Reported incidents of data breaches have reached record levels over the last two years.1 Given this undeniable reality, a data security incident response plan is no longer a luxury; it is a vital tool in every company’s larger crisis management plan. A well-thought-out and thorough response plan can not only significantly reduce the confusion that often follows a data security incident, but can also reduce the pitfalls that often lead to regulatory scrutiny and putative class actions in the United States and the fairly recent “group actions” in the European Union.
In a minute or less, here are the essential components of a working incident response plan.
An incident response plan must identify those individuals responsible for invoking the plan and leading the response to any data security incident. It should identify one person who is ultimately accountable for the response, including clearly defined roles and responsibilities for all other response team members, including a member of top management.
Timing is critical in the wake of a data security incident. The use of tabletop exercises can detail team members' respective roles, provide the necessary skills to navigate an incident, and facilitate teamwork with other appropriate personnel to manage the incident.
This section of the plan should be supplemented with key external resources, such as a detailed contact list for legal counsel, forensic...
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