notification to the supervisory authority (GDPR)

[[portal or address]]

[[24/7 number]]

[[our registration or policy number]]

[[financial competent authority]]

RD-10 initial notification (DORA)

RD-11 intermediate report (DORA)

RD-12 final report (DORA)

[[portal or address]]

[[24/7 number]]

[[our registration or policy number]]

[[customers with a notification clause]]

RD-14 notice to customers under contract (Contract)

[[portal or address]]

[[24/7 number]]

[[our registration or policy number]]

[[insurer or broker incident line]]

RD-15 notice to the cyber insurer (Insurance)

[[portal or address]]

[[24/7 number]]

[[our registration or policy number]]

[[national cybercrime reporting service]]

RD-16 crime report (Law enforcement)

[[portal or address]]

[[24/7 number]]

[[our registration or policy number]]

Yearly calendar

The plan stays ready only if these happen on time. Put each one in the owner's calendar.

When

Activity

Owner

Rule

At least once a year, in [[month]]

Exercise the plan: a tabletop exercise on a realistic scenario, with the crisis team and deputies; alternate the scenario year to year.

Head of Information Security

IM-12

Every quarter

Check every number in the contact directory, including deputies, suppliers, the retainer, the insurer and the authorities; call the 24/7 numbers.

Incident manager

IM-12

Every quarter

Report incidents by severity, reports made on time and overdue review actions to executive management.

Head of Information Security

IM-12

Every quarter

Review the quarter's Severity 3 and 4 incidents together, looking for repeated causes and for incidents that should have been rated higher.

Head of Information Security

IM-11

After every Severity 1 incident

Review this plan against what happened, and record the review in the revision history even if nothing changes.

Head of Information Security

IM-12

Every year, and at renewal

Check the retainer and the cyber insurance: cover, response times, notice periods and panel firms.

Executive incident lead

IM-12

When something changes

Update the plan and the directory when a role holder, a critical supplier, a regulated status or a core service changes.

Head of Information Security

IM-12

IM-12: “The plan must be exercised at least once a year and reviewed after every Severity 1 incident; incidents by severity, reports made on time and overdue review actions must be reported to executive management every quarter.”

Measures of success

The quarterly report to executive management shows four measures (IM-12). IMM-01 is also the board's measure of incidents.

Measure

What it counts

Target

EXAMPLE, Q3 2026

IMM-01 Significant incidents and time to contain

Incidents reported to an authority as significant (NIS2) or major (DORA) in the quarter, and for each the hours from detection to containment.

Each contained within [[24]] hours

1 significant incident; contained in 6 hours

IMM-02 Reports made on time

Reports to authorities and individuals made by their deadline, out of all that fell due in the quarter.

All

4 of 4

IMM-03 Review actions overdue

Open post-incident review actions past their due date.

None more than 30 days overdue

1 (PIA-04, 5 days)

IMM-04 Months since the plan was last exercised

Whole months from the last exercise of the plan (not a live incident) to the end of the quarter.

12 or fewer

6 months (last exercise 18 Mar 2026)

How the plan ran on 12 August 2026

EXAMPLE. The example organisation (a wholesale distributor with about 900 staff, three warehouses and an online ordering service that takes 60% of its orders) is an important entity under NIS2 in its Member State, and not a financial entity, so DORA's reporting duties do not apply. This is its ransomware incident, INC-2026-014, run against this plan. The security monitoring provider alerted on encryption activity on one office PC at Warehouse 2. It had spread to 14 office PCs on that site's office network before the site was cut off. Ordering and dispatch were not affected.

What happened, phase by phase

Time

From declaration

What happened

Who

Phase

12 Aug 2026, 07:50

35 minutes before

Monitoring alert: encryption activity on one office PC at Warehouse 2

Security monitoring provider (SUP-006)

Detect and report

12 Aug 2026, 08:05

20 minutes before

Triage starts (out of hours: within 60 minutes)

IT service desk

Triage and declare

12 Aug 2026, 08:25

Declaration

Declared Severity 1, category IC-01; reporting clocks start

Incident manager

Triage and declare

12 Aug 2026, 08:40

+15 minutes

Executive incident lead told

Incident manager

Triage and declare

12 Aug 2026, 08:55

+30 minutes

Decision: cut Warehouse 2's office network off from all other networks (the incident manager's decision; the executive incident lead agreed, as it stopped office work at the site)

