Incident Response Policy - PrivionGRC Security Documentation

Document Information

Company: PrivionGRC, Inc.
Effective Date: October 17, 2025
Version: 1.0
Policy Owner: Matt Fishman, CEO
Review Frequency: Annual

Emergency Contact

Email: security@priviongrc.com
Phone: [Emergency Number]
24/7 Hotline: Available

1. Purpose

This policy establishes procedures for detecting, responding to, and recovering from security incidents to minimize impact on business operations and customer data while meeting regulatory notification requirements.

2. Scope

This policy applies to all security incidents affecting:

Information systems and applications
Customer data and personal information
Business operations and services
Intellectual property and trade secrets
Employees, contractors, and vendors

3. Incident Definition

A security incident is any event that:

Compromises confidentiality, integrity, or availability of data or systems
Violates security policies or acceptable use policies
Poses a threat to business operations
Requires investigation or response action

Examples:

Data breach (unauthorized access to customer data)
Malware infection (ransomware, virus, trojan)
Unauthorized access (compromised accounts)
Denial of service (DDoS attack)
Lost or stolen devices containing sensitive data
Insider threat (malicious or accidental)
System compromise (hacked server, unauthorized changes)
Physical security breach
Social engineering attack (phishing, pretexting)

NOT Security Incidents:

Failed login due to forgotten password (unless pattern indicates attack)
Routine system maintenance or planned downtime
User error without security impact
False positive alerts from security tools

4. Incident Severity Classification

Severity 1 - CRITICAL

Impact:

Severe harm to customers, company, or operations

Examples:

Large-scale customer data breach (>1,000 records)
Ransomware affecting production systems
Complete system outage (>4 hours)
Confirmed unauthorized access to RESTRICTED data
Active ongoing attack

Response Requirements:

Response Time: Immediate (within 15 minutes)
Escalation: CTO, CEO immediately notified
Communication: Customer notification may be required

Severity 2 - HIGH

Impact:

Significant harm to customers, company, or operations

Examples:

Small-scale customer data breach (<1,000 records)
Compromised administrator account
Malware on employee device (not production)
Partial system outage (1-4 hours)
Suspected unauthorized access to CONFIDENTIAL data

Response Requirements:

Response Time: Within 1 hour
Escalation: CTO notified within 1 hour
Communication: Internal stakeholders notified

Severity 3 - MEDIUM

Impact:

Moderate harm or potential for escalation

Examples:

Successful phishing attack (credentials disclosed)
Lost/stolen device with encrypted data
Minor system vulnerability discovered
Policy violation (password sharing)
Suspicious activity (under investigation)

Response Requirements:

Response Time: Within 4 hours
Escalation: Security Officer/IT Manager notified
Communication: Incident team only

Severity 4 - LOW

Impact:

Minimal harm, informational

Examples:

Failed phishing attempt (reported by employee)
Vulnerability scan findings (low-risk)
Suspicious email (investigated, false alarm)
Minor policy violation (corrected)

Response Requirements:

Response Time: Within 24 hours
Escalation: IT team handles
Communication: Optional

5. Incident Response Team

5.1 Core Team

Role	Responsibility	On-Call
Incident Commander	Overall coordination, decisions	CTO
Security Lead	Technical investigation, containment	Security Officer/Lead Developer
Communications Lead	Internal/external communications	CEO/COO
Legal Counsel	Regulatory obligations, liability	External Counsel
Customer Success	Customer impact assessment, support	CS Manager

5.2 Extended Team (as needed)

Development Team (system expertise)
Infrastructure Team (cloud/network)
HR (insider threats, employee communications)
Public Relations (media inquiries)
External Forensics (major breaches)

5.3 Contact Information

Primary Contacts:

CTO (Incident Commander): [Phone], [Email]
Security Officer: [Phone], [Email]
CEO: [Phone], [Email]

Emergency Contacts:

24/7 Emergency Hotline: [Phone Number]
Incident Reporting Email: security-incidents@priviongrc.com

6. Incident Response Process

Phase 1: DETECTION & REPORTING

How incidents are detected:

Automated security alerts (monitoring, IDS/IPS)
User reports (employees, customers)
Threat intelligence feeds
Audit log reviews
Third-party notifications (vendors, researchers)

Reporting Process:

Discover incident → Report immediately
Report to: security-incidents@priviongrc.com or call 24/7 hotline
Provide details:
- What happened?
- When was it discovered?
- What systems/data affected?
- Is it still ongoing?
- Who else knows?

DO NOT:

Try to investigate alone
Delete evidence
Power off systems (unless actively destructive)
Notify customers/public (wait for IR team)
Discuss on social media or public forums

Phase 2: TRIAGE & ASSESSMENT (15 min - 1 hour)

Incident Commander actions:

Assess severity (Critical, High, Medium, Low)
Activate incident response team
Establish incident war room (Slack channel, Zoom bridge)
Assign roles (investigation, containment, communications)
Begin incident log (timeline, actions, findings)

Initial Assessment Questions:

What data/systems are affected?
How many customers impacted?
Is incident still active?
What is the attack vector?
Are backups available?
What is the business impact?

