ISO/IEC 27001

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Information Security Incident Management Policy

1. Purpose

The Information Security Incident Management Policy establishes the organization’s approach for identifying, reporting, assessing, responding to, recovering from, and learning from information-security incidents.

The objective is to ensure that information-security events are:

  • Identified promptly
  • Reported through defined channels
  • Assessed consistently
  • Classified according to risk and impact
  • Contained appropriately
  • Investigated using reliable evidence
  • Communicated to relevant stakeholders
  • Recovered in a controlled manner
  • Recorded and tracked
  • Reviewed for lessons learned
  • Used to improve information-security controls

The policy supports the organization’s Information Security Management System (ISMS) and should be implemented proportionately to the organization’s size, risk profile, business requirements, contractual obligations, and applicable legal and regulatory requirements.


2. Scope

This policy applies to information-security incidents involving:

  • Information assets
  • Information systems
  • Cloud environments
  • Applications
  • Networks
  • Databases
  • Endpoints
  • Mobile devices
  • Identity and access systems
  • Physical information assets
  • Customer information
  • Personal information
  • Confidential information
  • Source code
  • Credentials and secrets
  • Suppliers and third parties
  • Cloud service providers
  • SaaS applications
  • Software and technology dependencies
  • Employees, contractors, and other authorized users

The policy applies to employees, contractors, temporary personnel, suppliers, and other parties whose activities may affect the organization’s information security.


3. Information Security Incident Management Principles

The organization shall manage information-security incidents according to the following principles:

  1. Report early — suspected incidents should be reported promptly.
  2. Assess before concluding — alerts and unusual activity should be validated.
  3. Contain appropriately — actions should limit further impact.
  4. Preserve evidence — relevant evidence should be protected from unnecessary alteration.
  5. Protect confidentiality — incident information should be shared only with authorized parties.
  6. Maintain business continuity — response actions should consider business impact.
  7. Meet obligations — applicable legal, regulatory, contractual, and customer requirements should be considered.
  8. Document decisions — significant actions and decisions should be traceable.
  9. Learn from incidents — significant incidents should contribute to corrective action and continual improvement.

4. Definitions

Information Security Event

An observed occurrence that may indicate a security issue but has not yet been established as an incident.

Examples:

  • Multiple failed login attempts
  • Unusual network traffic
  • Malware alert
  • Unexpected configuration change

Information Security Incident

A single or series of unwanted or unexpected information-security events that has a significant probability of compromising information security or disrupting business operations.

Security Alert

A notification generated by a security tool, monitoring system, supplier, employee, or other source indicating potentially suspicious activity.

Data Breach

An incident involving unauthorized access to, disclosure, alteration, loss, or destruction of protected information, where applicable under relevant law or contractual requirements.

Major/Critical Incident

An incident whose impact or potential impact requires significant management involvement, coordinated response, or urgent escalation.


5. Incident Management Lifecycle

The organization shall manage incidents through an appropriate lifecycle:

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

Not every security event will require every stage. The response should be proportionate to the nature and severity of the event.


6. Incident Sources

Information-security events may be identified through:

  • Employees
  • Customers
  • Security monitoring
  • SIEM
  • EDR
  • Cloud security tools
  • Vulnerability scanners
  • Application monitoring
  • Network monitoring
  • IAM systems
  • Audit logs
  • Penetration testing
  • Internal audits
  • Supplier notifications
  • Cloud provider notifications
  • Threat intelligence
  • Security researchers
  • Automated alerts
  • Physical security systems

The organization should provide practical mechanisms for reporting suspected incidents.


7. Incident Reporting

All personnel should promptly report suspected information-security incidents through the organization’s approved reporting channel.

Reports should contain, where available:

  • Reporter
  • Date and time
  • Description of event
  • Affected system
  • Affected information
  • Location/environment
  • Source of detection
  • Users involved
  • Initial impact
  • Evidence available
  • Actions already taken

Employees should not conceal, intentionally delay, or independently suppress a suspected security incident.

