If you got hacked tomorrow, do you have a basic plan: who calls who, what’s your IT/IR contact, who tells customers?
Demonstrate that the organization has documented, assigned, and tested incident response procedures including internal escalation contacts, external incident response resources, and customer notification protocols.
Description
What this control does
This control ensures the organization maintains a documented incident response plan that defines roles, responsibilities, and communication protocols for cybersecurity incidents. The plan must specify who initiates the response, escalation paths to IT and incident response teams, and procedures for notifying affected customers, regulators, and other stakeholders. A functional incident response plan reduces response time, limits damage, ensures legal compliance with breach notification laws, and maintains stakeholder trust during security events.
Control objective
What auditing this proves
Demonstrate that the organization has documented, assigned, and tested incident response procedures including internal escalation contacts, external incident response resources, and customer notification protocols.
Associated risks
Risks this control addresses
- Delayed incident detection and containment due to unclear escalation procedures, allowing attackers prolonged access to systems and data
- Failure to notify customers within legally mandated timeframes (e.g., GDPR 72-hour requirement), resulting in regulatory fines and legal liability
- Inconsistent or unauthorized public communications during a breach, causing reputational damage and loss of customer confidence
- Critical response personnel unavailable or unreachable due to outdated contact information, extending incident duration
- Evidence spoliation or improper forensic handling due to untrained staff taking ad-hoc response actions without guidance
- Ransomware spread across the environment while teams debate who has authority to isolate systems or engage external IR firms
- Regulatory non-compliance with sector-specific requirements (HIPAA, PCI-DSS, state breach laws) due to missing notification procedures
Testing procedure
How an auditor verifies this control
- Request and review the current incident response plan document, noting version date, approval signatures, and distribution list
- Verify the plan explicitly identifies incident response team members by name, role, and current contact information (phone, email, alternate channels)
- Confirm the plan includes documented escalation paths from initial detection through executive leadership and specifies decision-making authority for containment actions
- Identify and verify documented contact information for external incident response retainers, forensics firms, legal counsel, and cyber insurance carriers
- Review customer notification procedures for completeness, including trigger criteria, approval workflows, communication templates, and timeline requirements aligned with applicable breach notification laws
- Interview at least two personnel named in the plan to confirm they are aware of their roles and can locate the plan documentation when needed
- Examine records of incident response plan testing or tabletop exercises conducted within the past 12 months, including participant lists and lessons learned
- Validate the plan addresses after-hours and weekend incident scenarios with clearly defined on-call responsibilities or third-party monitoring arrangements