The chances of your organization being the victim of a data breach is now up to 1 in 4.
In 2021 alone, we’ve seen a pileup of data breaches and privacy incidents across industries and businesses. These frontpage headlines have increased consumer anxiety about the collection of their personal data. More tangible consequences have come from enforcement actions and fines.
Although a data breach can seem inevitable, surprisingly most organizations aren’t thinking about how they’re going to handle incidents when they do arise.
Ask any company that’s experienced a data breach and you’ll get a feel for the moment-by-moment challenges of this kind of event. You have to execute the required tasks within the required timeline to remain in compliance with regulations. Locating, coordinating, and communicating with all the appropriate stakeholders — security, IT, logistics, marketing, and executives — can be the biggest roadblock to achieving this compliance.
To avoid this worst-case-scenario, a modern privacy leader should automate as much of the response as possible. You can do this by preparing an incident management playbook.
Creating an Incident Management Playbook
Having a plan of attack ready for when a data breach strikes is essential.
An incident management playbook will be your data breach training guide and incident response checklist. It should cover every type of incident your organization could face, what team members will be responsible for what tasks, and steps that meet notification requirements for all applicable jurisdictions and regulations.
Essentially, an incident management playbook is an actionable guide for how to report events, define responsibilities, and manage response procedures. You’ll use it to:
- See a clear incident status view across your organization.
- Create and execute deep regulatory, research-backed responses to data breaches.
- Automate investigation steps through the set up of custom workflows.
- Track risks and incidents to create a full audit trail.
- Link data maps and vendors to incidents to see affected data.
To see the most benefit from an incident management playbook, privacy leaders should cover six steps in it. This will allow you to manage a crisis in a timely, coordinated, and all-inclusive manner.
Step 1: Prepare
The first step is to prepare for a data breach by establishing an Incident Response Team (IRT). This section of the incident response playbook should define roles, objectives, and goals for each IRT member. Also outline response plans and timelines for specific types of incidents. The goal of this section is to help your IRT understand each other’s responsibilities and obligations when an event occurs.
Step 2: Investigate
The second section of your incident response playbook covers the first steps your IRT will take once an incident occurs. This section includes determining what types of data were involved, validating the information provided, and identifying if personal data was overlooked. At this stage of the response, you’ll also need to ascertain the jurisdictions and sectoral laws affected. If other teams or individuals need to be involved in the resolution, now is the time to route incidents to them.
Step 3: Assess
Once the IRT determines if information at risk is protected by jurisdictional or sectoral laws, the assessment step of the incident response playbook goes into effect. This section includes categorizing the incident’s severity level and deciding on a remediation plan. At this point, you’ll also want to notify the appropriate individuals, regulatory bodies, customers, and vendors.
Step 4: Remediate
You’ve chosen a remediation plan. In this step of the incident response playbook, it’s time to execute that plan. Your remediation plan should involve a relevant containment strategy to limit damage to organizational resources. At this time in the incident response, collect all evidence to preserve it in case criminal activity is involved. Track electronic evidence in a documented and repeatable process. As the last part of this step, perform technical analysis to see what went wrong to cause the incident.
Step 5: Notify
The last step to resolve the incident is to notify the affected parties. In this part of the incident response playbook, include a communication and disclosure strategy for both external audiences and internal stakeholders. Create templates the IRT can use to quickly craft communication and reports for external organizations and agencies.
Step 6: Understand lessons learned
An incident response playbook is a living document. After an incident, it needs to be updated with any new processes or procedures based on experience. The last step of an incident response is to perform a post-mortem. Determine the root cause of the incident and identify any tactics that would have improved decision making and response time.
Conclusion: Privacy Incident Response in Half the Time
Incident response remains the cornerstone of privacy management. An incident response playbook can help your organization reduce risk and fulfill legal obligations with a consistent, reliable, and automated plan.
A risk assessment platform can also cut the time it takes your IRT to respond to an incident in half. Technology like this enables your team to make accurate and timely notification decisions amid an increasingly complex data breach landscape.
OneTrust Security Incident Management is designed to centrally manage incidents, automate tasks, and keep records for compliance and notification. Paired with OneTrust DataGuidance Research, you can build context-aware, automated workflows to react to incidents based on the regulations for each jurisdiction. These tools help privacy leaders bridge the gap between privacy and security by automating incident notifications and storing the audit trails needed for compliance.
