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Best Practices for Building an Incident Response Plan (2/5)
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Incident Response Planning - Hitachi Systems Security
Posted on Tuesday, March 20th, 2018 by

Incident Response Planning in a Nutshell: Best Practices

 

“Failing to plan is like planning to fail.” – Alan Lakein

As part of our 5-part series about Incident Response Planning (IRP), this article dives deeper into several best practices to keep in mind when building an Incident Response Plan. Incident Response Planning has proven to be an effective strategy for organizations to:

  • handle cybersecurity incidents,
  • minimize their impact if they occur, and
  • strengthen their defenses against future incidents.

 

Part 1/5: The 5 Benefits of an Incident Response Plan

Part 3/5: Incident Response Team: Roles and Responsibilities 

Past 4/5: Data Breach Notification Laws: Canada, U.S. & Europe

Part 5/5: Lessons Learned: The Unsung Hero of the Incident Response Planning Process

 

Note: This 5-part blog series was developed to help organizations understand what IRP is, what they should consider when implementing IRP, and how they can leverage IRP to secure themselves against cyberthreats.

 

  • Incident Response Plans are written and documented.

While it is important that organizations talk about how to prepare for, handle and recover from a potential security incident, best practices recommend developing an IRP in writing.

According to the SANS Institute, documenting the Incident Response Plan is especially necessary as it can be a “substantial lifesaver when it comes to incident response”, both for evidence retention purposes in case of legal action as well as for lessons learned exercises to improve incident response capabilities going forward.

Some legislations impose retention time even for expired policies, so make sure to find out about what’s required in your industry and legislation prior to implementing an IRP.

The security rule of the Health Insurance Portability and Accountability Act (HIPAA) of 1996, for example, requires that entities maintain written security policies and procedures and written records of required actions, activities and assessments until six years after the later of the date of their creation or last effective date, see 45 C.F.R. § 164.316.

 

  • Incident Response Plans are battled-tested.

According to the Best Practices for Victim Response and Reporting of Cyber Incidents issued by the U.S. Department of Justice, regular exercises must be conducted to guarantee the suitability of the IRP, the accessibility of necessary lines of communication as well as the understanding of assigned individuals of their respective roles and responsibilities.

Battle-testing an IRP means assessing the sufficiency of the dedicated technical and human resources to address the latest cyber threats. It should verify whether the organization has acquired or has access to the necessary technology and services, even if it requires outsourcing some or most of the IRP.

Note that testing may be required by law.

The American Federal Information Security Management Act of 2002 [FISMA], for instance, requires that all federal agencies conduct “periodic testing and evaluation of the effectiveness of information security policies, procedures, and practices, to be performed with a frequency depending on risk, but no less than annually”.

Federal agencies must have an annual independent evaluation of their programs and practices – a standard that large corporations may seek to endorse as well.

 

  • Incident Response Plans evolve over time.

Given that IRPs are battle-tested and reviewed frequently, they should be modified in a consequent manner as to reflect the conclusions of these exercises or changes in the threat landscapes.

As a general rule, IRPs need to be robust enough to withstand frequent organizational changes as a company grows and flexible enough to be applicable to a variety of different scenarios.

NIST Special Publication 800-61 (‘Computer Security Incident Handling Guide’) and the Payment Card Industry Data Security Standard [PCI-DSS] recommend reviewing the plan annually.

Applicable standards depend on compliance, jurisdiction and sectoral activity. The Information & Privacy Commissioner of British Columbia, for example, recommended that a University should review their privacy and security policies at least every three years.

To ensure accountability and adherence to regular review schedules, the IRP should also identify the person responsible for annual or periodic reviews.

 

  • Incident Response Plans are implemented as a business practice.

IRPs need to be synchronized with other business functions, practices and policies that are relevant, such as those regarding insider threats or human resources.

When it comes to corporate policy management, organizations that develop their plans and policies as standalone documents in informational silos run the risk of disrupting alignments, create conflict and sacrifice the organization’s effectiveness, efficiency, and agility.

In the same way, the depth and complexity of an Incident Response Plan will largely depend on the size of the organization.

  • Fortune 500 companies, for instance, will likely have an extensive Incident Response Plan with a variety of different roles on the incident response team, including:
    • the legal counsel
    • public relations and communications
    • IT operations
    • executive management
    • human resources and so on.
  • Smaller to medium-sized organizations, on the other hand, tend to have rather short Incident Response Plan with a minimum of 2 different roles on their incident response team:
    • a technical resource able to fix issues
    • a decision maker with the necessary authority to respond to the incident and take appropriate decisions.

 

  • Incident Response Plans are actionable.

In the words of Pablo Picasso, “action is the foundational key to all success”.

The same principle applies to Incident Response Plans, which need to be actionable to be effective and relevant to an organization’s success. This implies two underlying assumptions:

  • IRPs are drafted in a precise and goal-oriented manner, as to cover the practical steps, decisions and actions that must be taken in case of a cybersecurity incident, including but not limited to the prioritization of assets, the preservation of data for forensic purposes and the clarification of decisional rights.
  • All employees must familiarize themselves with the IRP. In that sense, employees who are likely to play an actual role in the event of a security incident should receive training for this particular purpose. For example, the PCI DSS compliance standard requires that personnel be trained and acknowledge their understanding of the security policies and procedures upon hire and at least annually.

 

In a Nutshell

There is no doubt that security incidents against organizations are here to stay. And sooner than later, we’ll all need to live up to the fact that careful incident planning and preparation is one of the best strategies to respond to security incidents.

For Incident Response Plans to be effective, they must be written and documented, tested in battle, flexible enough to evolve over time, in alignment with the organization’s context and business practices and actionable. If your organization is planning to implement an IRP or review an IRP that’s currently in place, make sure to keep these best practices in mind.

Now that we’ve learned about the best practices of Incident Response Planning, what roles and responsibilities should be established within an IRP?

 


To learn more about how to better protect your organization and respond to cyberattacks, check out our free on-demand webinar about “The Keys to Improving Response to a Cyber Security Incident”.

How Cyber Resilience is Changing Cyber Security

Vanessa Henri
About author:
Vanessa is an academic and legal expert on data protection laws, as well as a certified data protection officer. Currently, Vanessa is Hitachi Systems Security’s Director of Legal and Compliance as well as Data Protection Officer. She oversees the performance of privacy advisory services by Hitachi Systems Security to its clientele, including services such as GDPR Posture Assessments. She advises boards of directors at the macro-strategic level on the implementation of privacy obligations through efficient reporting systems. She has published a variety of data privacy-related materials and has contributed as a speaker to various conferences about data protection laws, such as Code Blue, in Tokyo. Vanessa is a member of the Quebec Bar Association, and holds a master’s in laws from McGill University. She also teaches corporate cybersecurity practices at St Thomas University, in Miami, Florida. She is a certified Data Protection Officer.

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