Incident Response Policy (RES-POL-001)

1. Objective

This policy establishes a comprehensive incident response framework for [Company Name] to effectively detect, respond to, contain, and recover from information security incidents. The policy ensures that security incidents are handled in a coordinated, timely, and effective manner to minimize impact on business operations, protect sensitive data, maintain regulatory compliance with SOC 2 requirements, and preserve evidence for potential legal proceedings.

2. Scope

This policy applies to all [Company Name] workforce members, contractors, third parties, and business associates who may detect, report, or respond to information security incidents. It encompasses all information systems, applications, networks, devices, and data owned, operated, or managed by [Company Name], including cloud services, mobile devices, and third-party systems. This policy covers all types of security incidents including data breaches, malware infections, unauthorized access, denial of service attacks, and physical security breaches.

3. Policy

[Company Name] maintains a formal incident response capability that enables rapid detection, assessment, containment, eradication, and recovery from security incidents while ensuring compliance with regulatory notification requirements.

3.1 Incident Response Framework

[Company Name] implements a structured incident response process based on industry best practices and regulatory requirements.

3.1.1 Incident Response Team

The IT Manager/Security Officer leads incident response activities with support from relevant personnel:

  • Incident Commander: IT Manager/Security Officer responsible for overall incident coordination
  • Technical Response: IT Department personnel for technical investigation and remediation
  • Communications: Designated personnel for internal and external communications
  • Legal/Compliance: Legal counsel and compliance officers for regulatory requirements
  • Business Continuity: Business unit leaders for operational impact assessment

3.1.1 Incident Response Lifecycle

The incident response process shall follow a systematic lifecycle approach based on the NIST Cybersecurity Framework (Prepare, Detect & Analyze, Contain/Eradicate/Recover, Post-Incident Activity).

1. Preparation:

  • Development and at least annual review of the Incident Response Plan (IRP).
  • Establishment and maintenance of a designated Incident Response Team (IRT) with clearly defined roles and responsibilities.
  • Annual training and simulation exercises (e.g., tabletop exercises) for the IRT to ensure readiness, with outcomes documented for improvement tracking.
  • Deployment and maintenance of tools and technologies mandated for incident detection, analysis, and response. 3.1.2 Incident Response Process

The incident response process follows a structured four-phase approach:

1. Preparation:

  • Maintenance of incident response procedures and contact information
  • Training and awareness for incident response team members
  • Regular testing of incident response capabilities with documented results

2. Detection and Analysis:

  • Continuous monitoring of information systems to detect security events
  • Initial triage to determine if a potential incident has occurred
  • Formal incident declaration and activation of the incident response team
  • Impact and severity assessment to classify the incident
  • Evidence collection and chain of custody documentation

3. Containment, Eradication, and Recovery:

  • Execution of containment strategies to prevent incident spread
  • Identification of root cause and all affected systems
  • Eradication of the threat (removing malware, disabling accounts, patching vulnerabilities)
  • Systematic recovery of affected systems from trusted sources
  • Validation that systems are clean before returning to production

4. Post-Incident Activity:

  • Incident documentation and reporting
  • Lessons learned analysis and improvement recommendations
  • Incident response plan updates
  • Stakeholder communication and follow-up

3.1.3 Incident Classification

All incidents are classified based on severity and potential impact:

Critical (P1) - Response within 15 minutes:

  • Confirmed data breach involving confidential data
  • Active compromise of critical systems affecting operations
  • Widespread malware infection or ransomware attack
  • Physical security breach affecting critical assets

High (P2) - Response within 1 hour:

  • Unauthorized access to sensitive systems or data
  • Malware infection on critical systems
  • Denial of service attacks affecting operations
  • Suspected insider threat activity

Medium (P3) - Response within 4 hours:

  • Unsuccessful attack attempts against critical systems
  • Malware infection on non-critical systems
  • Policy violations with potential security impact
  • Suspicious network activity or anomalous behavior

Low (P4) - Response within 24 hours:

  • Security policy violations without immediate risk
  • Failed login attempts within normal thresholds
  • Spam or phishing emails reported by users
  • Minor physical security issues

3.2 Incident Response Team

A designated Incident Response Team (IRT) shall be established with clearly defined roles and responsibilities.

