Is It Time to Revisit Your Breach Response Plan?

Response to sensitive-data breaches should involve legal, PR departments

3:40 PM -- This morning, I was reading an article about a warning issued by the state of Massachusetts to the members of its Prescription Advantage insurance program. Like many other breach reports, this report features confusing and contradictory information -- which really isn't surprising, given the general lack of documented breach response procedures or formal protocols for who is allowed to talk with the media.

The article quotes a November 19 letter sent to affected members which states that "a few members were recently the victims of attempted identity theft." The article goes on to say that the Prescription Advantage staff has "no reason to believe" that members’ information has been misused. Sounds like there's a disconnect between the person writing the letter and the one talking to the press.

Every organization should have an incident response plan for data breaches that reads something like this: "Step 1: If the system breached is used to store and process personal information, immediately notify management and legal and public relations departments, then proceed with analysis by trained incident response specialists and forensic investigators."

Of course, that's just a start. The plan should include details for isolating the breached systems and dealing with mission-critical systems. There also needs to be documentation on who is allowed to speak to the press, and how much they are allowed to say.

Most IT people think that security incident response plans are entirely technical documents, but they shouldn't be -- especially with the emergence of state laws that govern how organizations must deal with breaches of personal information. The legal department must be involved to properly interpret the law. Public relations must designate spokespeople, along with what those spokespeople are allowed to say. Management must sign off on the plan.

If your incident response plan doesn't cover breach of sensitive personal information -- or outline the role of legal, public relations, and management -- then it's time for the next revision. And the best time to do it is now -- not while investigating an actual breach.

– John H. Sawyer is a security geek on the IT Security Team at the University of Florida. He enjoys taking long war walks on the beach and riding pwnies. When he's not fighting flaming, malware-infested machines or performing autopsies on blitzed boxes, he can usually be found hanging with his family, bouncing a baby on one knee and balancing a laptop on the other. Special to Dark Reading<