Principles before procedures
- Do not panic. Do not pull cables blindly. Poorly-chosen containment actions destroy forensic evidence.
- Document everything from minute one. Timestamps, who did what, what was observed. This becomes your regulatory and legal record.
- Engage legal and breach coach counsel early. Privilege attaches to communications through counsel, not through your internal security team.
- Do not communicate externally about the incident until legal has cleared it. No tweets, no customer emails, no vendor calls.
- Assume the adversary is watching your response. Use out-of-band communications (phone, Signal, dedicated ticketing).
Hour 0-1: Initial triage
- Incident Commander designated (typically CISO or on-call security lead)
- Scribe designated (takes notes, timestamps, records decisions)
- Out-of-band communication channel established (Signal group, dedicated Teams/Slack with audit logging off the compromised tenant)
- Legal counsel notified
- Initial severity assessment: what is compromised, what is the blast radius
- Preserve initial evidence (screenshots, log snapshots, endpoint state)
- Do NOT reboot, reimage, or restore systems. You are destroying evidence
Hour 1-4: Containment without destruction
- Isolate affected systems at the network layer (firewall rules, not power-off)
- Disable compromised user accounts, revoke active sessions
- Rotate credentials accessible to compromised systems (API keys, service account tokens, database passwords)
- Preserve memory images for forensic analysis if feasible
- Snapshot affected systems at hypervisor or cloud provider level
- Preserve network traffic captures if available
- Begin timeline reconstruction
Hour 4-12: Scope assessment
- Engage external forensic firm if internal capability is limited (pre-selected via IR retainer is faster)
- Notify cyber insurance carrier (required under most policies, affects coverage)
- Begin log analysis: what did the adversary access? For how long?
- Identify initial access vector (phishing, exploit, valid creds, supply chain)
- Assess lateral movement extent
- Determine data exfiltration (check egress logs, DLP alerts, unusual outbound traffic)
- Identify regulatory notification triggers (HIPAA, GDPR, state breach laws, SEC 4-day, NYDFS 72-hour)
Hour 12-24: Stakeholder notification
- Executive team briefed with current facts and open questions (not speculation)
- Board notified per policy
- Legal drafts initial regulatory notifications (may not send yet, but prepare)
- Public relations engaged for potential external communications
- If SEC-reporting company: materiality determination begins formally
- Decision on law enforcement engagement (FBI, Secret Service, local)
Hour 24-48: Eradication
- Remove adversary persistence (backdoors, scheduled tasks, registry changes, cron jobs, rogue service accounts)
- Patch exploited vulnerabilities
- Rebuild compromised systems from known-good sources (not restore from backup if backup may be compromised)
- Rotate all credentials that could have been accessed
- Revoke all long-lived API tokens, certificates accessible from compromised systems
- Update firewall and EDR rules to block observed adversary tooling and IPs
Hour 48-72: Recovery and notification
- Restore operations on verified clean systems
- Enhanced monitoring for 30-90 days post-incident (adversaries often return)
- File required regulatory notifications within required windows
- Customer notifications per contract and regulatory requirements
- Media statement if applicable (legal-cleared only)
- Begin post-incident review
Scenario-specific notes
Ransomware
- Do NOT pay without legal and insurance carrier approval
- Check OFAC sanctions screening before any payment consideration (US Treasury prohibits payments to sanctioned entities)
- Confirm backup integrity and connectivity to air-gapped storage
- Preserve ransom note and adversary communications for forensics and attribution
- NYDFS regulated entities: 24-hour notification on ransom payment plus 30-day written justification
Business Email Compromise (BEC)
- Identify mailbox rules set by adversary (auto-forwarding, deletion rules)
- Revoke all OAuth tokens on the affected tenant
- Check for any wire transfers initiated or modified. Contact bank within hours (often reversible within 24-72 hours)
- Review related-communication patterns for other compromised mailboxes
- Contact FBI IC3 within 72 hours for wire fraud reporting (helps with kill chain for recovery)
Credential compromise
- Disable account; do not just force password reset
- Revoke all sessions and tokens for the account
- Review what systems the credential accessed in the last 30 days
- Check for privilege escalation or lateral movement from the account
- Audit for creation of additional accounts or modification of existing ones
Data exfiltration
- Preserve the evidence of what was taken (access logs, egress data volumes)
- Classify exfiltrated data categories (PII, PHI, cardholder data, trade secrets, regulated data)
- Notification triggers determined by classification and jurisdiction
- Assess dark-web exposure (specialized firms monitor for your data appearing for sale)
Regulatory notification quick reference
| Regulator | Trigger | Timeline |
|---|---|---|
| SEC (public companies) | Material cyber incident | 4 business days from materiality determination |
| NYDFS (regulated financial) | Cybersecurity event | 72 hours |
| NYDFS (ransom payment) | Ransom paid | 24 hours for notification, 30 days for written justification |
| HHS OCR (HIPAA) | Breach of unsecured PHI | 60 days for notification (affected individuals, HHS, media for 500+) |
| GDPR (EU data) | Personal data breach | 72 hours to supervisory authority |
| State breach laws | Varies by state | 30-60 days typical; some require AG notification |
| CISA (critical infrastructure under CIRCIA) | Substantial cyber incident | 72 hours (once CIRCIA final rule effective) |
Post-incident review
Within 30 days of incident closure, conduct a post-incident review:
- Timeline of adversary actions and defender actions
- Root cause analysis (not just technical root cause. Organizational root cause too)
- What went well, what did not
- Remediation tracking with owners and dates
- Updates to the IR plan based on lessons learned
- Tabletop exercise scheduled to validate updated plan
IR retainer saves time during incidents. Pre-selecting forensics, legal, and PR partners before an incident means you are calling contacts during the worst hours of the incident instead of cold-pitching. Retainers typically cost $5K-$25K/year and pay for themselves on the first incident.
