If we accept that data breaches and other cyber-incidents are inevitable then it makes sense to have a plan in place to not only protect your assets but to ensure you communicate to customers and the public quickly, accurately and authoritatively.
Wayne Tufek, from CyberRisk, discussed what he considers the key elements of a cyber incident response plan.
Tufek says the first step is to have a plan with designated team members who are trained in their roles within the plan. It’s important to test the plan at least annually.
By having the plan ready and tested, it makes it possible to mobilise quickly and get on the front foot during the initial stages where your company’s reputation can be damaged simply by a slow response and poor communication.
Within that plan, you need to have appropriate communications such as press releases, emails and social media posts drafted. This will ensure some control of the messaging and that errors aren’t made during the frenetic first moments after an incident is detected. This is critical as poor communications will potentially give the media to report on a poor response rather than the specifics of the incident.
It’s important to acknowledge in those statements what you do and don’t know. There’s a fine line between releasing not enough and too much information. Be honest, acknowledge the facts and note that information provided, especially during the initial period following the breach, may be incomplete.
Tufek says there are several things that should be addressed in the initial communications. These are attribution, how attack happened, is it incident over or contained, and can it or will it happen again
The media may have contacts within your organisation so internal communications should not be neglected. Provide statements to your internal personnel so that they can respond to customers, media and partners with a common message and have your call centre ready for increased call volumes.
In order to be ready for the expected influx of communications, Tufek cited the example of American health insurer Anthem. As part of their incident response plan, Anthem has a dark web site – a site that was ready but not public – in place so anyone making inquiries as to what was happening could be quickly referred to a single authoritative information source.
Don’t forget social
When an American Airlines plane was forced to make an emergency landing in the Hudson River in 2009, the first pictures came from a Twitter user catching a ferry on the river. Just 32 minutes after the picture was taken, the photographer was being interviewed live on MSNBC and his picture, originally shared to fewer than 130 people, was being used by news agencies across the world.
Social media means news travels fast. The Target breach on late 2013 was reported by Brian Krebs six days before target acknowledged the incident.
Establishing a two-way communication strategy across multiple social platforms should be an integral part of your cyber incident response plan. This can include video messages, social media, press releases, and store signage.
The goal is to satisfy the audience and provide sufficient information but not have to issue corrections as this affects credibility, and to tell your side of the story before other parties build stories based on speculation and innuendo.
One challenge for companies is the question of disclosure. Although Australia does not yet have mandatory disclosure laws, Tufek notes the Office of the Australian Information Commissioner recommends appropriate disclosures are made.
Although the word “appropriate” may seem to be indeterminate, the Privacy Act suggests that having a well formulated plan that is tested is reasonable and this may assist with avoiding penalties.
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