Incident Checklist

Sensitive Data Exposure Incident Checklist

We recommend reading the purpose statement, introduction, overview, and suggestions for how to use the checklist before downloading a copy.

Purpose

To provide a toolkit that includes resources, procedures, and guidelines for the management of incidents involving the exposure of sensitive and/or personal information. Complementary to the Data Incident Notification Toolkit, this information can be referred to during the process of responding to incidents that create the need for such notification.

Introduction

The following information is intended to provide a general checklist of the steps that an institution might take when an incident involving sensitive data is discovered. Although each item is recommended as an effective practice, we recognize that state/local legal requirements, institutional policy, or campus culture might cause each institution to approach this process differently. State legislation regarding incident breach varies broadly and institutions should check with legal counsel in advance to ensure this checklist meets statutory need. Institutions will also be at varying stages of progress in their incident response management capabilities. Some will start with the need to establish actions in the areas of policies, processes, or tools, some will be ready to implement, and others will be able to revise and fine-tune their processes. This checklist can be helpful for all, as a review of readiness or as a roadmap for development.

Checklist Overview

The checklist consists of the five major steps described below, with sub-steps included for each.

>>STEP 1: Identification

Verify that an incident has actually occurred. This activity typically involves the Unit systems administrator and end user, but may also result from proactive incident detection work of the Security Office or central IT operations. If it is determined that an incident has occurred, inform appropriate authorities.

>>STEP 2: Damage Containment and Data Exposure Assessment

Identify an Incident Response Lead and assemble an incident response team charged with limiting further damage from the incident. Conduct a thorough assessment of the type and scope of data exposed following applicable laws, regulation and policy.

>>STEP 3: Eradication and Recovery

Take steps to remove the cause of the exposure, reduce the impact of the exposure of the sensitive data, restore operations if the incident compromised or otherwise put out of service a system or network, and ensure that future risk of exposure is mitigated.

>>STEP 4: Notification

Determine the need to give notice to individuals whose data may have been exposed by the incident. Swiftness in notifying those affected by a breach of personally identifiable information (PII), as well as informing certain government entities, is legally mandated in many states and, depending on the nature of the data, also federal law. Speed is also important from a public relations standpoint. To this end, many of the sub-steps can and should be undertaken in parallel to accommodate these needs.

>>STEP 5: Follow-up

Identify lessons learned from the incident, implement any remediation needs, and securely store a complete record of the incident.

How To Use

Depending upon the nature of the incident and size of the response team, it may be advisable and practical to address some of the checklist steps and sub-steps in parallel. For example, as soon as the cause of an incident is determined (Step 2.6), eradication of that cause and recovery of the function it put out of service (Step 3) could commence while documentation activities of Step 2.7 are being addressed. The potential for multitasking incident steps and sub-steps is depicted in this <ac:link-body>workflow</ac:link-body>.

In ways similar to emergency preparedness planning, it is wise to periodically practice the institution's security incident response readiness in advance of actual events. Lessons learned should be incorporated as needed into the checklist, response procedures, and/or resource allocations.

The checklist includes actions needed to address the most serious of security incidents, i.e. the exposure of personally identifiable information (PII) protected by laws, industry standards, and/or contracts with parties external to the institution. It can also be used effectively to address other security incident types, e.g., defacement of public websites, unauthorized access to confidential but not legally protected data, or the loss of confidential paper records.

As helpful as we hope this checklist will be, it is important to consider that:

Training and Tools

In addition to establishing a coordinated, repeatable process for incident response (which this checklist facilitates), access to trained technical professionals and tools are also needed for effective incident response. While there is an abundance of security consulting firms available to supply these needs, institutions may find it more cost-effective to train and equip their own staffs to address incidents on an ongoing basis.

Training – There are many good sources of both management and technical training in computer incident handling techniques. The SANS Institute, for example, provides a number of courses (at this writing, six on the specialty of computer forensics alone). Training is also offered by some academic institutions and, of course, by many technical training vendors.

Tools – Likewise, there is a wide range of incident response tools from both commercial and open source origins. Categories include but are not limited to:

Incident response tools in these and other categories are generally available as single products, although they might also be included in integrated product suites that seek to provide incident responders with a common "workbench" of tools from multiple categories. Additionally, these tools might be featured in products having much broader purposes than simply incident response. For example, products that facilitate governance, risk, and compliance process, i.e., GRC systems, typically include an incident/issue workflow and documentation component.

Additional Resources
Download the Checklist

The Sensitive Data Exposure Incident Checklist is available to download and print in Word or PDF format. The 12-page checklist includes all five steps and sub-steps.


 

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