Where immediate containment is required, personnel may take reasonable emergency action within their authority and should report the action as soon as practical.


8. Incident Validation

The designated security or incident-management team shall assess whether a reported event is:

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

Validation may include:

  • Reviewing logs
  • Checking authorized changes
  • Confirming affected identities
  • Reviewing system activity
  • Checking vulnerability information
  • Reviewing relevant evidence
  • Contacting system owners
  • Engaging suppliers

The organization should avoid declaring an incident solely on the basis of an automated alert without reasonable validation where practical.


9. Incident Classification

Incidents should be classified using an approved severity methodology.

An illustrative classification is:

SeverityTypical Characteristics
LowLimited security impact and no significant business disruption
MediumMeaningful security issue requiring coordinated response
HighSignificant impact to systems, information, customers, or operations
CriticalMajor compromise, widespread impact, significant customer/data exposure, or critical business disruption

Classification should consider:

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

The organization may define different thresholds appropriate to its environment.


10. Incident Escalation

Incidents shall be escalated according to severity and business impact.

Escalation may involve:

  • Security leadership
  • IT/Cloud team
  • Application owners
  • Business owners
  • Senior management
  • Privacy team
  • Legal counsel
  • Compliance
  • Communications team
  • Supplier management
  • Cloud provider
  • External incident-response specialists

Critical incidents should have a clearly identified incident manager responsible for coordinating response activities.


11. Roles and Responsibilities

RoleResponsibility
All PersonnelReport suspected incidents and cooperate with investigations
Incident ManagerCoordinate incident response
Security Lead/CISODirect security assessment and response
IT/Cloud TeamContainment, technical investigation, and recovery
Application OwnerAssess application impact and support recovery
Business OwnerAssess business impact and service priorities
Privacy/Data Protection OwnerAssess privacy and personal-data implications
Legal/ComplianceAssess legal, regulatory, and contractual requirements
Supplier OwnerCoordinate incidents involving suppliers
Communications LeadCoordinate approved internal/external communications
ManagementProvide decisions, resources, and risk acceptance where required

One person may perform multiple roles in a startup, but responsibilities should remain clear.


12. Incident Response Team

The organization should maintain an appropriate incident-response capability.

Depending on organizational size, this may include:

  • Incident Manager
  • Security Lead
  • Cloud/Infrastructure Engineer
  • Application Engineer
  • IT/IAM Administrator
  • Privacy/Compliance representative
  • Legal representative
  • Business representative
  • Communications representative

External specialists may be engaged when internal capability is insufficient.


13. Immediate Response and Containment

Response actions should seek to prevent further damage while preserving evidence where practical.

Potential containment actions include:

  • Disabling compromised accounts
  • Revoking sessions
  • Blocking malicious traffic
  • Isolating endpoints
  • Restricting network access
  • Removing unauthorized access
  • Disabling compromised API keys
  • Rotating credentials
  • Isolating cloud workloads
  • Blocking malicious domains/IPs
  • Restricting affected applications
  • Suspending compromised integrations

Containment actions should consider:

  • Business impact
  • Evidence preservation
  • Customer impact
  • Safety
  • Recovery requirements

14. Evidence Preservation

Relevant evidence should be preserved where necessary for:

  • Investigation
  • Root-cause analysis
  • Regulatory requirements
  • Contractual requirements
  • Legal proceedings
  • Insurance requirements
  • Corrective actions

Evidence may include:

  • Audit logs
  • Authentication logs
  • Network logs
  • Application logs
  • Cloud logs
  • Endpoint information
  • Security alerts
  • Emails
  • Screenshots
  • System configurations
  • Access records
  • Vulnerability reports
  • Incident tickets
  • Supplier communications

Evidence should be protected from unauthorized modification and access.

Actual credentials, 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:

What happened?

  • What event occurred?
  • When did it occur?
  • How long did it continue?

How did it happen?

  • Compromised credentials?
  • Vulnerability?
  • Misconfiguration?
  • Phishing?
  • Malware?
  • Supplier compromise?
  • Insider activity?
  • Software supply-chain issue?