Immediate Actions:

Preserve evidence (logs, snapshots, memory dumps)
Isolate affected systems (if safe to do so)
Reset compromised credentials
Block malicious IP addresses
Notify insurance carrier (if applicable)

Phase 3: CONTAINMENT (1-24 hours)

Goals:

Stop the incident from spreading
Prevent further damage
Maintain business operations (if possible)

Short-Term Containment:

Isolate affected systems (network segmentation, disable accounts)
Block attacker access (firewall rules, password resets)
Deploy security patches (if vulnerability exploitation)
Enable enhanced monitoring (detailed logging)

Long-Term Containment:

Build clean systems in parallel
Plan for system recovery
Implement temporary workarounds for business continuity
Strengthen defenses (WAF rules, rate limiting)

Evidence Preservation:

Take system snapshots/images
Export relevant logs before rotation
Document all actions taken
Chain of custody for forensic evidence

Phase 4: ERADICATION (2-48 hours)

Goals:

Remove threat completely
Fix root cause
Prevent recurrence

Actions:

Remove malware/backdoors
Patch vulnerabilities
Close security gaps
Rebuild compromised systems from clean backups
Reset all potentially compromised credentials
Review and update security controls

Verification:

Scan systems for residual malware
Review logs for suspicious activity
Test security controls
Confirm no persistence mechanisms remain

Phase 5: RECOVERY (2-72 hours)

Goals:

Restore normal operations
Validate systems are clean
Monitor for recurrence

Actions:

Restore systems from clean backups (if needed)
Gradually restore services (critical first)
Enhanced monitoring for 30 days post-incident
User communication (system availability)
Performance validation

Recovery Checklist:

Systems rebuilt/patched
Data restored and validated
Credentials reset
Security controls verified
Monitoring enabled
Backups tested
Business operations normal
Customer communication sent (if required)

Phase 6: POST-INCIDENT REVIEW (Within 7 days)

Lessons Learned Meeting:

What happened? (timeline, root cause)
What worked well?
What could be improved?
What are the action items?
Who owns each action item?
What is the deadline?

Incident Report Contents:

Executive Summary
Timeline of events
Root cause analysis
Impact assessment (customers, data, downtime)
Response effectiveness
Regulatory notifications required
Corrective actions
Preventive measures
Cost analysis

7. Communication Protocols

7.1 Internal Communications

During Incident:

Use dedicated Slack channel: #incident-response-[ID]
Status updates every 2 hours (Critical), every 4 hours (High)
Restrict information to need-to-know basis
Document all decisions and actions

Stakeholder Updates:

Executive team: Real-time for Critical, hourly for High
All employees: After containment (if broad impact)
Board of Directors: Critical incidents within 24 hours

7.2 Customer Communications

When to Notify:

Customer data breach (GDPR 72 hours, state laws vary)
Service outage >4 hours
Security incident affecting customer systems
Credentials compromised

Communication Channels:

Email (primary)
In-app notifications
Status page updates
Support portal announcements

7.3 Regulatory Notifications

GDPR Data Breach (EU customers):

Notify supervisory authority within 72 hours if high risk
Notify data subjects "without undue delay" if high risk to rights
Document reasons if notification not made

State Breach Notification Laws (US):

Varies by state (45+ states have breach notification laws)
Generally "without unreasonable delay"
Some states require notification within 30-90 days
May require notification to state Attorney General if >500 residents

Other Notifications:

SEC (if publicly traded): Material incidents within 4 business days
Insurance carrier: Per policy requirements
Law enforcement: If criminal activity suspected

9. Special Incident Types

9.1 Ransomware

DO:

Isolate infected systems immediately
Preserve forensic evidence
Assess backup availability
Contact law enforcement (FBI)
Engage incident response firm (if needed)

DON'T:

Pay ransom without exhausting all options
Power off systems (may lose volatile evidence)
Restore from backups before eradication

9.2 Data Breach

Immediate Actions:

Determine scope (what data, how many records)
Confirm unauthorized access (vs. potential access)
Legal counsel consultation
Regulatory notification assessment
Credit monitoring (if SSN/financial data)

9.3 Insider Threat

Immediate Actions:

Preserve evidence (logs, files, emails)
Disable user access
HR involvement
Legal counsel consultation
Review privileged access logs

DON'T:

Confront employee before evidence secured
Tip off employee (secure evidence first)

9.4 Lost/Stolen Device

Immediate Actions:

Remote wipe device (if possible)
Disable user accounts
Assess data exposure (encrypted?)
File police report
Insurance claim (if applicable)

10. Tabletop Exercises

Exercise Details

Frequency: Annually (minimum)
Scenarios:
- Ransomware attack
- Customer data breach
- Compromised administrator account
- DDoS attack
- Insider threat

Participants

Incident Response Team
Executive management
Key personnel from each department

Deliverables

Exercise report
Lessons learned
Updated procedures
Training needs identified

11. Tools and Resources

Incident Response Tools

Incident tracking: [Jira, ServiceNow, or spreadsheet]
Communication: Slack #incident-response-[ID]
Forensics: [Forensic toolkit, if available]
Log analysis: [Supabase logs, Netlify logs]

External Resources

Incident response firm: [Name/Contact]
Legal counsel: [Name/Contact]
Cyber insurance: [Provider/Policy Number]
Law enforcement: FBI IC3, local police

Documentation

Incident response runbooks (system-specific procedures)
Contact lists (updated quarterly)
Communication templates
Regulatory notification requirements

13. Related Policies

Information Security Policy
Data Classification and Handling Policy
Access Control Policy
Business Continuity and Disaster Recovery Policy
Communication Policy

Emergency Contact Information

24/7 Emergency Hotline

[PHONE NUMBER]

Security Incidents Email

mfishman@priviongrc.com

For questions regarding this policy, contact:
Matt Fishman, CEO: mfishman@priviongrc.com
San Diego, CA