ISO/IEC 27001

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Incident Response Procedure

1. Purpose

The Incident Response Procedure defines the operational process for identifying, reporting, assessing, containing, investigating, resolving, and closing information-security incidents.

The procedure ensures that incidents are handled consistently and that the organization can demonstrate:

  • What happened
  • When it happened
  • What was affected
  • How the incident was contained
  • What evidence was collected
  • How recovery was performed
  • What risks remain
  • What corrective actions were taken
  • What was learned

This procedure supports the organization’s Information Security Incident Management Policy and should be applied proportionately to the nature, severity, and business impact of each incident.


2. Scope

This procedure applies to security incidents involving:

  • Information systems
  • Applications
  • Servers
  • Endpoints
  • Networks
  • Cloud services
  • Databases
  • SaaS applications
  • User accounts
  • Privileged accounts
  • Mobile devices
  • Customer information
  • Personal information
  • Confidential information
  • Source code
  • Credentials and secrets
  • Physical information assets
  • Suppliers and third parties
  • Software and technology dependencies

It applies to employees, contractors, temporary personnel, suppliers, and other authorized parties.


3. Incident Response Lifecycle

The organization shall manage incidents through the following lifecycle:

Prepare → Detect → Report → Validate → Classify → Assign → Contain → Investigate → Eradicate → Recover → Verify → Communicate → Close → Learn → Improve

Not every incident will require identical actions. The response should be proportionate to the incident.


4. Incident Types

Incidents may include:

  • Unauthorized access
  • Account compromise
  • Credential theft
  • Malware
  • Ransomware
  • Phishing
  • Data leakage
  • Data breach
  • Unauthorized disclosure
  • Vulnerability exploitation
  • Cloud misconfiguration
  • Unauthorized configuration change
  • Denial-of-service attack
  • Insider incident
  • Lost or stolen device
  • Physical security incident
  • Supplier incident
  • Software supply-chain incident
  • API compromise
  • Website/application compromise
  • Security-policy violation

5. Roles and Responsibilities

RoleResponsibility
Incident ReporterReports suspected incident
Incident ManagerCoordinates overall response
Security LeadDirects security investigation and response
IT/Infrastructure TeamPerforms technical containment and recovery
Application OwnerAssesses application impact
Cloud TeamHandles cloud-specific technical response
Data/Privacy OwnerAssesses personal/customer data impact
Legal/ComplianceReviews legal, regulatory, and contractual obligations
Business OwnerAssesses business impact
Supplier OwnerCoordinates third-party incidents
ManagementMakes significant business/risk decisions

For smaller organizations, one individual may perform multiple roles.


6. Preparation

Before an incident occurs, the organization should maintain appropriate response capability.

Preparation should include:

  • Approved incident-management policy
  • Incident-response procedure
  • Incident reporting channel
  • Incident severity criteria
  • Incident contacts
  • Escalation contacts
  • Asset inventory
  • System/application owners
  • Cloud service information
  • Relevant security logs
  • Backup and recovery capability
  • Security monitoring
  • Vulnerability management
  • Contact information for key suppliers
  • Legal/privacy escalation contacts

The organization should periodically verify that important contacts and response procedures remain current.


7. Incident Detection

An incident may be detected through:

  • Employee reports
  • Customer reports
  • Security monitoring
  • SIEM
  • EDR
  • Antivirus
  • Firewall
  • WAF
  • Cloud security tools
  • Authentication alerts
  • Audit logs
  • Vulnerability scanners
  • Penetration testing
  • Supplier notifications
  • Cloud provider notifications
  • Threat intelligence
  • Security researchers
  • Internal audits

The person or system identifying a potential incident should initiate the reporting process.


8. Incident Reporting

The reporter should provide as much information as reasonably available.

The initial report should include:

  • Date and time
  • Reporter
  • Description of event
  • Affected system
  • Affected user/account
  • Possible information involved
  • How the event was detected
  • Initial business impact
  • Screenshots/logs/evidence where available
  • Actions already taken

Employees should not intentionally delay reporting while attempting to determine whether an event is a genuine incident.


