Incident Response Playbook
Boston, MA

Note: These preventive measures should be reviewed quarterly and updated based on evolving threat landscapes and regulatory changes. 

Initial Response Directions

When a cybersecurity incident is suspected or confirmed, taking the right immediate steps is critical to preserve data, prevent further damage, and support investigation and recovery efforts. The following steps should be taken as soon as the incident is detected:

Step-by-Step Initial Response

Note: These directions should be printed and readily accessible at all critical workstations, network closets, and by all key personnel.

Following these precautions helps preserve forensic integrity, reduce liability, and streamline recovery. 

Phases of Response

A structured response is essential to minimizing the impact of a cybersecurity incident and restoring normal operations. Attain Technology’s incident response process is divided into six distinct phases, each serving a critical purpose in the overall strategy:

Roles and Responsibilities Overview 

To ensure a fully aligned and compliant response effort, a company must proactively coordinate with its cyber insurance stakeholders. 

Pre-Incident Coordination 

• A meeting should be held with both the Insurance Carrier and Insurance Agent to review this Incident Response Plan in full. 
• The goal is to gain their buy-in, verify that all recovery and investigation procedures are within the scope of the policy, and secure pre-approval for any preferred forensic vendors or IR response teams. 
• All feedback or required changes to align with the insurance contract should be reviewed, approved, and documented by the Legal and Compliance Liaison and the Executive Sponsor. 

This coordination should be revisited annually or anytime the cyber insurance policy changes. 

A clearly defined chain of command and division of duties ensures a coordinated and efficient response to any cybersecurity incident. Below is an outline of the primary roles involved in a company’s incident response efforts: 

Roles and Responsibilities Directory

In the event of a cybersecurity incident, a company may be subject to mandatory reporting requirements imposed by regulatory authorities, contractual agreements, or government contracts. It is critical to identify and act upon these obligations swiftly to ensure compliance and avoid legal or financial penalties.

Key considerations include:

• Government Contracts: Many federal, state, or local contracts include clauses that require immediate or time-bound incident reporting to specified government agencies or contract officers.
• Industry-Specific Regulations: Depending on the sector, organizations may be subject to specific cybersecurity incident reporting mandates such as those under HIPAA, GLBA, DFARS, CMMC, or others.
• Client and Vendor Agreements: Contractual obligations may require notification of clients, vendors, or third-party stakeholders within a defined timeframe.
• Insurance Notification Windows: Timely notification to the cyber insurance provider is often a requirement of coverage.

All reporting obligations must be clearly documented, with contacts, deadlines, and procedures outlined and maintained in the Compliance Register. The Legal and Compliance Liaison is responsible for ensuring all relevant notifications are completed appropriately.

Action Required:

Review all existing contracts and regulatory commitments and update this plan with a list of required notifications, associated timelines, and responsible parties.

Mandated Notification Requirements Form

Use the following table to track and maintain generic notification requirements. This form should be reviewed and updated regularly by the Legal and Compliance Liaison:

Note: This section must be reviewed and updated after each major change to the backup system or vendor.

Communication Guidelines 

During any cybersecurity incident, it is imperative that consistent and legally sound terminology is used. All internal staff, contractors, and vendors must refer to such events solely as “incidents“. The use of terms such as “breach” or “compromise” is strictly prohibited unless explicitly authorized by legal counsel or the executive team. 

Only the Communications Officer is authorized to speak with the media, external stakeholders, or regulatory bodies. This includes both official and unofficial statements or comments regarding the incident. No other employee, contractor, or vendor shall provide public commentary or formal notification without written approval from the executive leadership. 

If clients or vendors inquire about the situation, all personnel should respond with a consistent, approved statement such as: 

“We’re currently looking into an incident, and as soon as there’s an update, we’ll make sure you’re informed. We appreciate your patience and understanding.” 

This policy ensures unified messaging, minimizes legal risk, and supports compliance with all contractual and regulatory requirements. 

 

Sample Form

[Insert description] | [Insert time] | [Insert contact or agency] | [Insert contact info] | [Insert notes] 

Ransom Payment Considerations

In the event of a ransomware incident, carefully evaluate whether to engage with threat actors or consider ransom payment. While paying a ransom may appear to offer a quick path to recovery, it introduces legal, ethical, and operational risks.

Key Considerations:

• Legal Restrictions: Some jurisdictions prohibit or heavily regulate ransom payments. Payments to sanctioned entities can carry severe penalties.
• Insurance Requirements: The cyber insurance provider must be notified prior to any consideration of payment. They may have requirements or limitations that impact this decision.
• Law Enforcement Notification: Contacting law enforcement or cybercrime units is recommended and may be required by policy.
• Data Recovery Alternatives: Confirm that all recovery options have been explored, including restoring from backups.
• Intellectual Property Exposure: Evaluate the risk of critical business information, trade secrets, or proprietary systems being sold or leaked. Threat actors may threaten to release or monetize intellectual property (IP) publicly to create pressure. Consider the potential long-term damage to competitive advantage, regulatory obligations, and trust.
• Third-Party Harassment: Be aware that threat actors have been known to extract client and vendor contact lists and pressure external stakeholders by threatening them or publicly releasing stolen data to force a ransom payment. This tactic can escalate reputational damage and add additional external pressure to respond.
• Reputation and Precedent: Paying a ransom can encourage future targeting and may harm your organization’s reputation.
• Likelihood of Data Return: There is no guarantee that payment will result in data decryption or deletion.

The final decision should involve executive leadership, legal counsel, the insurance carrier, and law enforcement, with clear documentation of the rationale and risk analysis.

Incident Lifecycle Timeline (Industry Averages)

Understanding the average timeline of a cybersecurity incident can help set realistic expectations and guide planning. The following are typical phases and durations observed across industries:

Note: Timelines vary based on preparedness, tools, staff availability, and attacker sophistication. Organizations with mature incident response programs may accelerate this timeline significantly.

Severity Classification Matrix

Establishing clear severity levels ensures appropriate prioritization and response for each incident type. The following matrix outlines standard classification tiers:

Note: All incidents must be documented and escalated according to these classifications.

Incident Logging and Tracking Template

Maintaining detailed logs during an incident is critical for accountability, forensics, and post-incident review. The table below should be used throughout the lifecycle of an incident:

Regulatory and Compliance Mapping

Certain regulations and contracts require formal incident reporting. This section maps key frameworks to incident response obligations:

Note: Legal and Compliance Liaison must verify requirements based on industry, location, and contract terms.

Tabletop Exercise Template

Simulated incident drills help assess readiness and refine procedures. Use the template below to plan and execute tabletop exercises:

Exercises should be held at least annually and whenever major system or policy changes occur.

Financial Impact Assessment Worksheet

This worksheet can be used to estimate and record the direct and indirect costs of an incident:

“Please ensure a current copy of the organization’s Cyber Insurance Policy is attached to this document, along with any other supporting materials.”

Disclaimer

This document is intended to serve as a general guide for establishing and managing a cybersecurity incident response process. It does not constitute legal advice or a formal representation of any insurance carrier. Users of this document should consult their own legal counsel and insurance representatives to ensure that all strategies, procedures, and terminology are aligned with applicable laws, regulations, and policy requirements. 

Attain Technology Inc. assumes no liability for the use or implementation of this document without such independent review and professional guidance. 

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