Read to learn about incident response plan basics and how to best develop and implement your incident response plan.
This post contains the text from the White Paper: How to Make and Implement a Successful Incident Response Plan.
You need to have a current incident response plan that is ready to go if your organization ever gets breached.
When it comes to making an incident response plan, it can get a little overwhelming. In this white paper, you will learn about incident response plan basics, how to best develop and implement your incident response plan, and what should be included in your incident response plan.
Unfortunately, nearly every organization will experience system attacks, with some of these attacks breaching organization’s security.
If breached, you may only be liable for a few of the following fines, or you could be expected to pay even more than listed below. It depends on a number of factors. Along with possible legal fines, federal/municipal fines, increased monthly card processing fees, you may have to pay for the following:
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 and if you’re following PCI DSS requirements, you should already have an incident response plan prepared and employees trained to quickly deal with a data breach situation.
But if there is no plan, employees scramble to figure out what they’re supposed to do, and that’s when big mistakes can occur. For example, if employees wipe a system without first creating images of the compromised systems, this can prevent you from learning what happened and what you can do to avoid re-infection.
Set your incident response plan into motion immediately after learning of a suspected data breach.
An incident response plan should be set up to address a suspected data breach in a series of phases with specific needs to be addressed. The incident response phases are:
Preparation often takes the most effort in your incident response planning, but it’s by far the most crucial phase to protect your organization. This phase includes the following steps:
Identification (or detection) is the process where you determine whether you’ve actually been breached by looking for deviations from normal operations and activities.
An organization normally learns they’ve been breached in one of four ways:
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 can inadvertently destroy valuable forensic data. Forensic investigators use this data to determine how and when the breach occurred, as well as devising a plan to prevent similar future attacks.
When you discover a breach, remember:
After containing the incident, you need to find and eliminate policies, procedures, or technology that led to the breach. This means all malware should be securely removed, systems should again be hardened and patched, and updates should be applied.
Whether you or a third party do this, you need to be thorough. If any trace of malware or security issues remain in your systems, you may still be losing sensitive data, with your liability increasing.
Recovering from a data breach is the process of restoring and returning affected systems and devices back into your business environment. During this time, it’s important to get your systems and business operations up and running again without the fear of another breach.
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.
After the forensic investigation, meet with all incident response team members and discuss what you’ve learned from the data breach, reviewing the events in preparation for the next attack.
This is where you will analyze everything about the breach. Determine what worked well and what didn’t in your response plan. Then revise your incident response plan.
You can’t afford to be unprepared for a data breach’s aftermath. It’s up to you to control the situation and protect your brand in the wake of a data breach’s potentially devastating effect on your reputation.
Developing and implementing an incident response plan will help your business handle a data breach quickly and efficiently while minimizing the damage.
Start off by identifying and documenting where your organizations keeps its crucial data assets. You need to assess what would cause your organization to suffer heavy losses if it were stolen or damaged.
After identifying critical assets, prioritize them according to importance and highest risk, quantifying your asset values. This will help justify your security budget and show executives what needs to be protected and why it’s essential to do so.
Determine what risks and attacks are the greatest current threats against your systems. Keep in mind that these will be different for every organization.
For organizations that process data online, improper coding could be their biggest risk. For a brick-and-mortar organization that offers WiFi for their customers, their biggest risk may be Internet access. Other organizations may place a higher focus on ensuring physical security, while others may focus on securing their remote access applications.
Here are examples of a few possible risks:
Top failed vulnerabilities discovered by SecurityMetrics vulnerability scans:
If you don’t have established procedures to follow, a panicked employee may make detrimental security blunders that could damage your organization. Your data breach policies and procedures should include:
Over time, you might need to adjust your policies according to your organization’s needs. Some organizations might require a more robust notification and communications plan, while others might need help from outside resources. However, all organizations need to focus on employee training (e.g., your security policies and procedures).
You need to organize an incident response team that coordinates your organization’s actions after discovering a data breach. Your team’s goal should be to coordinate resources during a security incident to minimize impact and restore operations as quickly as possible.
Some of the necessary team roles are:
Make sure your response team covers all aspects of your organization, and that they understand their particular roles in the plan. Each will bring a unique perspective to the table with a specific responsibility
to manage the crisis.
Your incident response team won’t be effective without proper support and resources to follow your plan.
Security is not a bottom-up process. Management at the highest level (e.g., CEO, VP, CTO) must understand that security policies–like your incident response plan–must be implemented from the top and be pushed down. This is true for organizations from mom and pop shops to enterprise organizations.
For enterprise organizations, executive members need to be on board with your incident response team. For smaller organizations, management needs to be fine with additional funding and resources dedicated to incident response.
When presenting your incident response plan, focus on how your plan will benefit your organization (e.g., financial and brand benefits). For example, if you experience a data breach and poorly manage the incident, your company’s reputation will likely receive irreparable brand damage.
The better your goals are presented, the easier it will be to obtain necessary funding to create, practice and execute your incident response plan.
Just having an incident response plan isn’t enough. Employees need to be properly trained on your incident response plan and know what they’re expected to do after a data breach.