What was affected?

  • Systems
  • Applications
  • Infrastructure
  • Accounts
  • Networks
  • Information
  • Customers

What information was involved?

  • Public
  • Internal
  • Confidential
  • Customer
  • Personal
  • Financial
  • Source code
  • Credentials

What was the actual impact?

The investigation should distinguish between:

  • Suspected exposure
  • Confirmed access
  • Confirmed modification
  • Confirmed disclosure
  • Confirmed destruction

16. Information and Data Impact Assessment

For incidents involving information, the organization should determine:

  • Type of information
  • Classification
  • Owner
  • Location
  • Number of records, where known
  • Customer involvement
  • Personal-data involvement
  • Confidentiality impact
  • Integrity impact
  • Availability impact
  • Evidence of unauthorized access
  • Evidence of exfiltration
  • Retention requirements

Where personal information may be involved, the appropriate privacy/legal process should be initiated.


17. Supplier and Third-Party Incidents

Where an incident involves a supplier, the organization should:

  1. Identify the affected supplier.
  2. Identify the affected service.
  3. Determine what information or systems are involved.
  4. Review contractual notification requirements.
  5. Contact the supplier through the approved channel.
  6. Obtain available incident information.
  7. Assess organizational impact independently.
  8. Track supplier containment and corrective actions.
  9. Assess residual risk.
  10. Update supplier records where necessary.

Examples include:

  • Cloud provider incident
  • SaaS compromise
  • Supplier credential compromise
  • Third-party data breach
  • Software supply-chain compromise
  • Managed-service-provider incident

18. Cloud Incidents

Cloud incidents should be handled using the organization’s Cloud Incident Response Procedure.

Examples include:

  • Compromised cloud administrator account
  • Unauthorized IAM role assumption
  • Publicly exposed storage
  • Compromised cloud workload
  • Unauthorized security-group modification
  • Cloud database exposure
  • Compromised API credentials
  • Cloud cryptomining
  • CI/CD compromise

Relevant cloud logs and provider evidence should be preserved.


19. Cybersecurity Incident and Business Continuity

Where an incident affects availability or critical business operations, incident management should coordinate with:

  • Business Continuity Plan
  • Disaster Recovery Plan
  • Cloud Backup and Recovery Procedure
  • Crisis Management Process

For example:

Cyber Incident → Containment → Determine Service Impact → Activate Recovery → Restore Service → Validate Security → Resume Operations

Security recovery should not introduce the original compromise again.


20. Communication

Incident information should be communicated on a need-to-know basis.

Internal communication may include:

  • Incident status
  • Affected systems
  • Required actions
  • Business impact
  • Recovery status
  • Management decisions

External communication may involve:

  • Customers
  • Suppliers
  • Cloud providers
  • Regulators
  • Law enforcement
  • Insurance providers
  • Other contractual stakeholders

Only authorized personnel should issue external communications.

The organization should avoid unverified conclusions or speculative statements.


21. Legal, Regulatory and Contractual Notifications

For relevant incidents, the organization shall determine whether notification obligations exist under:

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

The appropriate legal, privacy, compliance, and management personnel should participate in these decisions.

Notification timelines should be based on the applicable requirement rather than an arbitrary internal assumption.


22. Eradication

After containment and investigation, the organization should remove the cause of the incident where practical.

Actions may include:

  • Removing malware
  • Patching vulnerabilities
  • Correcting misconfigurations
  • Removing unauthorized accounts
  • Removing malicious code
  • Rotating compromised credentials
  • Rebuilding systems
  • Replacing compromised components
  • Removing unauthorized integrations
  • Strengthening security controls

For significant incidents, rebuilding affected systems from trusted configurations may be preferable to attempting to clean compromised systems in place.


23. Recovery

Recovery activities should include:

  • Restoring systems
  • Restoring information
  • Rebuilding infrastructure
  • Reconfiguring security controls
  • Validating authentication
  • Validating access controls
  • Validating monitoring
  • Testing application functionality
  • Validating data integrity
  • Monitoring for recurrence

Recovery should be coordinated with business owners and system owners.


