7 Steps for Developing a Data Breach Response Plan

Data breaches are a constant threat these days. One click on a malicious link could send tons of customer information flying out the window. Even with all the strategies and tools to prevent them, unauthorized people keep gaining access to sensitive data.

So, maybe it’s not a matter of whether your company will ever experience a data breach but about when. The million-dollar question is: will you be ready to respond effectively against hackers when the time comes? Sure, that’s a sobering thought, but what if you could minimize the damage and bounce back quickly?

This guide provides all the essential steps to build a comprehensive, foolproof data breach response plan that will turn a potential disaster into a controlled situation.

• What is a data breach?
• What is a data breach response plan?
• Why do you need a data breach response plan?
• The NIST and SANS Institute frameworks
• 7 steps to creating an effective data breach response plan
• Developing a sure-fire data breach response plan: key takeaways

What is a data breach?

A data breach occurs when unauthorized individuals access sensitive information, like customer records, financial data, trade secrets, or intellectual property. They can happen intentionally, through hacking or other attacks, or unintentionally, thanks to human error or system vulnerabilities.

The consequences can be severe. According to Statista, data breaches exposed over eight million records globally in the fourth quarter of 2023 alone.

No wonder it’s one of the biggest concerns business leaders have. After all, breaches can lead to massive financial losses, reputational damage, and even legal repercussions.

Even the best contact center solutions and teams may need performance optimization during a data breach. Imagine hundreds, maybe thousands, of concerned customers, calling with their anxieties and (completely understandable) frustration.

What is a data breach response plan?

Many organizations just laser-focus on network defense, stacking layers and layers of tools, technologies, and strategies to prevent security incidents.

So, you have firewalls standing guard, and intrusion detection systems (IDS) scanning for threats. You have access controls keeping unauthorized users out. The whole nine yards.

But sometimes, even all that’s not enough—even sturdy walls can have loopholes. What happens when a data breach occurs despite your efforts?

A data breach response plan is a structural approach that outlines the steps and procedures you must follow when a breach occurs. With that emergency playbook in place, you’re in a better position to minimize a breach’s impact and work towards returning to normal operations.

Why do you need a data breach response plan?

There are cyber attack reports everywhere you turn. And yet, according to a 2024 tech.co report, more than a quarter of businesses are unsure of their company’s ability to defend and respond to a data breach. That's pretty worrying.

Here are some key reasons why you need a robust response plan.

1. Save costs

As you can imagine, a data breach can be costly. According to IBM’s Cost of a Data Breach Report 2023, the global average cost of a data breach that year was $4.45 million, up 15% over three years.

So, you’re likely going to lose some money anyway. However, swift action can significantly save businesses money. The report from the previous year highlights that organizations that could prevent data breaches in under 200 days saved over $1.12 million on average.

2. Minimize the damage

Data breaches can cause service disruptions, data exposure, losses, and reputational damage. Even minor breaches can cause customers to lose trust in your business. A data breach response plan cannot guarantee that all that will disappear but it can significantly reduce the impact.

For instance, proper contact center management aims to keep downtimes low because an outage is one of the worst things for a business. If a data breach occurs, clear protocols for restoring your systems and operations will ensure minimal disruption to customer service so that clients are the least disgruntled possible in such a situation.

3. Regulatory compliance

Some industries expect organizations to have a security incident or data breach response plan. If you fall into such a jurisdiction and don’t have one (or comply), you’re setting your company up for steep fines or legal repercussions.

These are some guidelines in the United States:

• HIPAA - Security Rule §164.308(a)(6)(i).
• Federal Trade Commission 16 CFR - §314.4(h).
• Payment Card Industry (PCI) - Rule 12.10.
• New York Department of Financial Services (NYDFS) Cybersecurity Regulation (23 NYCRR 50) - Section 500.16.
• Gramm-Leach-Bliley Act - § 314.4(h).
• Massachusetts 201 CMR - Section 17.03(2)(j)

4. Reduce the risk of legal repercussions

In the case of a severe data breach, some people will try to seek compensation, whether the lead-up to it was intentional or not. You can be ill-equipped to handle this legal aftermath without a solid data breach response plan.

That’s because your plan comes with procedures for assessing the breach, notifying affected customers and parties, and how you can cooperate with regulatory procedures. You’re bound to skip something that will come back to haunt you if you’re only thinking and executing on your feet.

The NIST and SANS Institute frameworks

Now that you understand the importance of having a data breach response plan let’s explore how you can build one.

The good news is that you're not starting from scratch. The National Institute of Standards and Technology (NIST) and the SANS Institute have released systemic approaches (or frameworks) for incidence responses. They’re for cybersecurity incidents in general but apply to data breaches.

Here are the phases of the NIST Cybersecurity Incident Response Plan:

• Preparation
• Detection and Analysis
• Containment
• Eradication
• Recovery
• Post-Incident Activity

On the other hand, the SANS Institute separates a response plan into six stages:

• Preparation
• Identification
• Containment
• Eradication
• Recovery
• Lessons Learned

Both frameworks will provide valuable insights for building your organization's unique plan. In the coming sections, we’ll touch on various phases.

7 steps to creating an effective data breach response plan

With a well-defined data breach response plan, you’re not left scrambling from the impact of a data breach and making random decisions that could dig you into a deeper hole. Instead, you can take control and respond with precision.