Incident manager

Contain

12 Aug 2026, 09:10

+45 minutes

Warehouse 2 office network isolated

Managed IT provider (SUP-001)

Contain

12 Aug 2026, 09:20

+55 minutes

Crisis team convened

Executive incident lead

Contain

12 Aug 2026, 11:30

+3 hours 5 minutes

Reporting screen complete: NIS2 significant; GDPR breach to assess; DORA not applicable

Incident manager, Data Protection Officer

Triage and declare

12 Aug 2026, 11:45

+3 hours 20 minutes

Cyber insurer told

Executive incident lead

Contain

12 Aug 2026, 12:20

+3 hours 55 minutes

Board chair told

Executive incident lead

Contain

12 Aug 2026, 13:50

+5 hours 25 minutes

Contained: 14 PCs isolated, no activity on any other site

Incident manager

Contain

12 Aug 2026, 15:40

+7 hours 15 minutes

NIS2 early warning submitted

Incident manager

Contain

12 Aug 2026, 17:10

+8 hours 45 minutes

Crime reported

Legal

Contain

12 Aug 2026, 19:30

+11 hours 5 minutes

Eradicated: the phishing email removed from every mailbox, its sender and attachment blocked, and the affected user's and Warehouse 2 administrator passwords reset

Managed IT provider (SUP-001), email provider (SUP-005)

Eradicate

13 Aug 2026, 14:00

+1 day 5 hours

Office work resumes on rebuilt PCs; backups checked before restoring

Managed IT provider (SUP-001), backup provider (SUP-011)

Recover

14 Aug 2026, 10:00

+2 days 1 hour

GDPR assessment: unlikely to result in a risk; recorded, not notified

Data Protection Officer

Recover

14 Aug 2026, 14:00

+2 days 5 hours

NIS2 incident notification submitted

Incident manager

Recover

21 Aug 2026, 09:00

+9 days

Closed after 7 days' monitoring without recurrence

Incident manager

Recover

27 Aug 2026, 10:00

+15 days 1 hour

Post-incident review held

Head of Information Security

Review

11 Sep 2026, 12:00

+30 days 3 hours

NIS2 final report submitted

Incident manager

Review

Escalation against the plan's deadlines

The incident was declared Severity 1 at 12 Aug 2026, 08:25, category IC-01 (ransomware or destructive malware), so the Ransomware Response Playbook applied and every Severity 1 clock started.

Step

Deadline

Took

Result

Triage starts (IM-02)

60 minutes (out of hours) from report

15 minutes

Met, 45 minutes to spare

Declared (IM-02)

[[30]] minutes from start of triage

20 minutes

Met, 10 minutes to spare

Executive incident lead told (IM-05)

30 minutes from declaration

15 minutes

Met, 15 minutes to spare

Crisis team convened (IM-05)

1 hour from declaration

55 minutes

Met, 5 minutes to spare

Reporting screen complete (IM-06)

4 hours from declaration

3 hours 5 minutes

Met, 55 minutes to spare

Board chair told (IM-05)

4 hours from declaration

3 hours 55 minutes

Met, 5 minutes to spare

Contained (IMM-01)

[[24]] hours (target) from detection

6 hours

Met, 18 hours to spare

The incident manager decided to cut Warehouse 2's office network off 30 minutes after declaration, within the decision rights: isolating a site is the incident manager's decision. The executive incident lead was told and agreed, because it stopped office work at the site.

Reports against their deadlines

The reporting screen found: NIS2 — significant: capable of severe operational disruption; early warning, notification and final report made; GDPR — personal data breach (availability of shipping records on the PCs); restored from backup, no sign of data taken; unlikely to result in a risk, so recorded and not notified; DORA — not applicable: not a financial entity.