9. Initial Triage

The incident owner should perform an initial assessment to determine:

  1. Is this a genuine security event?
  2. What system is affected?
  3. Is the system operational?
  4. Is unauthorized access suspected?
  5. Is sensitive information involved?
  6. Is the incident ongoing?
  7. Is immediate containment required?
  8. Does management need to be notified?
  9. Are legal, privacy, customer, or regulatory requirements potentially involved?

The objective is to establish the initial scope quickly without prematurely assuming the final cause or impact.


10. Event Validation

The response team should validate the event using available evidence.

Validation may include:

  • Reviewing logs
  • Checking authentication activity
  • Reviewing recent changes
  • Confirming authorized activity
  • Checking system configuration
  • Reviewing endpoint alerts
  • Checking application activity
  • Contacting system owners
  • Reviewing supplier information

The event may be categorized as:

  • False positive
  • Normal/authorized activity
  • Security event
  • Suspected incident
  • Confirmed incident

11. Incident Classification

Confirmed incidents should be classified according to the organization’s approved severity methodology.

An illustrative model is:

SeverityDescription
LowLimited impact with no significant business disruption
MediumMeaningful security impact requiring coordinated response
HighSignificant impact to information, systems, customers, or operations
CriticalMajor compromise, widespread impact, critical service disruption, or significant data exposure

Classification should consider:

  • Confidentiality
  • Integrity
  • Availability
  • Information sensitivity
  • Customer impact
  • Personal-data impact
  • Production impact
  • Privileged access
  • Number of affected systems
  • Duration
  • Business impact
  • Regulatory requirements
  • Contractual obligations

12. Incident Assignment and Escalation

Each confirmed incident should have an identified owner.

The Incident Manager should determine whether additional personnel are required.

Escalation may include:

  • Security leadership
  • IT
  • Cloud/DevOps
  • Application owners
  • Business owners
  • Privacy
  • Legal
  • Compliance
  • Management
  • Suppliers
  • Cloud providers
  • External incident-response specialists

Critical incidents should receive appropriate management attention.


13. Immediate Containment

The response team should take appropriate action to prevent further damage.

Possible actions include:

Account compromise

  • Disable account
  • Revoke sessions
  • Reset credentials
  • Revoke tokens
  • Rotate access keys
  • Enforce MFA
  • Remove unauthorized privileges

Compromised endpoint

  • Isolate device
  • Disable network access where appropriate
  • Preserve evidence
  • Remove malicious software

Compromised application

  • Restrict affected functionality
  • Block malicious traffic
  • Disable compromised credentials
  • Deploy emergency security controls

Data exposure

  • Remove unintended access
  • Restrict affected resources
  • Preserve relevant evidence
  • Assess whether information was accessed

Containment should consider both security and business impact.


14. Evidence Preservation

The response team should preserve relevant evidence where required.

Evidence may include:

  • Authentication logs
  • Application logs
  • Cloud logs
  • Network logs
  • Endpoint information
  • Security alerts
  • Firewall/WAF logs
  • Database logs
  • Configuration history
  • Emails
  • Screenshots
  • System images
  • Vulnerability reports
  • Supplier communications
  • Incident tickets

Evidence should be:

  • Protected from unauthorized modification
  • Accessible only to authorized personnel
  • Traceable to the incident
  • Retained according to applicable requirements

Actual passwords, API keys, private keys, or other secrets must not be stored in incident records.


15. Investigation

The investigation should establish, as far as reasonably possible:

Timeline

  • When did the activity begin?
  • When was it detected?
  • How long did it continue?
  • When was it contained?