Here are six steps to building your ideal emergency playbook:

1. Assess your current risks and security measures

First, you want to have a full grasp of your existing security posture, as well as the potential issues that threaten your data. In doing so, you’re auditing your defense and checking for existing loopholes.

These are some of the questions you need answers to:

• What are the potential entry points for cyber threats?
• What are the biggest threats to our data security?
• Are the employees trained, loyal, and competent?
• How effective are our current security measures? Where do they fall short?
• Have we conducted recent vulnerability assessments and penetration tests to identify weaknesses?
• Do we have procedures for employees to report suspicious activity or potential issues?
• Have there been previous breaches? What was targeted? Have we fixed the vulnerabilities?

In short, understand the risks (internal, industry-specific, etc.) and your existing defenses (technical, administrative, physical), and then carry out vulnerability assessments.

2. Define roles and responsibilities

A data breach response is complex, especially if it follows a major security incident. A coordinated effort is essential to stemming the tide and recovering quickly.

Generally, there are no fixed roles, but a typical data breach response team consists of:

• Team leader: You may have sub-teams, each with its own leader in charge of security, but you want someone to oversee the overall effort, delegate, and make decisions.
• IT security: The frontlines of the response. They identify, contain, investigate, and implement.
• Legal: Guides on legal obligations and potential liabilities associated with the breach.
• Communications: Comms manages internal and external messaging with relevant stakeholders and the general public.
• Customer support: Communicates with affected customers. Support informs them about the incident and any subsequent steps they may need.
• HR: This is especially essential when the breach involves current or former employees.
• Management: Their leadership and decision-making are critical during a crisis.

3. Create a communication plan

In 2017, leading consumer credit reporting company Equifax suffered a monstrous data breach that exposed the highly sensitive personal information of 147 people.

The firm held on to that information for 40 days before informing the public. Stephen Gandel, a journalist, detailed the bizarre communication chain of events, including the board's becoming aware of the hack weeks after it happened.

A data breach is usually a PR nightmare, but effective communication helps you weather it. You need pre-defined messages tailored to each audience so you can notify them immediately. And you must be transparent, even if you expect harsh pushback.

4. Develop a containment, eradication, and recovery strategy

We've learned from frameworks like NIST and SANS that data breach response is a multi-phase process.

Data breaches are time-sensitive events and every second counts. Each phase requires specific actions to contain the damage and effectively restore normalcy. That’s why you must set up workflows outlining your teams' specific steps at each stage.

For instance, here’s what a workflow could look like for system isolation in the containment phase:

• Check logs and system activity for signs of compromise.
• Prioritize systems based on how critical they are.
• Immediately disconnect affected systems or networks from the other infrastructure.
• Disable external connectivity.
• Implement access controls and restrictions.

5. Train your team

A single employee’s mistake caused that catastrophic data breach in 2017, according to Richard F. Smith, Equifax’s former CEO. This individual ignored security warnings and didn’t implement vital security fixes. It wasn’t malicious or intended, but 147 million Americans (plus the company’s reputation and bottom line) paid for it.

Here’s the thing: while the former chief executive attributed the breach to one staff member's mistake, the bigger picture reveals that Equifax may have lacked robust security awareness training.

Your data breach response plan can cover training on:

• Fundamentals of data security
• Your organization's data security policies
• Common social engineering tactics and how to avoid them
• Incident response procedures
• Simulations to test their readiness
• A security-minded work culture

6. Review the incident response execution

While you’re struggling through it, you won't think so, but a data breach presents a valuable learning opportunity. After the dust settles, you want to review your plan execution to identify areas for extensive improvement. That way, you’re strengthening your security posture.

Answer these and other relevant questions:

• How quickly did you detect the breach?
• Did the team respond fast enough?
• Did team members perform as planned?
• Did they have access to the tools and expertise needed?
• How long did each response phase take?
• Were there any communication breakdowns or delays?
• Were all affected systems restored, and was data loss minimized?

7. Test your plan

The IBM study referenced earlier found that organizations that regularly tested their incident response plans saw an average of $2.66 million lower in breach costs than those without a plan and didn’t bother to test their plans.

You’ve learned about the best practices, put in the research, and crafted a solid data breach response plan. Well, at least you consider it so. How do you know it will work in the real world? You don’t — until you test it.

Even if you’re not motivated enough to do so, some compliance frameworks, like PCI DSS and SOC, demand annual tests. Depending on your company’s risk level, you should probably push that up to semi-annually or quarterly.

These are the most common ways to go:

• Table-top exercises: This is the most basic approach. Gather your data breach response team members and key stakeholders in a conference room. Walk them through a simulated breach scenario, where they discuss their roles, responsibilities, and other aspects, like communication channels.
• Simulated attacks: A more realistic approach. Here, testers from your security team or external parties fake attacks on your systems or networks. They can be pre-coordinated simulations or blind attacks.

Developing a sure-fire data breach response plan: key takeaways

No organization wants to experience a data breach's loss, damage, and pressure. Still, with cybersecurity incidents on a steady rise, you’re much better off preparing to respond to a breach than simply hoping your security measures prevent common cybersecurity attacks.

This article highlighted and discussed seven essential steps to creating a data breach response plan that can quickly set you on the road to recovery. Preparation is your best defense against data breaches; a response plan is another way to prepare.