24. Incident Closure

An incident may be closed when:

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

Closure does not necessarily mean every corrective action has already been completed. Outstanding actions should remain tracked until resolved or formally risk-accepted.


25. Root Cause Analysis

Significant incidents should undergo root-cause analysis.

The organization should distinguish:

Immediate cause

What directly caused the incident?

Contributing factors

What conditions made the incident possible or increased its impact?

Root cause

What underlying weakness allowed the incident to occur or persist?

Example:

Incident: Unauthorized access to production environment

Immediate cause: Compromised credentials

Contributing factors:

  • Excessive permissions
  • Weak credential controls
  • Limited monitoring

Underlying control weaknesses:

  • Inadequate privileged-access management
  • Insufficient access review
  • Incomplete MFA enforcement

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


26. Corrective Actions

Incident findings should be recorded and tracked through the organization’s corrective-action process.

Actions may include:

  • Control improvements
  • Policy updates
  • Access changes
  • Security configuration changes
  • Vulnerability remediation
  • Additional monitoring
  • Employee awareness
  • Supplier requirements
  • Architecture changes
  • Backup improvements
  • Incident-response improvements
  • Risk treatment

Each significant action should have:

  • Finding
  • Risk
  • Root cause
  • Action
  • Owner
  • Due date
  • Status
  • Evidence
  • Verification
  • Closure

27. Lessons Learned

For significant incidents, the organization should perform a post-incident review.

The review should consider:

  • How was the incident detected?
  • Was detection sufficiently timely?
  • Was escalation effective?
  • Were roles clear?
  • Were logs sufficient?
  • Was evidence available?
  • Was containment effective?
  • Was recovery effective?
  • Were communications appropriate?
  • Were customer obligations met?
  • What controls failed?
  • What controls were missing?
  • What should change?

Lessons learned should feed into the ISMS improvement process.


28. Incident Testing and Exercises

The organization should periodically test its incident-management capability where appropriate.

Testing may include:

  • Tabletop exercises
  • Simulated phishing
  • Cloud compromise scenarios
  • Ransomware scenarios
  • Data-breach exercises
  • Lost-device scenarios
  • Supplier incident scenarios
  • Credential compromise exercises
  • Business continuity exercises

Exercises should evaluate the organization’s ability to:

  • Detect
  • Report
  • Escalate
  • Contain
  • Communicate
  • Recover
  • Document
  • Learn

Test findings should be tracked as corrective actions.


29. Incident Records

The organization should maintain appropriate records of information-security incidents.

Typical records include:

  • Incident ID
  • Date/time detected
  • Date/time reported
  • Reporter
  • Incident category
  • Affected systems
  • Affected information
  • Classification
  • Severity
  • Incident owner
  • Investigation
  • Evidence
  • Containment
  • Root cause
  • Impact assessment
  • Communications
  • Recovery
  • Corrective actions
  • Residual risk
  • Closure date
  • Approval
  • Lessons learned

The level of documentation should be proportionate to incident severity.


30. Incident Categories

The organization may categorize incidents such as:

  • Unauthorized access
  • Account compromise
  • Malware
  • Phishing
  • Ransomware
  • Data exposure
  • Data breach
  • Information leakage
  • Denial of service
  • Vulnerability exploitation
  • Cloud misconfiguration
  • Insider incident
  • Lost or stolen device
  • Physical security incident
  • Supplier incident
  • Software supply-chain incident
  • Credential compromise
  • Policy violation
  • Availability incident

The organization may add categories relevant to its environment.


31. Metrics and Management Reporting

Management may monitor appropriate incident-management metrics, such as:

  • Number of incidents
  • Number by severity
  • Number by category
  • Mean time to detect
  • Mean time to respond
  • Mean time to contain
  • Mean time to recover
  • Repeated incidents
  • Incidents involving suppliers
  • Incidents involving customer information
  • Open corrective actions
  • Overdue corrective actions
  • Incident exercise findings

Metrics should be used to identify trends and improvement opportunities rather than merely to count incidents.