Attack or failure mechanism

Examples:

  • Stolen credentials
  • Phishing
  • Vulnerability exploitation
  • Misconfiguration
  • Malware
  • Unauthorized access
  • Supplier compromise
  • Software vulnerability

Affected assets

Identify:

  • Systems
  • Applications
  • Accounts
  • Devices
  • Databases
  • Networks
  • Cloud resources
  • Information

Impact

Determine whether there was:

  • Unauthorized access
  • Unauthorized disclosure
  • Unauthorized modification
  • Data destruction
  • Service disruption

16. Scope Assessment

The investigation should determine whether the incident is isolated or broader than initially reported.

Consider:

  • Related accounts
  • Related systems
  • Similar vulnerabilities
  • Other environments
  • Other users
  • Other customers
  • Other suppliers
  • Related cloud resources
  • Related applications
  • Related credentials

Where appropriate, threat-hunting activities may be performed to identify additional compromise.


17. Information and Data Impact Assessment

Where information is involved, determine:

  • Information type
  • Classification
  • Information owner
  • Location
  • Approximate volume
  • Customer involvement
  • Personal-data involvement
  • Confidentiality impact
  • Integrity impact
  • Availability impact
  • Evidence of access
  • Evidence of disclosure or exfiltration

The organization should distinguish between:

Potential exposure → Suspected access → Confirmed access → Confirmed disclosure

This distinction should be supported by available evidence.


18. Supplier and Third-Party Incidents

If an incident involves a supplier:

  1. Identify the supplier.
  2. Identify the affected service.
  3. Determine affected information/systems.
  4. Review contractual obligations.
  5. Notify or engage the supplier.
  6. Obtain available incident information.
  7. Assess organizational impact.
  8. Track supplier corrective actions.
  9. Reassess supplier risk where appropriate.
  10. Update supplier records.

Supplier notifications should be validated against the organization’s own information where practical.


19. Cloud Incidents

Cloud-specific incidents should be handled using the Cloud Incident Response Procedure.

Examples include:

  • Compromised cloud account
  • Unauthorized IAM activity
  • Public storage exposure
  • Compromised cloud workload
  • Unauthorized security-group changes
  • Cloud database exposure
  • Compromised API credentials
  • Cloud cryptomining

Relevant cloud audit logs and provider information should be preserved.


20. Eradication

After sufficient investigation and containment, the response team should remove the cause of compromise.

Actions may include:

  • Remove malware
  • Patch vulnerabilities
  • Correct configuration weaknesses
  • Remove unauthorized accounts
  • Remove malicious code
  • Rotate credentials
  • Rebuild systems
  • Replace compromised components
  • Remove malicious persistence
  • Disable compromised integrations

Where appropriate, affected systems should be rebuilt from trusted configurations.


21. Recovery

Recovery should restore systems to a secure and operational condition.

Activities may include:

  • Restore from trusted backups
  • Rebuild systems
  • Deploy patched applications
  • Restore databases
  • Restore configuration
  • Reconfigure security controls
  • Validate access
  • Validate monitoring
  • Test application functionality
  • Verify data integrity

Recovery should be coordinated with the relevant business and system owners.


22. Recovery Verification

Before the incident is considered operationally recovered, verify:

  • Unauthorized access has been removed.
  • Compromised credentials have been addressed.
  • Vulnerabilities have been remediated or risk-treated.
  • Security controls are functioning.
  • Logging is operational.
  • Monitoring is operational.
  • Data integrity is acceptable.
  • Applications are functioning.
  • Business services are available.
  • No continuing indicators of compromise are present.

23. Communication

Incident information should be communicated according to severity and need-to-know.

Internal stakeholders may include:

  • Management
  • Security
  • IT
  • Application owners
  • Business owners
  • Privacy
  • Legal
  • Compliance

External stakeholders may include:

  • Customers
  • Suppliers
  • Cloud providers
  • Regulators
  • Law enforcement
  • Insurance providers

Only authorized personnel should issue external communications.

Communications should be factual and should avoid unsupported conclusions.


