AuditRubric
rs-co-2 high Respond / Incident Response Reporting and Communication

Internal and external stakeholders are notified of incidents in a timely manner

Incident communication is an obligation, not an option. Internally, stakeholders need to know what is happening so they can make decisions, redirect resources, and prepare for operational disruption. Externally, customers, regulators, and partners may have legal rights to timely notification. Organizations that fail to notify in time, or notify inconsistently, compound a technical incident into a legal and reputational one.

Estimated effort: 4h
incident-communicationbreach-notificationregulatorystakeholdersgdpr

Implementation steps

  1. 1

    Define internal notification requirements by incident severity

    Document who must be notified internally for each incident severity level: a low-severity event may only require the security team, a high-severity event may require the CISO and department heads, and a critical event may require executive notification including the CEO and board. Define the time frame for each notification. Internal notifications should happen early enough that leadership is not surprised by news from external sources.

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  2. 2

    Map data types and incident categories to external notification requirements

    Build a reference mapping data types to their regulatory notification requirements and time frames: GDPR requires notification to the supervisory authority within 72 hours of becoming aware of a breach; HIPAA requires notification to the HHS and affected individuals; PCI DSS requires notification to your acquiring bank and card brands. Know which requirements apply to your organization before an incident occurs so that legal review time is available in an incident, not instead of it.

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  3. 3

    Pre-draft communication templates for common incident types

    Writing external communications during an active incident under time pressure leads to errors and omissions. Pre-draft notification templates for the most likely incident types: credential compromise, data breach, service disruption. Templates should have blanks for specific details but provide the structure, tone, and required elements. Have legal review templates in advance so the approval process during an incident is faster.

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Evidence required

Incident notification policy and procedures

A documented policy defining notification requirements by severity and data type.

  • · Incident response policy section defining internal notification requirements
  • · Regulatory notification requirement matrix mapping data types to obligations
  • · Communication plan in the incident response plan with stakeholder lists

Notification records from past incidents

Evidence that notifications were sent in accordance with defined requirements.

  • · Incident ticket history showing notification timestamps
  • · Regulatory notification letter from a past breach
  • · Internal incident communication records showing escalation timeline

Related controls