DPWAT-ISMS-PROC-005 v1.0

Incident Response Procedure

Document ID: DPWAT-ISMS-PROC-005
Version: 1.0
Owner: ISMS Manager / CISO (RMSI) — Timo Andreas Bejan
Approved by: Administrator (ADM) — Anna Boros
Effective date: 2025-11-10
Next review: 2027-02-01 (or on major change)

1. Immediate actions (anyone)

2. Triage (CISO)

Severity classification

Severity Criteria Response time Examples
Critical Confirmed data breach involving customer data; regulatory notification likely required; complete loss of critical business capability Immediate (within hours) Customer source code exfiltrated; ransomware with data encryption; GDPR-reportable breach
High Potential/suspected data breach; major system compromise; lost/stolen device containing customer data Same business day Compromised admin account; laptop stolen with local repos; suspicious bulk data access
Medium Contained security incident; suspicious activity requiring investigation; minor exposure (internal only) Within 2 business days Phishing click with credential entry (contained); unauthorized access attempt blocked; accidental internal disclosure
Low Near-miss; blocked attack; policy violation with no actual impact Within 1 week Phishing email reported (no click); failed login attempts; minor AUP violation

Severity determines response urgency and escalation. Critical and High incidents are escalated to the Administrator immediately.

3. Containment and eradication

4. Recovery

5. Authority notification

The CISO (or Administrator if CISO is unavailable) is the only person authorized to make official reports to external authorities.

When to notify

Incident type Authority Deadline Notes
Personal data breach (GDPR) ANSPDCP 72 hours from awareness Unless breach is unlikely to result in risk to individuals
Significant cyber-attack, malware, ransomware DNSC As soon as practicable Use 1911 for emergencies
Criminal activity (extortion, intentional theft) DIICOT / Police As soon as practicable Coordinate with legal counsel
Compromised cloud infrastructure AWS / Azure / GCP / GitHub Immediately Per provider abuse/security channels

Contact details

See authorities-contact-register for current contact information.

Customer environments

If an incident occurs in a customer-managed environment, notify the customer security lead first; the customer decides whether to report to authorities unless DP WAT has independent legal obligations (e.g., DP WAT is a data controller for the affected data).

6. Lessons learned

7. Records