24. Legal, Regulatory and Contractual Assessment

The organization should determine whether the incident creates notification or reporting obligations under:

  • Applicable laws
  • Data-protection requirements
  • Regulatory requirements
  • Customer contracts
  • Supplier agreements
  • Data Processing Agreements
  • Insurance requirements

Legal, privacy, compliance, and management personnel should be involved where appropriate.


25. Root Cause Analysis

Significant incidents should undergo root-cause analysis.

The analysis should distinguish:

Immediate Cause

What directly caused the incident?

Contributing Factors

What increased the likelihood or impact?

Root Cause

What underlying control or process weakness allowed the incident?

Example:

Incident: Unauthorized production access

Immediate cause: Compromised user credentials.

Contributing factors:

  • Excessive privileges
  • Weak authentication controls
  • Inadequate monitoring

Underlying weakness:

Insufficient privileged-access management.

Corrective actions:

  • Enforce MFA
  • Implement least privilege
  • Remove unnecessary privileged access
  • Perform periodic access reviews
  • Improve monitoring

26. Corrective Actions

Incident findings should be recorded in the organization’s corrective-action process.

Each action should identify:

  • Finding
  • Risk
  • Root cause
  • Corrective action
  • Owner
  • Priority
  • Due date
  • Status
  • Evidence
  • Verification
  • Closure

Corrective actions should address underlying control weaknesses rather than only the immediate incident symptom.


27. Lessons Learned

For significant incidents, conduct a post-incident review.

Consider:

  1. How was the incident detected?
  2. Was detection timely?
  3. Was reporting effective?
  4. Was escalation appropriate?
  5. Were roles clear?
  6. Was evidence sufficient?
  7. Was containment effective?
  8. Was recovery effective?
  9. Were communications appropriate?
  10. Were contractual/regulatory requirements met?
  11. What controls failed?
  12. What controls were missing?
  13. What should be changed?

Lessons learned should feed into the ISMS continual-improvement process.


28. Incident Closure

An incident should be formally closed when:

  • Investigation is sufficiently complete.
  • Containment is confirmed.
  • Eradication is complete or appropriately tracked.
  • Recovery is verified.
  • Required notifications are completed.
  • Evidence has been retained.
  • Corrective actions have been assigned.
  • Residual risk has been assessed.
  • Required approvals have been obtained.

Open corrective actions do not necessarily prevent incident closure, provided they remain formally tracked.


29. Incident Record

Each confirmed incident should have an incident record containing, as applicable:

FieldDescription
Incident IDUnique identifier
Date/TimeDetection and reporting time
ReporterPerson/source reporting
CategoryType of incident
SeverityIncident classification
Incident OwnerResponsible person
Affected AssetsSystems/services involved
InformationInformation involved
DescriptionWhat happened
EvidenceSupporting evidence
TimelineKey events
ContainmentActions taken
InvestigationFindings
ImpactBusiness/security impact
Root CauseUnderlying cause
RecoveryRecovery actions
NotificationsStakeholders notified
Corrective ActionsRemediation
Residual RiskRemaining risk
ClosureClosure date/approval

30. Incident Response Evidence

Typical evidence includes:

  • Incident reports
  • Incident register
  • Security alerts
  • Audit logs
  • Authentication logs
  • Investigation notes
  • Screenshots
  • System/configuration evidence
  • Containment records
  • Credential-rotation evidence
  • Recovery records
  • Customer/regulatory communications
  • Root-cause analysis
  • Corrective-action records
  • Lessons-learned records
  • Management approvals
  • Incident exercise results

31. Incident Response Testing

The organization should periodically test its response capability where appropriate.

Examples:

  • Tabletop exercise
  • Phishing simulation
  • Compromised account exercise
  • Ransomware scenario
  • Cloud compromise scenario
  • Data-breach scenario
  • Supplier incident scenario
  • Lost-device scenario

Testing should assess:

Detection → Reporting → Escalation → Containment → Investigation → Communication → Recovery → Closure

Findings should be documented and tracked.


