Read to learn about incident response plan basics, including how to develop and implement your incident response plan.
This post contains the text from the White Paper: How to Effectively Manage a Data Breach. Download the PDF.
You can’t afford to be unprepared for a data breach’s aftermath. Even organizations with the strictest data security and IT policies could easily go the way of recent victims. (Victims like Hilton Hotels, Home Depot, and Anthem).
It’s up to you to control the situation and protect your brand in the wake of a data breach’s potentially devastating hold on reputation. The following 5 steps will help you successfully stop information from being stolen, mitigate further damage, and restore operations as quickly as possible.
Set your incident response plan into motion immediately after learning about a suspected data breach.
A business typically learns they’ve been breached in one of four ways:
If you suspect a data breach, here’s your objective: stop information from being stolen and repair your systems so a breach won’t happen again. This begins by executing your incident response plan (IRP).
A well-executed incident response plan can minimize breach impact, reduce fines, decrease negative press, and help you get back to business more quickly. In an ideal world, you should already have an incident response plan prepared and employees trained to quickly deal with a data breach situation.
For some reason, however, most businesses SecurityMetrics has investigated that have been breached didn’t have an incident response plan at the time of the incursion. With no plan, employees scramble to figure out what they’re supposed to do, and that’s when big mistakes are made. (e.g., wiping a system without first creating images of the compromised systems to learn what occurred and to avoid re-infection).
When an organization becomes aware of a possible breach, it’s understandable to want to fix it immediately. However, without taking the proper steps and involving the right people, you could inadvertently destroy valuable forensic data used by investigators to determine how and when the breach occurred, and what to recommend in order to properly secure the network against the current attack or similar future attacks.
When you discover a breach, remember:
Your first priority at this point in time is to isolate the affected system(s) to prevent further damage until your forensic investigator can walk you through the more complex and long-term containment.
A data breach is a crisis that must be managed through teamwork. Assemble your incident response team immediately. (Hopefully you’ve already met and discussed roles during crisis practices and initiated your incident response plan.)
Your team should include a team leader, lead investigator, communications leader, C-suite representative, office administrator, human resources, IT, attorney, public relations, and breach response experts. Each brings a unique side to the table with a specific responsibility to manage the crisis.
Proper communication is critical to successfully managing a data breach, and a key function of the incident response team is to determine how and when notifications will be made.
Several states have legislated mandatory time frames that dictate when a merchant must make notifications to potentially affected cardholders. You should be aware of the particular laws in your state and have instructions in your incident response plan that outline how you will make mandated notifications.
Identify in advance the person within your organization (perhaps your inside legal counsel, newly hired breach management firm, C-level executive, etc.) that is responsible for ensuring the notifications are made timely and fulfill your state’s specific requirements. Your public response to the data breach will be judged heavily, so think this through.
Your customers will discover if you keep important breach information from them. If the media marks your brand untrustworthy for withholding information, that label could end up hurting you worse than the other effects of the data breach. Some companies fall into the, “Let’s make sure we know exactly what’s going on before we say anything at all” trap, but excessive delays in releasing a statement may be seen as an attempted cover-up.
Providing some information is usually better than saying nothing at all. You can always provide updated statements as needed on your website. In all cases regarding public statements, seek the guidance of your legal counsel.
Poorly informed employees can often circulate rumors—true or not. As a team, establish your media policy that governs who is allowed to speak to the media. Designate a spokesperson and ensure employees understand they are not authorized to speak about the breach.
Depending on your particular circumstances, you may find it beneficial to withhold from the rank and file employees the fact that your company has suffered data breach until shortly before any public statements are made.
Disclosures of the breach both within the company and to the public should be in accordance with advice from your legal counsel.
Your incident response team should craft specific statements that target the various audiences, including a holding statement, press release, customer statement, and internal/employee statement. These should be communicated to appropriate parties that could potentially be affected by the breach, such as third party contractors, stockholders, law enforcement, and ultimately cardholders.
Your statements should nip issues in the bud by addressing questions like:
Explain that you are committed to solving the issue and protecting your customer’s information and interests. Where you deem appropriate, you could offer an official apology and perhaps other forms of assistance such as one year of free credit monitoring.
Management of a data breach doesn’t end with your public statement. Now comes the hardest part: investigating and fixing everything. Luckily, you’re not alone. Your PFI will perform the majority of the investigation and then provide recommendations on how to repair your environment to ensure this doesn’t happen again.
After the cause of the breach has been identified and eradicated, you need to ensure all systems have been hardened, patched, replaced, and tested before you consider re-introducing the previously compromised systems back into your production environment. During this process, ask yourself these questions:
Obviously, the financial examples presented below will change based on: your size, how many customer cards were stolen, how hackers got into your organization, if you were willfully aware of your vulnerabilities, whether you have breach protection services etc. Data breaches have serious financial consequences.
If breached, you may only be liable for a few of these fines, or you could be expected to pay even more than listed below. It all depends on the size of your breach. Along with possible legal fines, federal/municipal fines, increased monthly card processing fees, you may have to pay for the following:
A key part of a successful breach response is what you learned from the breach. After the dust has settled, assemble your incident response team once again to review the events in preparation for the next attack. Incorporate the lessons you’ve learned and ask, “How can we improve the process next time?” And then revise your incident response plan. Don’t forget to communicate your commitment to data security to the media, even after you’ve repaired the damage.
If you don’t have an incident response plan, making one should be a top priority. Then practice and review your plan. Without annual desktop run-throughs and simulation trainings, your staff will panic in the face of a data breach.
Suffering a data breach is one of the most stressful situations a business owner or organization can endure, but it doesn’t have to be the end of your business. Greet it with a solid and practiced incident response plan to avoid significant brand damage.
We help customers close security and compliance gaps to avoid data breaches. Our forensic, penetration testing, and audit teams identify best security practices and simplify compliance mandates (PCI DSS, HIPAA, HITRUST, GDPR). As an Approved Scanning Vendor, Qualified Security Assessor, Certified Forensic Investigator, we have tested over 1 million systems for security.
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