Cybersecurity Policy Template
Incident Response Policy
1. Introduction
1.1 Purpose and Scope: This Incident Response Policy (IRP) outlines the procedures for identifying, responding to, and recovering from Information and Communications Technology (ICT) incidents that threaten the confidentiality, integrity, and availability (CIA triad) of organizational data and systems. This policy applies to all employees, contractors, and third-party vendors with access to organizational ICT systems and data. The scope encompasses all types of ICT incidents, including but not limited to security breaches, system failures, malware infections, denial-of-service attacks, and data loss events.
1.2 Relevance to DORA: This IRP is crucial for achieving compliance with the Digital Operational Resilience Act (DORA). DORA mandates robust incident management capabilities to ensure the resilience of ICT systems supporting financial services. This policy directly addresses DORA's requirements related to incident reporting, recovery time objectives (RTOs), recovery point objectives (RPOs), and the establishment of effective incident management processes. It contributes to achieving DORA's goals by minimizing disruption, enhancing operational resilience, and ensuring business continuity.
2. Key Components
This Incident Response Policy includes the following key components:
Incident Definition and Classification: Defining what constitutes an incident and establishing a classification system for prioritizing responses.
Incident Reporting Procedures: Procedures for reporting incidents, including reporting channels, escalation paths, and required information.
Incident Handling Procedures: A step-by-step guide for managing incidents, including containment, eradication, recovery, and post-incident activity.
Roles and Responsibilities: Clearly defined roles and responsibilities for individuals and teams involved in incident response.
Communication Plan: A plan for communicating with stakeholders during and after an incident.
Recovery Strategies and Objectives: Defining RTOs and RPOs for critical systems and data.
Testing and Training: Regular testing and training exercises to ensure preparedness and effectiveness.
Post-Incident Review: A process for reviewing incidents to identify lessons learned and improve future responses.
3. Detailed Content
3.1 Incident Definition and Classification:
In-depth explanation: An incident is any event that disrupts or threatens to disrupt the normal operation of ICT systems, data, or services. Incidents are classified based on severity (e.g., low, medium, high, critical) and impact (e.g., financial, reputational, operational). A classification matrix should be developed.
Best practices: Use a standardized classification scheme that aligns with industry best practices (e.g., NIST Cybersecurity Framework). Consider factors like impact, urgency, and likelihood when classifying.
Example: A low-severity incident might be a minor service outage affecting a non-critical application, while a critical incident could be a ransomware attack that encrypts sensitive customer data.
Common pitfalls: Failing to define incidents clearly, leading to inconsistent responses. Not having a standardized classification system, leading to prioritization issues.
3.2 Incident Reporting Procedures:
In-depth explanation: This section outlines how and to whom incidents should be reported. It includes contact information for the security incident response team (SIRT) or equivalent, reporting channels (e.g., phone, email, ticketing system), and required information (e.g., date, time, description, impact, affected systems).
Best practices: Establish multiple reporting channels to ensure accessibility. Use a secure incident reporting system. Provide clear guidance on what constitutes a reportable incident.
Example: An employee discovers a phishing email. They immediately report it through the company's security ticketing system, providing a screenshot of the email and its headers.
Common pitfalls: Lack of clear reporting procedures, leading to delays in incident response. Using insecure communication channels for reporting.
3.3 Incident Handling Procedures:
In-depth explanation: This outlines the steps to take when responding to an incident. This will often follow the following stages: Preparation, Identification, Containment, Eradication, Recovery, and Post-incident Activity. Each stage includes detailed tasks and responsibilities.
Best practices: Use a well-defined incident response lifecycle model. Document all actions taken during the incident response. Ensure regular updates to stakeholders.
Example: A Distributed Denial of Service (DDoS) attack targets the company website. The SIRT follows the established procedure: contains the attack by engaging with the internet service provider (ISP), eradicates the attack vector, recovers the website from backups, and reviews the incident to identify vulnerabilities and preventative measures.
Common pitfalls: Lack of a structured incident handling process. Insufficient resources dedicated to incident response. Inadequate documentation of actions taken.