3.2.1 Core Team Members

Incident Commander:

  • Overall incident response coordination and decision-making authority
  • Communication with executive leadership and external stakeholders
  • Resource allocation and escalation decisions
  • Post-incident review and improvement oversight

Security Analyst:

  • Technical investigation and analysis
  • Evidence collection and preservation
  • Malware analysis and threat intelligence gathering
  • System forensics and artifact examination

System Administrator:

  • System containment and isolation procedures
  • System restoration and recovery activities
  • Network security controls implementation
  • Infrastructure monitoring and maintenance

Legal Counsel:

  • Legal implications assessment and guidance
  • Law enforcement coordination and communication
  • Litigation hold and evidence preservation requirements
  • Regulatory compliance coordination
  • Regulatory notification and compliance support

Communications Lead:

  • Internal and external communication coordination
  • Media relations and public communications
  • Customer and stakeholder notification
  • Crisis communication management

3.2.2 Extended Team Members

3.2 Incident Detection and Reporting

Multiple detection methods are employed to identify potential security incidents as early as possible.

3.2.1 Detection Methods

Automated Detection:

  • Security monitoring system alerts and notifications
  • Intrusion detection and prevention system alerts
  • Antivirus and anti-malware system notifications
  • Network anomaly detection and behavioral analysis
  • File integrity monitoring and system change detection

Manual Detection:

  • Workforce member reports of suspicious activity
  • System administrator observation of anomalous behavior
  • Security team proactive monitoring activities
  • Third-party security service provider notifications
  • Customer or partner reports of potential compromise

3.2.2 Incident Reporting Procedures

Immediate Reporting Channels:

  • 24/7 security hotline: [Phone Number]
  • Email reporting: [Email Address]
  • Online incident reporting portal: [URL]
  • In-person reporting to IT Manager/Security Officer

Reporting Requirements:

  • All suspected incidents are reported within 2 hours of discovery
  • Initial reports may be verbal with written follow-up within 24 hours
  • Reports include all available information about the incident
  • Workforce members do not investigate incidents independently

3.3 Incident Response Procedures

Standardized procedures are followed for responding to different types of security incidents.

3.3.1 Initial Response Procedures

Incident Verification:

  • Confirm that a security incident has occurred
  • Gather initial information about scope and impact
  • Classify the incident according to established criteria
  • Activate appropriate incident response procedures
  • Notify relevant incident response team members

Evidence Preservation:

  • Preserve all relevant evidence in its original state
  • Maintain proper chain of custody documentation
  • Create forensic images of affected systems when appropriate
  • Secure physical evidence and access logs
  • Document all actions taken and decisions made
  • Maintain chain of custody for digital and physical evidence
  • Take system snapshots or images before making changes
  • Collect network traffic captures and log files

3.4.2 Containment Procedures

3.3.2 Containment Procedures

Short-term Containment:

  • Isolate affected systems from the network
  • Disable compromised user accounts and change passwords
  • Block malicious IP addresses and domains
  • Implement temporary firewall rules to prevent spread

Long-term Containment:

  • Rebuild compromised systems from clean backups
  • Apply security patches and configuration hardening
  • Conduct security validation before system restoration

3.3.3 Eradication and Recovery Procedures

Threat Eradication:

  • Remove malware and malicious artifacts from systems
  • Close security vulnerabilities that enabled the incident
  • Validate that all traces of compromise have been eliminated

System Recovery:

  • Restore systems and data from clean backups
  • Implement additional security monitoring and controls
  • Gradually restore full system functionality
  • Monitor systems for signs of compromise or instability

3.4 Regulatory and Legal Compliance

Incident response procedures ensure compliance with applicable legal and regulatory requirements.

3.4.1 Breach Notification Requirements

When incidents involve potential data breaches:

  • Determine whether incident constitutes a data breach under applicable laws
  • Assess the risk of harm to affected individuals
  • Document the breach assessment decision and rationale
  • Comply with applicable notification timelines and requirements
  • Coordinate with legal counsel for regulatory notifications

3.5 Communication and Coordination

Effective communication is maintained throughout the incident response process.

