Assigning a breach response lead from existing staff. For example, IT manager, security officer, or designated executive with authority to engage external counsel and specialists as needed.
Defining breach notification procedures. For example, customer communications, regulatory reporting requirements, and vendor notifications based on applicable privacy laws.
Implementing security remediation measures. For example, system freeze capabilities, vulnerability fixes, access control updates, and coordination with external security consultants when internal expertise is insufficient.
Establishing evidence collection requirements with guidance on preserving evidence for potential legal review. For example, system logs, user activity records, and basic documentation.
Can be standalone document or integrated in existing incident response procedures/policies
Organizations can submit alternative evidence demonstrating how they meet the requirement.