3.4 Roles and Responsibilities:
In-depth explanation: This section clearly defines the roles and responsibilities of individuals and teams involved in incident response, including the SIRT, IT Operations, Legal, Communications, and Business Units. RACI matrix (Responsible, Accountable, Consulted, Informed) can be used.
Best practices: Assign clear roles and responsibilities with well-defined authorities. Provide regular training to personnel.
Example: The SIRT is responsible for leading the incident response, IT Operations is responsible for restoring systems, and Legal is responsible for ensuring compliance with regulations.
Common pitfalls: Unclear or overlapping responsibilities. Lack of training and awareness among personnel.
3.5 Communication Plan:
In-depth explanation: This outlines how information will be communicated during and after an incident. It includes communication channels (e.g., email, phone, SMS), target audiences (e.g., employees, customers, regulators), and communication messages.
Best practices: Establish a communication escalation path. Use a centralized communication system. Ensure timely and accurate communication.
Example: During a data breach, the Communications team issues a press release to inform the public, while the SIRT updates affected employees through internal communications.
Common pitfalls: Inconsistent or delayed communication. Failure to communicate effectively with stakeholders.
3.6 Recovery Strategies and Objectives:
In-depth explanation: This section defines the RTOs and RPOs for critical systems and data. It outlines recovery strategies, including backups, disaster recovery plans, and business continuity plans.
Best practices: Establish realistic RTOs and RPOs based on business impact analysis. Regularly test recovery plans.
Example: The RTO for the company's online banking system is 4 hours, and the RPO is 24 hours. A disaster recovery plan is in place to ensure business continuity in the event of a major outage.
Common pitfalls: Unrealistic RTOs and RPOs. Inadequate recovery plans.
3.7 Testing and Training:
In-depth explanation: This describes the regular testing and training exercises that will be conducted to ensure the effectiveness of the incident response plan. Tabletop exercises, simulations, and drills will be performed.
Best practices: Conduct regular tests and drills to validate the plan. Provide training to personnel on incident response procedures.
Example: Annual tabletop exercises are conducted to simulate various incident scenarios. Employees receive regular training on security awareness and incident reporting.
Common pitfalls: Infrequent testing and training. Lack of realistic scenarios in training exercises.
3.8 Post-Incident Review:
In-depth explanation: This section outlines the process for reviewing incidents to identify lessons learned and improve future responses.
Best practices: Conduct a thorough post-incident review within a defined timeframe. Document findings and recommendations. Implement improvements based on lessons learned.
Example: After a ransomware attack, a post-incident review identifies vulnerabilities in the network security and recommends improvements to security controls.
Common pitfalls: Failing to conduct post-incident reviews. Not implementing improvements based on lessons learned.
4. Implementation Guidelines
1. Establish the SIRT: Define roles, responsibilities, and membership.
2. Develop and document procedures: Create detailed procedures for each component of the IRP.
3. Communicate the policy: Disseminate the policy to all relevant personnel.
4. Conduct training: Provide training on incident reporting and response procedures.
5. Test the plan: Conduct regular testing and drills.
6. Review and update: Regularly review and update the policy based on lessons learned and changes in the threat landscape.
5. Monitoring and Review
The effectiveness of this IRP will be monitored through:
Incident reports: Regular review of incident reports to track trends and identify areas for improvement.
Testing results: Analysis of testing results to assess the effectiveness of the response procedures.
Feedback from personnel: Gathering feedback from personnel involved in incident response.
The policy will be reviewed and updated annually or as needed, based on changes in regulations, technology, or organizational structure.
6. Related Documents
Data Breach Response Plan
Business Continuity Plan
Disaster Recovery Plan
Security Awareness Training Program
Acceptable Use Policy
7. Compliance Considerations
This IRP directly addresses DORA requirements related to:
Incident reporting: The policy establishes clear procedures for reporting ICT incidents.
Recovery time objectives (RTOs): The policy defines RTOs for critical systems.
Recovery point objectives (RPOs): The policy defines RPOs for critical data.
Incident management: The policy provides a comprehensive framework for managing ICT incidents.
This policy must also comply with relevant legal and regulatory requirements, such as GDPR and national data protection laws, depending on the organization's location and the type of data processed. Failure to comply with DORA and related regulations can result in significant penalties. Legal counsel should be consulted to ensure full compliance.
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