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Incident Response Plan (IRP)

Owner Patrick Tolvstein
Version 1.1
Created 2025-08-14
Last reviewed 2026-06-16
Next review 2027-06-16

1. Purpose and Scope

This plan describes how the company identifies, handles, escalates, and recovers from IT security incidents. It applies to all systems, data, and employees within the organization.

Types of incidents covered by this plan:

  • Data breaches and unauthorized access
  • Ransomware and malware attacks
  • DDoS attacks and service outages
  • Phishing and compromised accounts
  • Loss or leakage of sensitive data (including GDPR-relevant incidents)
  • Insider threats

2. Roles and Responsibilities

Role Responsibilities Primary Backup
Incident Commander (IC) Coordinates the overall response and escalation PT MH
Technical Lead Analysis, containment, and recovery of systems PT SD
Communications Lead Internal and external communication, including GDPR reporting MH PT
Legal / Compliance Assessment of legal obligations, GDPR, insurance CSL PT

All employees are responsible for reporting suspicious activity to the Incident Commander immediately.


3. Incident Classification

Level Name Description Example
P1 – Critical Active crisis Widespread system failure, confirmed data breach with personal data, active ransomware Ransomware encrypting files across systems
P2 – Serious High priority Compromised account with system access, phishing link clicked An employee account has been taken over
P3 – Moderate Limited impact Suspicious activity without confirmed compromise, isolated malware find Antivirus catches malware on a single device
P4 – Low Informational General phishing without any clicks, threats without consequence Employee reports spam email

4. The Incident Response Process (PICERL)

Phase 1 – Preparation (ongoing, not during an incident)

  • Maintain this plan and the contact list (see Appendix A)
  • Ensure all systems have up-to-date backups and test them quarterly
  • Enforce MFA on all accounts (email, cloud services, VPN)
  • Conduct at least one simulated phishing exercise and IRP walkthrough annually
  • Maintain an offline list of critical systems, vendors, and credentials

Phase 2 – Identification

Goal: Confirm an incident has occurred and determine its scope and severity.

  1. Receive report from employee, system alert, or external source
  2. Incident Commander assesses and classifies the incident (P1–P4)
  3. Document time of discovery, reporting party, and initial symptoms in the incident log (see Appendix B)
  4. Activate relevant team members based on classification:
    • P1/P2: Assemble the full IRT team
    • P3: Incident Commander + Technical Lead
    • P4: Technical Lead handles independently

Key questions to answer

  • What has been compromised? (systems, data, accounts)
  • When did the incident occur - and is it still active?
  • Does it involve personal data? (GDPR obligation)

Phase 3 – Containment

Goal: Stop the spread and limit the scope of damage.

Short-term containment (within hours):

  • Isolate compromised devices from the network (unplug cable / disable WiFi)
  • Disable compromised user accounts immediately
  • Block suspicious IP addresses or domains in firewall/DNS
  • Take screenshots and note observations before shutting down systems

Long-term containment (before recovery):

  • Implement temporary workarounds to maintain business operations
  • Monitor intensively for further activity
  • Do not delete logs or modify systems that may serve as evidence

Warning

Never delete logs or compromised files before they have been preserved as evidence.

Phase 4 – Eradication

Goal: Fully remove the root cause of the incident.

  • Identify and remove malware, backdoors, or malicious code
  • Reset all passwords for affected accounts (and related accounts as needed)
  • Patch or update vulnerable systems
  • Review access permissions and remove unnecessary privileges
  • Confirm the attack vector has been closed

Phase 5 – Recovery

Goal: Restore normal operations safely and in a controlled manner.

  • Restore from verified, clean backups
  • Bring systems online gradually and monitor intensively for a minimum of 72 hours
  • Verify system integrity before full reinstatement
  • Document when normal operations have resumed

Recovery priority:

  1. Critical business systems (email, payment systems, customer data)
  2. Internal productivity tools
  3. Non-critical systems

Phase 6 – Lessons Learned

Goal: Improve future response and prevent recurrence.

