Written by: Michael Curcurito, Clay Moseman
Importance of Incident Declaration and Reporting in Cybersecurity
You might be wondering when your organization will face a cyber-attack. Incidents such as data breaches, ransomware, and other malware infections are often seen in the news and on social media, and these system intrusions can cause severe damage to your organization’s reputation, finances, and operations. Are you prepared to declare an incident and accurately report it to the appropriate parties in a timely manner? In these cases, incident clarification and reporting are critical to mitigating the impact of cybersecurity threats on your organization.
A primary challenge in incident response is the alignment between IT/IS and communication management teams. Does the IT/IS team know what should be discussed with the communications team and when? An organization’s IT teams are responsible for detecting, declaring, containing, and eradicating threats, while communication teams handle external messaging and reputation management. Therefore, coordination between these two are essential to ensure consistent and transparent communication during cybersecurity incidents.
The purpose of this article is to provide comprehensive guidelines for organizations to improve incident declaration and reporting procedures by fostering collaboration between IT and communication management. By understanding the incident declaration process, bridging the gap between these departments, and collaborating effectively with relevant agencies, you will be able to strengthen your organization’s overall incident response strategy.
Understanding Incident Declaration
A cybersecurity incident refers to any event or activity that poses a potential threat to the confidentiality, integrity, or availability of an organization’s information systems and data. Establishing clear criteria for incident declaration is vital for an organization’s response strategy to be successful. Nevertheless, there are automated and common triggers for declaring a cybersecurity incident. Whether it is coming from an employee at the organization or an automated tool, the cybersecurity incident may include the detection of unusual activity, network traffic, unauthorized access, or the presence of malicious software. Employees should be trained periodically in reporting cybersecurity events and the tools your organization uses should have predefined triggers to ensure consistent response actions.
Role of IT and Communication Management in Declaring an Incident
IT teams play a crucial role in identifying and confirming cybersecurity incidents, while communication management is responsible for promptly notifying relevant stakeholders such as customers, partners, and regulatory agencies. Therefore, effective communication between these departments is crucial for timely and accurate incident declaration. Delays in reporting can exacerbate the damage caused by incidents, leading to increased recovery costs and potential legal and regulatory consequences. Thus, early detection and reporting enable faster containment and response.
Bridging the Gap between IT and Communication Management
Organizations should establish clear and direct communication channels between IT and communication management. This can include dedicated incident response teams, regular meetings, and communication tools to ensure seamless collaboration. Each department should have well-defined roles and responsibilities during a cybersecurity incident and these roles and responsibilities should be understood and upheld by those involved. Although IT teams handle technical aspects and communication teams manage external communications, clearly defining these roles avoids confusion and streamlines incident response efforts.
Conducting Joint Incident Response Training and Exercises
Regular joint training and simulated incident response exercises help IT and communication management teams understand each other’s workflows, challenges, and expectations. These exercises enhance teamwork, decision-making, and response capabilities. Organizational leadership should promote a culture of cooperation and collaboration between IT and communication management, since recognizing and rewarding successful collaboration efforts can foster a positive incident response environment.
Best Practices for Incident Reporting
Creating a standardized incident reporting process ensures consistency and accuracy in reporting. This process should include predefined templates, incident categorization, and escalation procedures. Incident reports submitted to regulatory agencies must be comprehensive and include all relevant information pertaining to the incident. Organizations should also carefully follow agency guidelines to ensure compliance. Additionally, reports should be concise, focusing on the critical details of the incident, since avoiding unnecessary information streamlines the reporting process and enhances clarity. It is critical for organizations to maintain detailed records and documentation of incident response activities. This documentation can serve as a valuable reference for future incidents and regulatory audits.
Incident Reporting to Appropriate Agencies
Different cybersecurity incidents may have reporting requirements to various regulatory agencies and authorities, such as the Cybersecurity and Infrastructure Security Agency (CISA), Securities and Exchange Commission (SEC), Federal Financial Institutions Examination Council (FFIEC), and more. Organizations must be aware of the specific reporting obligations based on their industry and geographic location.
Reporting Requirements and Timelines for Different Agencies
Each regulatory agency may have different reporting requirements and timelines. However, organizations must be well-informed about these requirements to ensure timely and accurate submissions. Below, we lay out the reporting requirements for each agency:
- FFIEC/OCC/FDIC: For financial institutions, notification to the primary regular must be given no later than 36 hours after the banking organization determines that a cyber incident has occurred.
- Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA): CIRCIA requires CISA to develop and issue regulations requiring covered entities to report to CISA any covered cyber incidents within 72 hours from the time the entity reasonably believes the incident occurred.
- SEC: Require issuers to file an 8-K to report cybersecurity incidents within four business days after the registrant determines that it has experienced a material cybersecurity incident.
Understanding the Type of Incidents That Must Be Reported
Organizations must distinguish between incidents that require reporting and those that do not. Understanding the reporting thresholds for different incident types helps prioritize response activities and compliance with reporting obligations. It is paramount for legal and compliance teams to be involved in incident reporting in order to address potential legal liabilities, and ensure adherence to data protection and privacy regulations.
Collaborating with Agencies During Incident Response
Maintaining open and transparent communication with regulatory agencies during an incident helps build trust and facilitates smoother cooperation. Timely coordination with agencies ensures they receive prompt and accurate information. Additionally, proactive communication aids agencies in their assessment and response efforts, and organizations should be aware of the specific expectations of regulatory agencies regarding incident reporting and response. Understanding these expectations enables organizations to meet compliance requirements effectively, since organizations must balance the need for sharing information with agencies, protecting sensitive data, and adhering to privacy regulations. Therefore, anonymizing data, when possible, can help strike this balance.
Case Studies and Lessons Learned
Examining past incidents and their reporting outcomes provides valuable insights into best practices and potential areas of improvement. Case studies that highlight successful collaboration between IT, communication management, and regulatory agencies offer practical examples for other organizations to follow. Understanding the challenges encountered during incident reporting and the solutions employed, provides valuable knowledge for strengthening future incident response strategies.
The Future of Incident Declaration and Reporting
Predicting emerging cybersecurity threats and incident response trends can help organizations proactively prepare for future challenges. The regulatory landscape is continuously evolving, and organizations should anticipate changes in reporting requirements to remain compliant. As technology and communication channels advance, organizations should prepare for improved integration between IT and communication management teams to enhance incident response capabilities.
In summary, collaboration between IT and communication management is fundamental to an effective incident response strategy, and timely incident declaration and reporting are essential for minimizing the impact of cybersecurity incidents. By following the guidelines outlined in this article, organizations can build a robust incident response strategy that ensures effective collaboration and communication during cybersecurity incidents.
Proactive efforts to bridge the gap between IT and communication management, along with adherence to reporting requirements, are key aspects in safeguarding an organization’s reputation and resilience in the face of cyber threats. Whether you are in the process of strengthening your incident response program or just getting started, our team is here to assist.
