xcPEP Incident Response Policy

xcPEP Incident Response Policy

 

1. Purpose and Scope

This Incident Response Policy establishes the framework for Advanced Structures India Private Limited's structured approach to managing security incidents that may impact the confidentiality, integrity, or availability of the xcPEP SaaS platform, its data, or related services. The policy aims to minimize the impact of incidents, facilitate rapid recovery, and ensure continuous improvement of our security posture.

2. Policy Objectives

  • To define clear roles and responsibilities for incident management.
  • To establish a systematic process for identifying, analyzing, containing, eradicating, and recovering from security incidents.
  • To minimize the business impact (financial, reputational, operational) of security incidents.
  • To ensure timely and effective communication with relevant stakeholders (e.g., customers, regulatory authorities).
  • To learn from incidents and continuously improve security controls and processes.
  • To comply with legal and regulatory incident reporting requirements.

3. Incident Response Team (IRT)

Advanced Structures India Private Limited maintains a dedicated Incident Response Team (IRT) comprising personnel from security, operations, legal, and communications. The IRT is responsible for executing the incident response plan.

4. Incident Response Lifecycle

Our incident response process follows a defined lifecycle based on industry best practices:

  • A. Preparation:
    • Training: Regular training and exercises for the IRT.
    • Tools & Resources: Ensuring necessary tools and resources are available (e.g., logging systems, forensic tools, secure communication channels).
    • Playbooks: Developing and maintaining detailed playbooks for various incident types.
    • Communication Plan: Establishing internal and external communication protocols, including stakeholder contact lists.
  • B. Identification:
    • Detection: Continuous monitoring of logs and alerts (as per xcPEP Logging and Monitoring Policy) for indicators of compromise.
    • Reporting: Clear channels for employees, automated systems, and customers to report suspected incidents.
    • Triage: Initial assessment to confirm if an incident has occurred and determine its severity and potential impact.
  • C. Containment:
    • Immediate Action: Taking rapid steps to prevent further damage or unauthorized access (e.g., isolating affected systems, blocking malicious IPs, disabling compromised accounts).
    • Evidence Preservation: Ensuring that relevant forensic evidence is preserved before taking containment actions.
  • D. Eradication:
    • Root Cause Analysis: Identifying the underlying cause of the incident (e.g., vulnerability exploited, misconfiguration, human error).
    • Removal of Threats: Eliminating the threat from the environment (e.g., removing malware, patching vulnerabilities, rebuilding compromised systems).
  • E. Recovery:
    • Restoration: Restoring affected systems and data from clean backups (as per xcPEP Backup and Recovery Policy).
    • Validation: Verifying that systems are fully functional and secure before returning to production.
    • Monitoring: Enhanced monitoring of recovered systems to detect any recurrence.
  • F. Post-Incident Activities:
    • Lessons Learned (Post-Mortem): Conducting a thorough post-mortem analysis to identify what went well, what could be improved, and actionable insights.
    • Remediation: Implementing corrective actions to address identified weaknesses and prevent similar incidents in the future.
    • Documentation: Maintaining comprehensive records of the incident, including timelines, actions taken, and findings.
    • Policy/Procedure Updates: Updating relevant policies, procedures, and playbooks based on lessons learned.

5. Communication and Notification

  • Internal Communication: Maintaining clear and timely internal communication channels within the IRT and with relevant management stakeholders.
  • External Notification:
    • Customers (Data Controllers): Notification to affected customers of Personal Data breaches will be conducted in accordance with the xcPEP Data Breach Notification Policy.
    • Regulatory Authorities: Notification to relevant data protection authorities as legally required.
    • Law Enforcement: Cooperation with law enforcement agencies when appropriate or required.

6. Incident Classification and Severity

Incidents are classified based on their severity and impact (e.g., Severity 1: Critical, Severity 2: High, etc.), which dictates response urgency and escalation paths, as defined in our xcPEP Support Policy.

7. Policy Review and Updates

This xcPEP Incident Response Policy is reviewed at least annually and updated as necessary to reflect changes in the threat landscape, our infrastructure, lessons learned from incidents, and evolving regulatory requirements.