Report

Deadline

Made

Result

RD-01 NIS2 early warning

13 Aug 2026, 08:25

12 Aug 2026, 15:40

On time, 16 hours 45 minutes to spare

RD-02 NIS2 incident notification

15 Aug 2026, 08:25

14 Aug 2026, 14:00

On time, 18 hours 25 minutes to spare

RD-04 NIS2 final report

14 Sep 2026, 23:59

11 Sep 2026, 12:00

On time, 3 days 11 hours to spare

RD-06 GDPR notification to the supervisory authority

15 Aug 2026, 08:25

Not needed: decided 14 Aug 2026, 10:00

Decided 22 hours 25 minutes before the clock ran out; recorded in the breach record (RD-08)

RD-15 notice to the cyber insurer

[[as the policy requires, often within 48 hours]]

12 Aug 2026, 11:45

Insurer's incident line; its panel firm was not needed

RD-16 crime report

[[as soon as practical for suspected crime]]

12 Aug 2026, 17:10

Reported to [[the national cybercrime reporting service]]

Recovery, closure and review

  • Recovered: office work resumed on rebuilt PCs at 13 Aug 2026, 14:00, 1 day 5 hours after declaration, with backups checked before they were restored (IM-10). Ordering and dispatch never stopped.
  • Closed: 21 Aug 2026, 09:00, after 7 days 19 hours of monitoring without recurrence (the plan requires 7 days).
  • Reviewed: 27 Aug 2026, 4 working days after closure (IM-11 requires 10). Cause: a phishing attachment opened by a warehouse office user whose account had local administrator rights. That site's office network was not yet separated, so it spread to 14 PCs.

The review's actions, as at the end of the quarter:

Action

Owner

Due

Status

PIA-01 Remove local administrator rights from all office PCs

Head of IT

31 Oct 2026

In progress

PIA-02 Finish separating the warehouse networks from the office network at all three sites (P05 TA-04; two were still joined on 12 Aug)

Head of IT

11 Sep 2026

Done, 11 Sep 2026

PIA-03 Reassess the risk of ransomware spreading to warehouse systems (P05 R-04)

Head of Logistics

26 Aug 2026

Done, 20 Aug 2026

PIA-04 Add site isolation steps for each warehouse to the Ransomware Response Playbook

Information Security Manager

25 Sep 2026

Open

PIA-05 Give the monitoring provider's out-of-hours analysts a direct line to the incident manager

Head of Information Security

15 Sep 2026

Done, 10 Sep 2026

What changed in the plan: out-of-hours alerts now reach the incident manager directly (PIA-05), and the Ransomware Response Playbook is being given site isolation steps for each warehouse (PIA-04). IMM-03 counts the second as overdue.

Guidance — delete before approval

Keep this worked example until you have run the plan in an exercise of your own; then replace it with your own exercise or incident, with the same tables. The comparison with each deadline is what the board and the auditor look for.

Document

Relationship

Security Incident Management Policy

The rules IM-01 to IM-12 this plan carries out

Incident Classification, Severity & Escalation Matrix

Severity criteria, categories, escalation times and reporting clocks

Incident Triage & First-Hour Assessment Procedure

Triage and the first hour after declaration

Ransomware Response Playbook; Business Email Compromise Response Playbook; Personal Data Breach Response Playbook

The response to the categories that need their own steps

Incident Case & Action Log

The case log, decision log, evidence log and review actions

Incident Communications Template Set

The approved messages, CT-01 to CT-10

Post-Incident Review Template

The post-incident review

Incident Response Readiness Checklist

Whether the plan, the people and the tools are ready

Third-Party Security Policy; Supplier Contract Security Clause Library

Suppliers' part in the response (TP-10, CL-07, CL-11); Third-Party Security Risk Management pack

Information Security Risk Register

Where the risks an incident touches are reassessed (IM-11); Information Security Risk Management pack

[[Business continuity plan]]

[[Keeps services running and restores them; hands over to and from this plan]]

Approval and review

Approval record

Version

Approved by

Date

Evidence of approval

Next review by

[[1.0]]

[[Executive management]]

[[YYYY-MM-DD]]

[[e.g. minutes of meeting, reference and item]]

[[YYYY-MM-DD]]

Review. This plan is reviewed at least every 12 months, after every Severity 1 incident and after every exercise (IM-12), and when a role holder, a critical supplier, a regulated status or a core service changes. A review that changes nothing is still recorded in the revision history.

Distribution. Everyone with a role in the plan, and their deputies, has the current version online and offline. [[List who holds printed copies.]]

Adapting this template

Guidance — delete before approval

Small organisation: keep the seven phases and the reporting screen; shrink everything else. One person may be incident manager and Head of Information Security, and the crisis team may be three people, but the executive incident lead is someone else, usually the managing director. The resources can be modest: a messaging group on personal phones, a meeting room, the insurer's panel instead of a retainer. The yearly exercise can be a two-hour discussion around one scenario.

