#First 15 minutes
- Open one incident record; start the timeline (UTC). Everything after this goes in it.
- Assign incident commander and scribe. One person decides; one person writes.
- Contain the obvious: isolate affected hosts, revoke sessions of affected identities, block known indicators.
- Preserve evidence before reimaging: memory where feasible, EDR telemetry, relevant logs.
#First hour
- Scope: hunt for the same indicators and techniques across the estate. Assume lateral movement has started (see breakout time).
- Decide whether this may be a "significant incident" (NIS2) or a personal-data breach (GDPR). If yes, the 24-hour and 72-hour clocks are running.
- Open a separate, out-of-band communication channel in case primary systems are compromised.
- Brief leadership with facts, unknowns and next update time.
#First 24 hours
| Clock | Trigger | Due |
|---|---|---|
| NIS2 early warning | Awareness of a significant incident | Within 24 hours |
| NIS2 incident notification | Awareness of a significant incident | Within 72 hours |
| GDPR Art. 33 | Awareness of a personal data breach (unless unlikely to result in risk) | Within 72 hours to supervisory authority |
| SEC 8-K Item 1.05 | Materiality determination | Within four business days |
- Convene the materiality assessment; document inputs and the decision time.
- Engage counsel, insurer and forensic support per policy.
- Eradication plan: credentials to rotate, persistence to remove, patches to apply.
#By 72 hours
- File required notifications from the single timeline.
- Verify containment: hunt again; confirm no new activity.
- Schedule recovery with monitoring heightened on restored systems.
- Book the post-incident review; capture detection gaps as new rules — and test them.
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