Legal

5.5 INCIDENT RESPONSE PLAN

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Effective Date: August 15, 2026


1. PURPOSE & SCOPE

1.1. Purpose.

The purpose of this Incident Response Plan (IRP) is to provide a structured approach for detecting, containing, analyzing, and recovering from security incidents. The primary goals are to:

  • Minimize damage to the Platform and Customer Data.

  • Preserve forensic evidence for investigation.

  • Ensure timely communication with stakeholders and regulators.

  • Restore Platform Integrity rapidly.

1.2. Scope.

This plan applies to all confirmed or suspected security incidents affecting the Company’s infrastructure, data, software, or personnel. It covers cyberattacks (e.g., SQL Injection, Ransomware), insider threats, and physical security breaches at hosting facilities.

1.3. Standard Alignment.

This framework follows the NIST SP 800-61 Computer Security Incident Handling Guide lifecycle: Preparation → Detection & Analysis → Containment, Eradication, & Recovery → Post-Incident Activity.

1.4. Reporting Channels.

Security incidents may be reported internally or by external researchers via the Company’s designated security contact channel (security@yourdomain.com).

2. SEVERITY CLASSIFICATION

Incidents are classified to determine resource allocation and notification timelines. Severity levels represent internal response targets and may vary depending on the scope and complexity of the incident.

  • SEV-1: CRITICAL (Crisis)

  • Definition: Confirmed data breach (PII/Financial), active ransomware, complete loss of control, or critical production outage caused by an attack.

  • Response: Immediate mobilization of Crisis Team. 24/7 Operations. Executive & Legal notified immediately.

  • SEV-2: HIGH (Emergency)

  • Definition: Critical vulnerability exploit, loss of redundancy, compromise of administrator credentials, or targeted attack with high potential impact.

  • Response: Response within 1 Hour. Incident Commander assigned.

  • SEV-3: MEDIUM (Warning)

  • Definition: Suspicious activity, multiple failed login attempts, policy violations, or minor malware confined to a single endpoint.

  • Response: Response within 24 Hours. Handled by Security Engineering.

  • SEV-4: LOW (Informational)

  • Definition: Automated scanner probes, non-critical bugs, or false positives.

  • Response: Reviewed during standard business hours.

3. ROLES & RESPONSIBILITIES

  • Incident Commander (IC): The technical lead with primary authority over the operational response. The IC directs the remediation and approves containment measures (e.g., shutting down the API).

  • Scribe: Responsible for maintaining a timestamped log of all actions, commands, and discoveries (crucial for legal protection and audit trails).

  • Executive Liaison: Manages communication with Legal, Customers, and Regulators, allowing the IC to focus strictly on technical resolution.

4. INCIDENT LIFECYCLE (The NIST Loop)

4.1. Detection & Analysis.

  • Sources: Alerts from centralized logging, IDS/IPS, WAF, or reports from the Security Contact.

  • Triage: The on-call engineer validates the alert to rule out false positives and assigns a Severity Level.

4.2. Containment (Stop the Bleeding).

  • Short-Term: Isolate affected systems (e.g., disconnect network interfaces, block IP ranges, revoke API tokens).

  • System Integrity: The Incident Commander is authorized to sever connections or shut down services if necessary to preserve Platform Integrity, even if it causes a temporary service outage.

  • Evidence: Before wiping or reimaging any system, a forensic image (snapshot) is preserved to maintain the chain of custody. Forensic artifacts are retained in accordance with the Company’s evidence retention requirements to support potential legal, regulatory, or law enforcement investigations.

4.3. Eradication & Recovery.

  • Eradication: Remove malware, patch vulnerabilities, delete compromised accounts, and rotate all relevant credentials. Access to critical recovery systems is performed via controlled "Break Glass" procedures with full audit logging.

  • Recovery: Restore systems from clean backups (referencing Document 5.3 Disaster Recovery). Systems are monitored closely for re-infection before returning to full production status.

4.4. Post-Incident Activity.

  • Post-Mortem: A blameless "Root Cause Analysis" (RCA) is conducted within 72 hours of resolution.

  • Report: A formal incident report is generated, detailing the timeline, root cause, and corrective actions (CAP).

5.1. Regulatory Notification (GDPR/CCPA).

In the event of a confirmed Personal Data Breach, the Company commits to notifying the competent Supervisory Authority within 72 hours of becoming aware of the breach, unless the breach is unlikely to result in a risk to the rights and freedoms of natural persons.

5.2. Customer Notification.

If Customer Data has been compromised, the Company will notify affected customers without undue delay (typically within 48 hours of confirmation or as required by DPA) via email to the designated administrative contact.

  • Content: The notice will describe the nature of the breach, the data involved, and the measures taken to mitigate the risk.

6. TESTING & TRAINING

  • Drills: The Company conducts at least one Tabletop Exercise annually to simulate a SEV-1 incident and test communication flows.

  • Onboarding: All technical personnel receive Incident Response training during onboarding.