Regulated entity: an essential or important entity under NIS2 needs incident handling and crisis management among its measures (Article 21(2)(b) and (c)) and reports significant incidents on the RD-01 to RD-05 clocks (Article 23(4)). A financial entity under DORA reports major ICT-related incidents under DORA instead of NIS2 (NIS2 Article 4(1), DORA Article 1(2)): replace RD-01 to RD-05 with RD-10 initial notification (within 4 hours of classifying the incident as major, and no later than 24 hours after awareness; where it is classified as major only after those 24 hours, within 4 hours of that classification); RD-11 intermediate report (within 72 hours of the initial notification, and again when regular activities are recovered); RD-12 final report (no later than one month after the latest intermediate report); RD-13 notice to clients (without undue delay). DORA also expects the plan to assign roles for each incident type, set communication plans, and report major incidents to senior management and the management body (Article 17(3)); the roles, the crisis team and the communications sections do this. Use the reporting template of Implementing Regulation (EU) 2025/302 for all three reports.

IT run by a service provider: your managed IT provider and security monitoring provider are likely to be the service desk and most of the technical responders. Name their leads in the roles table and the directory, make sure their contracts carry the incident notification and cooperation clauses (CL-07, CL-11), and invite them to the yearly exercise. Declaration, severity, the reporting screen and every decision in the decision rights stay with your own people: an outsourced provider can advise and act, but it cannot decide or report for you.

Delete this section before approval.

Framework references

These references show where this document supports an external framework. They indicate relevance only and do not reproduce the text of any standard. Editions referenced: ISO/IEC 27001:2022 incl. Amd 1:2024; NIST CSF 2.0; Directive (EU) 2022/2555 (NIS2) and Implementing Regulation (EU) 2024/2690; Regulation (EU) 2016/679 (GDPR); Regulation (EU) 2022/2554 (DORA), Delegated Regulations (EU) 2024/1772 and 2025/301, Implementing Regulation (EU) 2025/302.

Framework

Reference

Supported by

ISO/IEC 27001:2022

Annex A 5.24 — Information security incident management planning and preparation

Whole plan: phases, roles, deputies, resources, contact directory and calendar

ISO/IEC 27001:2022

Annex A 5.25 — Assessment and decision on information security events

Triage and declare; severity at a glance

ISO/IEC 27001:2022

Annex A 5.26 — Response to information security incidents

Contain, eradicate and recover; decision rights

ISO/IEC 27001:2022

Annex A 5.27 — Learning from information security incidents

Review; the worked example's actions

ISO/IEC 27001:2022

Annex A 5.29 — Information security during disruption

The crisis team; recovery; the hand-over to the business continuity plan

ISO/IEC 27001:2022

Annex A 5.5 — Contact with authorities

Reporting duties; the authorities in the contact directory

NIST CSF 2.0

ID.IM-04 — “Incident response plans and other cybersecurity plans that affect operations are established, communicated, maintained, and improved”

Whole plan: established, communicated, reviewed after incidents and exercises

NIST CSF 2.0

RS.MA-01 — “The incident response plan is executed in coordination with relevant third parties once an incident is declared”

The phases, run with suppliers and outside responders

NIST CSF 2.0

RS.MA-04 — “Incidents are escalated or elevated as needed”

Severity at a glance: who is told, and how fast

NIST CSF 2.0

GV.SC-08 — “Relevant suppliers and other third parties are included in incident planning, response, and recovery activities”

Suppliers in an incident

NIST CSF 2.0

RC.RP-01 — “The recovery portion of the incident response plan is executed once initiated from the incident response process”

Recover phase

NIST CSF 2.0

RC.RP-03 — “The integrity of backups and other restoration assets is verified before using them for restoration”

Recovery criteria: backups checked before use

NIST CSF 2.0

RC.RP-06 — “The end of incident recovery is declared based on criteria, and incident-related documentation is completed”

Closure after the monitoring period

NIS2 — Directive (EU) 2022/2555

Article 21(2)(b) — the cybersecurity risk-management measures include “incident handling”

Whole plan

NIS2 — Directive (EU) 2022/2555

Article 21(2)(c) — “business continuity, such as backup management and disaster recovery, and crisis management”