Hold a post-mortem meeting within 5 business days of the incident:

  • What happened, and when?
  • What worked well in our response?
  • What could we have done better?
  • What specific actions must be implemented? (with owner and deadline)

Update this plan based on the findings.


5. Communication

Internal Communication

  • The Incident Commander is the single point of contact - do not communicate broadly internally until the situation has been assessed
  • Use an out-of-band communication channel if email is suspected to be compromised (e.g. Signal, phone)
  • Brief leadership immediately for P1 and P2 incidents

External Communication

Recipient When Responsible
Data Protection Authority (GDPR) Within 72 hours of a breach involving personal data Communications Lead / Legal
Customers / Partners Only when required and after legal review Communications Lead
Police / National Cyber Authority For serious criminal attacks (ransomware, etc.) Incident Commander
Insurance company Immediately for P1 incidents (cyber insurance) Incident Commander
IT vendors / suppliers On an ongoing basis as needed Technical Lead

GDPR note

Personal data breaches must be reported to your national Data Protection Authority within 72 hours of discovery, unless the breach is unlikely to result in risk to individuals. Always document the decision to report or not to report.

Template: Internal Alert (P1/P2)

To: [IRT team]
Subject: 🚨 SECURITY INCIDENT – [Brief description] – [Date/time]

We have identified a potential security incident.

Type: [Ransomware / Data breach / Compromised account / Other]
Status: [Active / Under investigation / Contained]
Affected systems: [Systems/data]
Incident Commander: [Name]

Next update: [Time]
Contact: [Phone / Signal]

6. Evidence Preservation

The following must be documented and preserved as quickly as possible:

  • Screenshots of error messages, suspicious activity, or attack indicators
  • System and application logs (copy to a secure location)
  • Network logs from firewall/router
  • Timeline of observed events
  • Communications related to the incident (emails, messages)

Store evidence in an isolated and secure location. Consider legal chain of custody if criminal activity is suspected.


Appendix A - Contact List

Also maintain an offline copy (printed).

Role Name Phone Email
Incident Commander Primary PT +4528692480 pt@subscribed.dk
Backup MH +4553785353 michael@subscribed.dk
Technical Lead Primary PT +4528692480 pt@subscribed.dk
Backup SD +4525488636 sd@subscribed.dk
Communications Lead Primary MH +4553785353 michael@subscribed.dk
Backup PT +4528692480 pt@subscribed.dk
Legal / Compliance Primary CSL +4553633569 csl@subscribed.dk
Backup PT +454528692480 pt@subscribed.dk
External IT support / MSP N/A
Cyber insurance (claim no.) Tryg A/S +4578731962
Datatilsynet +4533 19 32 00 dt@datatilsynet.dk
Police (non-emergency) 114

Appendix B - Incident Log Template

INCIDENT LOG
============
Incident ID:      INC-[YYYY-MM-DD-XX]
Detected:         [Date and time]
Reported by:      [Name]
Classification:   P1 / P2 / P3 / P4

DESCRIPTION
-----------
[Brief description of what was observed]

TIMELINE
--------
[Date/time] – [Observation/action]
[Date/time] – [Observation/action]

AFFECTED SYSTEMS / DATA
-----------------------
[List of affected systems, data, users]

ACTIONS TAKEN
-------------
[Date/time] – [Who] – [What]

STATUS
------
[ ] Identification
[ ] Containment
[ ] Eradication
[ ] Recovery
[ ] Lessons Learned

GDPR RELEVANT: Yes / No
Reported to Data Protection Authority: Yes / No / Not required

9. Maintenance and Testing

Activity Frequency Responsible
Review and update of plan Annually (or after an incident) Incident Commander
Backup restoration test Quarterly Technical Lead
Phishing simulation Bi-annually Incident Commander
Tabletop exercise (scenario walkthrough) Annually Full IRT team
Contact list update Upon personnel changes Incident Commander

This document is confidential and should not be distributed outside the organization without authorization.