3.5.1 Internal Communications

  • Immediate notification to executive leadership for Critical incidents
  • Regular status updates throughout incident response
  • Final incident report with lessons learned and recommendations
  • Need-to-know basis for incident details

3.5.2 External Communications

  • Timely notification of customers potentially affected by incidents
  • Coordination with third-party service providers for response activities
  • Notification of business partners and vendors as required
  • Coordination with insurance carriers and coverage providers

3.6 Post-Incident Activities

Comprehensive post-incident activities ensure organizational learning and improvement.

3.6.1 Incident Documentation

Incident Report Contents:

  • Complete timeline of incident detection, response, and recovery
  • Root cause analysis and contributing factors
  • Impact assessment including affected systems and data
  • Response effectiveness evaluation and lessons learned
  • Recommendations for security improvements

3.6.2 Lessons Learned and Improvement

  • Formal review meeting within 2 weeks of incident closure
  • Analysis of response effectiveness and areas for improvement
  • Update incident response procedures based on lessons learned
  • Implement additional security controls to prevent similar incidents
  • Enhance monitoring and detection capabilities
  • Update business continuity and disaster recovery plans

4. Standards Compliance

This policy is designed to comply with and support the following industry standards and regulations.

Policy Section Standard/Framework Control Reference
All SOC 2 Trust Services Criteria CC7.1 - System Monitoring
3.4, 3.6 SOC 2 Trust Services Criteria CC7.2 - Controls Monitor Effectiveness
3.7 SOC 2 Trust Services Criteria CC2.1 - Communication and Information
All NIST Cybersecurity Framework RS.RP - Response Planning
3.4 NIST Cybersecurity Framework RS.CO - Communications
3.7 NIST Cybersecurity Framework RC.IM - Improvements

5. Definitions

Chain of Custody: Documentation of the chronological transfer of evidence from collection to presentation.

Incident Commander: Individual with overall authority and responsibility for incident response coordination.

Incident Response Team (IRT): Designated group of individuals responsible for detecting, responding to, and recovering from security incidents.

Indicators of Compromise (IOCs): Artifacts observed on networks or operating systems that indicate computer intrusion.

Mean Time to Detection (MTTD): Average time between when an incident occurs and when it is detected.

Mean Time to Recovery (MTTR): Average time to restore normal operations after an incident.

Security Incident: Any event that could result in unauthorized access to, disclosure, modification, or destruction of information assets.

6. Responsibilities

|Role|Responsibility| |—|—| |IT Manager/Security Officer|Lead incident response activities, coordinate team communications, ensure regulatory compliance, and approve major response decisions.| |IT Security Team|Detect and analyze security incidents, perform technical investigations, implement containment measures, and conduct system recovery.| |Legal Counsel|Provide legal guidance, coordinate law enforcement relations, manage litigation holds, and ensure regulatory compliance.| |System Administrators|Implement technical containment measures, perform system restoration, maintain evidence integrity, and support forensic activities.| |All Workforce Members|Report suspected incidents promptly, cooperate with investigations, follow incident response procedures, and participate in post-incident training.|

4. Standards and Controls

This policy maps to the following regulatory and compliance frameworks:

Section Framework Control
3.1 SOC 2 Trust Services Criteria CC7.4 - Response to System Disruptions
3.2 SOC 2 Trust Services Criteria CC7.1 - System Monitoring
3.3 SOC 2 Trust Services Criteria CC7.2 - System Monitoring
3.4 SOC 2 Trust Services Criteria CC1.4 - Regulatory Compliance

5. Definitions

Incident: Any actual or suspected compromise of information security that may result in unauthorized access, use, disclosure, modification, or destruction of information.

Incident Commander: Individual responsible for overall coordination and management of incident response activities.

Incident Response Team: Group of individuals responsible for responding to information security incidents.

Threat Actor: Individual or group responsible for an incident or attack against an organization.

6. Responsibilities

Role Responsibility
IT Manager/Security Officer Lead incident response activities, coordinate team communications, ensure regulatory compliance, and approve major response decisions.
IT Security Team Detect and analyze security incidents, perform technical investigations, implement containment measures, and conduct system recovery.
Legal Counsel Provide legal guidance, coordinate law enforcement relations, manage litigation holds, and ensure regulatory compliance.
System Administrators Implement technical containment measures, perform system restoration, maintain evidence integrity, and support forensic activities.
All Workforce Members Report suspected incidents promptly, cooperate with investigations, follow incident response procedures, and participate in post-incident training.