32. Startup-Friendly Implementation

A startup can establish effective incident management without building a large security operations center.

A practical initial model includes:

People

  • Incident owner
  • Technical responder
  • Management escalation point
  • Privacy/legal contact where relevant

Technology

  • Centralized cloud logging
  • IAM monitoring
  • Endpoint protection
  • Vulnerability scanning
  • Security alerting
  • Secure backup

Process

  • Incident reporting channel
  • Severity matrix
  • Escalation process
  • Incident register
  • Response procedures
  • Recovery process
  • Corrective-action tracking

Evidence

Maintain enough evidence to demonstrate:

Detection → Assessment → Response → Recovery → Closure → Improvement

As the company grows, it can add SIEM, 24×7 monitoring, dedicated incident response, forensic capability, and external response providers.


33. Relationship With Other ISMS Documents

DocumentRelationship
Information Security PolicyEstablishes overall information-security direction
Risk Management ProcedureProvides risk assessment and treatment methodology
Incident RegisterRecords security incidents
Cloud Incident Response ProcedureProvides cloud-specific response activities
Data Breach ProcedureHandles privacy/data-breach requirements
Vulnerability Management ProcedureHandles vulnerability-related issues
Supplier Incident Response ProcedureHandles supplier incidents
Cloud Backup and Recovery ProcedureSupports recovery of cloud services
Business Continuity PlanSupports business continuity
Disaster Recovery PlanSupports technical recovery
Corrective Action RegisterTracks remediation
Risk RegisterRecords significant residual risks
Supplier Monitoring ProcedureAddresses supplier-related monitoring
Lessons Learned RegisterRecords improvement opportunities

34. Internal Audit Checklist

An auditor can verify:

  • Information-security incident-management policy is approved.
  • Incident roles and responsibilities are defined.
  • Incident reporting mechanisms exist.
  • Events and incidents are distinguished.
  • Incident classification criteria exist.
  • Escalation requirements are defined.
  • Incident-response procedures exist.
  • Evidence preservation is addressed.
  • Confidentiality of incident information is addressed.
  • Supplier incidents are covered.
  • Cloud incidents are covered.
  • Personal-data incidents are assessed.
  • Legal/regulatory obligations are considered.
  • Business continuity and recovery are integrated.
  • Incident records are maintained.
  • Significant incidents receive root-cause analysis.
  • Corrective actions are tracked.
  • Lessons learned are captured.
  • Incident-response exercises are performed where appropriate.
  • Management receives appropriate incident information.
  • Incident trends are reviewed.
  • The ISMS is improved based on incident experience.

35. ISO 27001 Connection

Information-security incident management should be implemented as part of the organization’s risk-based ISMS.

The organization should establish the applicable requirements through:

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

This policy establishes the governance framework. It does not by itself demonstrate that incident management is operating effectively.

Operational evidence may include:

  • Incident records
  • Investigation records
  • Security alerts
  • Logs
  • Escalation records
  • Containment evidence
  • Recovery evidence
  • Notification records
  • Corrective actions
  • Lessons learned
  • Incident exercises

36. Final Information Security Incident Management Audit Trail

A complete incident-management lifecycle should produce:

Security Event
→ Reported
→ Validated
→ Classified
→ Assigned
→ Escalated
→ Contained
→ Evidence Preserved
→ Investigated
→ Impact Assessed
→ Eradicated
→ Recovered
→ Communications Completed
→ Residual Risk Assessed
→ Corrective Actions Assigned
→ Lessons Learned
→ Management Review
→ Incident Closed
→ ISMS/Risk/Controls Improved


37. Final Principle

Effective Information Security Incident Management = Detect + Report + Assess + Contain + Investigate + Recover + Learn + Improve

The objective 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 residual risk remains, what corrective actions were taken, and how the incident improved the organization’s security controls.

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