The crisis team; recovery; regulated-entity tailoring

NIS2 — Directive (EU) 2022/2555

Article 23(4) — an early warning within 24 hours of becoming aware of a significant incident; an incident notification within 72 hours; an intermediate report on request; a final report not later than one month after the incident notification (or a progress report, then a final report within one month of handling, if still ongoing)

Reporting duties RD-01 to RD-04; the worked example's reports

GDPR — Regulation (EU) 2016/679

Article 33(1) — notify the supervisory authority “without undue delay and, where feasible, not later than 72 hours after having become aware of it”, unless the breach is unlikely to result in a risk to the rights and freedoms of natural persons; a later notification gives reasons for the delay

Reporting duty RD-06; the worked example's GDPR decision

NIS2 — Directive (EU) 2022/2555

Article 4(1) — where a sector-specific Union legal act requires entities to notify significant incidents with requirements at least equivalent in effect, the relevant provisions of NIS2 do not apply to those entities

Regulated-entity tailoring: DORA's reporting replaces NIS2's for financial entities

DORA — Regulation (EU) 2022/2554

Article 1(2) — for financial entities identified as essential or important entities under NIS2, DORA “shall be considered a sector-specific Union legal act for the purposes of Article 4” of NIS2

Regulated-entity tailoring: DORA is the sector-specific act for NIS2 Article 4

DORA — Regulation (EU) 2022/2554

Article 17(3) — early warning indicators; procedures to log, categorise and classify incidents; roles for each incident type; communication plans; reporting major incidents to senior management and the management body; response procedures

Roles, communications and escalation to the management body; regulated-entity tailoring

DORA — Regulation (EU) 2022/2554

Article 19(4) — an initial notification, an intermediate report, and a final report when the root cause analysis is complete and actual impact figures are available

Reporting duties RD-10 to RD-12; regulated-entity tailoring

DORA — Delegated Regulation (EU) 2025/301

Article 5 — initial notification within 4 hours of classifying the incident as major and no later than 24 hours after becoming aware of it; intermediate report within 72 hours of the initial notification; final report no later than one month after the latest intermediate report

The DORA clocks in the regulated-entity tailoring

DORA — Implementing Regulation (EU) 2025/302

Article 1 — the Annex I template is used for the initial notification, the intermediate report and the final report

Regulated-entity tailoring: the DORA reporting template

Definitions

Term

Meaning in this plan

Event

Something observed or reported that might affect the security of our information or services. Most events are not incidents.

Incident

An event, declared by the incident manager, that has compromised, or threatens to compromise, the availability, authenticity, integrity or confidentiality of our data or services, and needs a managed response.

Significant incident

NIS2's term: an incident that has caused or could cause severe operational disruption or financial loss to us, or considerable damage to others. Reported to the authority on NIS2's clock.

Major ICT-related incident

DORA's term, for financial entities only: an ICT-related incident with a high adverse impact on systems that support critical or important functions, as tested by Delegated Regulation (EU) 2024/1772.

Personal data breach

GDPR's term: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data.

Awareness

The moment the reporting clocks start: the time the incident is declared, as recorded in the case log, unless the record shows we had reasonable certainty earlier, in which case the earlier time.

Containment

The incident can no longer spread or cause new harm, even though systems may not yet be restored.

Closure

Recovery criteria met, the monitoring period passed without recurrence, and the case log complete.

Crisis team

The group that takes the business decisions in a Severity 1 incident, chaired by the executive incident lead.

Deputy

The named person who holds a role, with its authority, when the role holder cannot be reached.

Monitoring period

The 7 calendar days of closer watching after restoration, before a Severity 1 or 2 incident is closed.

Out-of-band

Communication that does not depend on the systems affected by the incident.

Playbook

The steps for one category of incident, written in this plan's phases: the Ransomware Response Playbook, Business Email Compromise Response Playbook and Personal Data Breach Response Playbook.

Reporting screen

The check of every reporting duty made within 4 hours of declaration (IM-06).

Retainer

A contract with an outside incident response firm that lets it start work within agreed hours, without a new contract.

War room

The place, physical or online, where the crisis team meets and works.

Prepared by Zero One Cybersecurity · Published by CISO Times

CISO Times Resource Licence — Internal Use