Employees also need to understand their role in maintaining company security. To help them, employees should know how to identify attacks such as phishing emails, spear phishing attacks, and social engineering efforts.
Test your employees through tabletop exercises (i.e., simulated, real-world situation led by a facilitator). While tabletop exercises require time and money, they play a vital role in your staff’s preparation for a data breach. These tabletop exercises help familiarize your employees with their particular incident response roles by testing them through a potential hacking scenario.
After testing your employees, you can identify and address weaknesses in the incident response plan and help everyone involved see where they can improve, with no actual risk to your organization’s assets.
The regular routine of work makes it easy for employees to forget crucial security information learned during trainings.
Creating an incident response plan can seem overwhelming. To help, develop your incident response plan in smaller, manageable procedures.
While every organization will need varying policies, training, and documents, there are a few itemized response lists that most organizations need to include in their incident response plans, such as:
Proper communication is critical to successfully managing a data breach, which is why you need to document a thorough emergency contact/communications list. This list should contain information about: who to contact, how to reach these contacts, when it’s the appropriate time to reach out, and what you need to say.
In this list, you should document everyone that needs to be contacted in the event of a data breach, such as the following individuals:
You need to determine how and when notifications will be made. Several states have legislated mandatory time frames that dictate when an organization must make notifications to potentially affected cardholders (and law enforcement). You should be aware of the laws in your state and have instructions in your incident response plan that outline how you will make mandated notifications.
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. For example, you should have pre-prepared emails and talking points ready to go after a data breach.
Your statements should address questions like:
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 system backup and recovery processes list will help you deal with the technical aspects of a data breach. Here are some things that should be included:
This list helps you preserve any compromised data, quickly handle a data breach, and preserve your systems through backups. By creating and implementing this list, your organization can lessen further data loss and help you to return to normal operations as quickly as possible.
A forensics analysis list is for organizations that use in-house forensic investigations resources. Your forensic team will need to know where to look for irregular behavior and have access to system security and event logs. You might need multiple lists based on your different operating systems and functionalities (e.g., server, database).
Your forensic team may need the following tools:
However, if your organization doesn’t have access to an experienced computer forensic examiner in-house, you will want to consider hiring a forensics firm, first vetting them with in advance with pre-completed agreements. This vetting process helps ensure you get an experienced forensic investigator when you need it.
Your jumpbag list is for grab-and-go responses (i.e., when you need to respond to a breach quickly). This list should include overall responses and actions employees need to take immediately after a breach. Your list will keep your plan organized and prevents mistakes caused by panic.
Some things to include in your jumpbag list are:
Your security policy review list deals with your response to a breach and its aftermath. This list helps you analyze the breach, helping you know what you can learn and change afterwards.
Your security policy review list should include documentation of the following things:
You should look at where your security controls failed, and how to improve them. The purpose of this list is to document the entire incident, what was done, what worked, what didn’t, and what was learned.
An incident response plan is only useful if it is properly established and followed by employees. To help staff, regularly test their reactions through real-life simulations or what’s known as tabletop exercises. Tabletop exercises allow employees to learn about and practice their incident response roles when nothing is at stake, which can help you discover gaps in your incident response plan (e.g., communication issues).
In a discussion-based table exercise, you and your staff discuss response roles in hypothetical situations.
A discussion-based tabletop exercise is a great starting point because it doesn’t require extensive preparation or resources, while still testing your team’s response to real-life scenarios without risk to your organization. However, this exercise can’t fully test your incident response plan or your team’s response roles.
In a simulation exercise, your team tests their incident responses through a live walk-through test that has been highly choreographed and planned.
This exercise allows participants to experience how events actually happen, helping your team better understand their roles. However, simulation exercises can require a lot of time to plan and coordinate, while still not fully testing your team’s capabilities.
In parallel testing, your incident response team actually tests their incident response roles in a test environment.
Parallel testing is the most realistic simulation possible and provides your team with the best feedback about their roles. However, parallel testing is more expensive and requires more time planning than other exercise because you need to simulate an actual production environment (e.g., systems, networks).
Before conducting a tabletop exercise, determine your organization’s needs by asking:
Next, design your tabletop exercise around an incident response plan topic or section that you want tested. Identify any desired learning objectives or outcomes. From there, create and coordinate with your tabletop exercise staff (e.g., facilitator, participants, and data collector) to schedule your tabletop exercise.
When designing your tabletop exercise, prepare the following exercise information:
After conducting a tabletop exercise, set up a debrief meeting to discuss response successes and weaknesses. Your team’s input will help you know where and how to make necessary revisions to your incident response plan and training processes.
If you don’t already have an incident response plan, making one should be a top priority. Next, regularly practice and review your plan. Without regular tabletop exercises and simulation trainings, your staff may make poor decisions which may make beach impact worse.
A data breach can be an organization’s most stressful situation it handles, but it doesn’t have to be the end of your organization. By following your incident response plan, you can avoid significant brand damage.
It’s important to discover the breach quickly, identify where it’s coming from, and pinpoint what it has affected.
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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