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INC-001 Incident Response Plan

Tier 1+ProviderDeployerGPAI Model ProviderManaged Service Provider

Description

A documented Incident Response Plan defines the organisation's approach to detecting, containing, eradicating and recovering from security incidents. The plan covers roles and responsibilities, communication channels, escalation paths and coordination with legal, regulatory and communications functions. Incident handling runs in a case management system that records each handling step against the incident, generates and routes the notifications the plan requires and makes the current plan, its runbooks, the contact list and the incident's state available to responders without depending on the systems under investigation. The plan is reviewed at least annually and after significant incidents.

Rationale

Without a documented plan, incident response is improvised, slow and legally exposed, and a current tested plan is the foundation of the whole capability. A response pieced together afterwards from a chat channel cannot show when escalation happened or whether a notification went out, so the plan has to run in a tool rather than on paper. Independence from the estate under investigation is the property that decides whether the tooling is available in the incident it was bought for.

Applicability (9 profiles)

SaaS AI Providerstablerequiredcore
Enterprise AI Deployerstablerequiredcore
GPAI Model Providerstablerequiredcore
High-Risk Provider (EU)stablerequiredcore
Public Body Deployer (EU)stablerequiredcore
DORA ICT Provider (EU)stablerequiredcore
NIS2 Cloud Provider (EU)stablerequiredrole duty

Annex point 3.1.2(a) requires a categorisation system inside the policy that is consistent with the event assessment and classification under point 3.4.1, and point 3.1.3 requires the roles, responsibilities and procedures to be tested as well as reviewed. Point 3.5.3 adds a communication plan with the CSIRT or competent authority alongside the internal and stakeholder one.

Framework Mappings (21)

SEF-01Security Incident Management Policy and Proceduresfull
SEF-02Service Management Policy and Proceduresfull
SEF-03Incident Response Plansfull
SEF-01Security Incident Management Policy and Proceduresfull
SEF-02Service Management Policy and Proceduresfull
SEF-03Incident Response Plansfull
HIPAA-164.308.a.1.iSecurity Management Processpartial
HIPAA-164.308.a.6.iSecurity Incident Proceduresfull
HIPAA-164.308.a.6.iiResponse and Reportingfull
HIPAA-164.314.a.2.i.CBusiness Associate Contract Security Incident Reporting Terminformative
5.24Information security incident management planning and preparationfull
NIS2-Art.21.2.bIncident Handlingfull
NIS2-CIR-3.1Incident Handling Policypartial
NIS2-CIR-3.5Incident Responseinformative
IR-1Policy and Proceduresfull
IR-4(1)Incident Handling | Automated Incident Handling Processesfull
IR-6(1)Incident Reporting | Automated Reportingfull
IR-7(1)Incident Response Assistance | Automation Support for Availability of Information and Supportfull
IR-8Incident Response Planfull
GV-2.1-002AI Risk Roles and Responsibilities | GV-2.1-002partial
GV-6.2-003Third-Party Failure Contingency Processes | GV-6.2-003partial

Evidence (3)

policydocumentmanual

Documented Incident Response Plan covering roles, responsibilities, communication channels, escalation paths, and coordination with legal, regulatory, and PR functions.

Example: Incident Response Plan document (version-controlled, approved by CISO or equivalent senior owner, dated within the last 12 months) including RACI chart, communication tree, escalation criteria, and regulatory notification procedures

Test: Request the current IRP. Verify: (1) the plan defines roles and responsibilities with named owners or titles; (2) escalation paths cover at minimum: technical response, legal, PR/communications, and regulatory notification; (3) communication channels and contact lists are included; (4) the document was reviewed and approved within the last 12 months; (5) confirm the plan was updated following the most recent significant incident.

recorddocumentmanual

IRP review record confirming the plan was formally reviewed and approved within the last 12 months or following a significant incident.

Example: Document version history or review sign-off record for the IRP, showing last review date, reviewer, change summary, and approver sign-off

Test: Request the IRP version history and most recent review sign-off. Verify: (1) a formal review was conducted within the last 12 months; (2) a named approver with appropriate authority signed off the current version; (3) if a significant incident occurred in the review period, confirm the IRP was updated afterward.

configurationtechnicalautomated

Incident case management configuration showing the handling steps it records, the notification routes it generates and the responder access it provides.

Example: Incident platform configuration export, workflow and notification rules, 2026-08

Test: Export the incident case management configuration. Verify: (1) each phase the plan names has a matching step or state in the tool, (2) notification templates and recipient routes exist for each reporting obligation the plan carries, and at least one notification in the period was generated from them rather than written by hand, (3) the plan, runbooks and contact list are reachable from the tool by every responder role, (4) the tool and its content are hosted independently of the production estate a responder may have to isolate, (5) a closed incident in the period shows a complete step history rather than a single summary entry.

Questions (3)

boolean

Does your organisation have a documented incident response plan?

The IRP should be approved by the CISO or equivalent senior owner, version-controlled, and updated following significant incidents. A plan that has not been reviewed in over 12 months is considered stale.

multi

Which functions are explicitly covered in your Incident Response Plan?

Technical incident response (identification, containment, eradication, recovery)Legal counsel escalation pathPR and external communicationsRegulatory notification process (including GDPR timelines)Customer notification processExecutive and board-level escalationNone of the above

All six are expected in a mature IRP. Missing legal or regulatory escalation paths are a common gap that creates exposure during actual incidents.

multi

Which of the following does your incident tooling do?

Records each handling step against the incident as a caseGenerates and routes the notifications the plan requiresMakes the plan, runbooks and contact list available to responders during an incidentRuns independently of the production systems a responder may have to isolateNone of the above

Options run from the most commonly in place to the least. Independence from the estate under investigation decides whether the tooling is available in the incident it was bought for, and it is the item most often taken for granted.