32. Startup-Friendly Incident Response

A startup can begin with a simple but controlled model.

People

  • Incident Manager
  • Security/technical responder
  • Business/management escalation
  • Privacy/legal contact

Technology

  • Centralized logging
  • Endpoint protection
  • Cloud monitoring
  • MFA
  • Vulnerability management
  • Backup and recovery

Process

  • One incident-reporting channel
  • Severity matrix
  • Escalation contacts
  • Incident register
  • Response procedure
  • Corrective-action tracker

Evidence

Maintain a traceable record:

Detection → Response → Recovery → Closure → Improvement

As the organization grows, it can introduce SIEM, 24×7 monitoring, forensic capabilities, external incident-response retainers, and automated response.


33. Relationship With Other ISMS Documents

DocumentRelationship
Information Security Incident Management PolicyEstablishes overall governance
Incident RegisterRecords incidents
Cloud Incident Response ProcedureHandles cloud-specific incidents
Data Breach ProcedureHandles privacy/data-breach requirements
Vulnerability Management ProcedureHandles vulnerability-related findings
Supplier Incident Response ProcedureHandles supplier incidents
Cloud Backup and Recovery ProcedureSupports recovery
Business Continuity PlanSupports business continuity
Disaster Recovery PlanSupports technical recovery
Risk Management ProcedureSupports risk assessment
Corrective Action RegisterTracks remediation
Risk RegisterTracks significant residual risks
Lessons Learned RegisterTracks improvement opportunities

34. Internal Audit Checklist

An auditor can verify:

  • Incident response procedure is approved.
  • Roles and responsibilities are defined.
  • Reporting mechanisms exist.
  • Incident validation is performed.
  • Severity criteria are defined.
  • Escalation requirements are documented.
  • Containment procedures exist.
  • Evidence preservation is addressed.
  • Investigation procedures exist.
  • Data impact assessment is performed where applicable.
  • Supplier incidents are addressed.
  • Cloud incidents are addressed.
  • Recovery procedures are defined.
  • Recovery is verified.
  • Legal/regulatory requirements are assessed.
  • Incident records are maintained.
  • Significant incidents receive root-cause analysis.
  • Corrective actions are tracked.
  • Lessons learned are documented.
  • Incident-response testing is performed where appropriate.
  • Incident trends are reviewed.
  • Improvements are incorporated into the ISMS.

35. ISO 27001 Connection

This procedure operationalizes the organization’s information-security incident-management requirements.

The applicable controls should be determined through:

Context → Risk Assessment → Risk Treatment → Applicable Controls → Statement of Applicability → Implementation → Evidence → Continual Improvement

The procedure itself is not proof that incident management is effective.

An auditor should be able to trace an actual incident through:

Alert/Report → Incident Record → Classification → Investigation → Containment → Recovery → Evidence → Corrective Action → Closure

The organization should also demonstrate that lessons from incidents are considered in its risk assessment and continual improvement activities.


36. Final Incident Response Audit Trail

A complete incident should produce a traceable chain:

Event Detected
→ Reported
→ Validated
→ Classified
→ Assigned
→ Escalated
→ Contained
→ Evidence Preserved
→ Investigated
→ Scope Determined
→ Impact Assessed
→ Eradicated
→ Recovered
→ Recovery Verified
→ Communications Completed
→ Root Cause Identified
→ Corrective Actions Assigned
→ Residual Risk Assessed
→ Lessons Learned
→ Management Review
→ Incident Closed
→ ISMS/Risks/Controls Improved


37. Final Principle

Effective Incident Response = Detect Quickly + Contain Safely + Investigate Properly + Recover Securely + Verify + Learn

The goal is not simply to close an incident ticket.

The organization should be able to demonstrate:

What happened, how it was detected, what was affected, how the organization responded, what evidence supports the investigation, how recovery was verified, what risk remains, and what changed as a result of the incident.