Cybersecurity Incident Response Plan (Sector & State-Specific)

Example Conversation

Below is an example of how a typical IRP session unfolds. The agent gathers the organization profile, maps regulatory obligations, generates state notification timelines, and iteratively validates the plan.

You: We need to create a cybersecurity incident response plan for our company. We’re a healthcare technology company — SaaS platform that processes patient data for hospitals. We operate in 12 states.

Agent: I’ll help you draft a NIST SP 800-61r3-aligned IRP. Let me gather your organization profile:

1. Which regulatory frameworks apply? Based on healthcare SaaS processing patient data, I’m assuming HIPAA at minimum. Do you also process payment card data (PCI DSS)?
2. Which 12 states do you operate in?
3. What data types do you handle? (PHI, PII, financial data, etc.)
4. What’s your infrastructure — cloud, on-premises, or hybrid? Which cloud providers?
5. What security tools are in place? (SIEM, EDR, SOAR, etc.)
6. Do you have cyber insurance? If so, does the policy specify approved forensic vendors or breach counsel?

You: HIPAA and we also accept credit cards so PCI DSS. States: CA, TX, NY, FL, IL, PA, OH, NC, CO, WA, MA, NJ. Data is PHI and PII, some payment card data. AWS us-east-1 and us-west-2. We have CrowdStrike EDR and Splunk SIEM. Yes, we have cyber insurance through Beazley — they have a panel of approved vendors.

Agent: Understood. Two sector-specific frameworks plus 12 states with varying notification laws. Let me run the breach notification mapper for your states…

Here’s your state notification timeline — note the critical findings:

State	Deadline	AG Notification	Key Notes
California	Expedient	Required (500+)	CCPA private right of action for unencrypted PI
North Carolina	30 days	Required	One of the strictest US timelines (SB 300, 2022)
New Jersey	30 days	Required	NJSA 56:8-166.1, effective 2023
Colorado	30 days	Required (500+)	Very strict
Washington	30 days	Required (500+)
Florida	30 days	Required (500+)
New York	Expedient	Required	SHIELD Act — notify AG, DFS, state police
Massachusetts	Expedient	Required	Must describe security steps taken
…	…	…	…

Important: You have 6 states with 30-day deadlines and 4 requiring AG notification. Your IRP must default to the most restrictive deadline — 30 days — for all notifications unless state-specific analysis confirms a longer window. Also, NY triggers NYDFS 23 NYCRR 500 (72-hour DFS notification) if any of your hospital customers are DFS-regulated.

For sector requirements:

• HIPAA: Individual notification within 60 days of discovery; HHS notification within 60 days for 500+ individuals; media notification for 500+ in a single state
• PCI DSS v4.0: Notify acquiring bank and card brands immediately; engage PCI Forensic Investigator; preserve evidence for 365 days

Let me now build the NIST phases. What does your current IR team look like — who’s on call for security incidents?

You: Our CISO leads IR, with a 3-person security team. We use a 24/7 MDR service from CrowdStrike for after-hours. We don’t have an outside forensics firm on retainer.

Agent: I recommend establishing a retainer with a Beazley-approved forensics firm before an incident occurs — it avoids delays during an active breach. I’ve noted this in the Prepare phase.

I’ve built the IRP structure and run the completeness checker. There are 3 errors:

• [ERROR] Missing detection playbooks — ransomware, BEC, and data exfiltration playbooks are required per NIST Prepare phase and cyber insurance underwriting standards
• [ERROR] Missing evidence preservation and chain of custody procedures — required for law enforcement referral and PCI DSS 365-day retention
• [ERROR] Healthcare/HIPAA sector: HIPAA Breach Notification Rule requirements not addressed in regulatory notifications

Let’s start with the ransomware playbook since that’s the highest-probability, highest-impact scenario for healthcare SaaS. What’s your backup strategy — and are backups air-gapped or isolated from the production environment?

Sample Output Excerpt

Below is a representative excerpt from a generated IRP, showing the Regulatory Notification Matrix and a Ransomware Playbook — the sections most critical during an active incident.

7. Regulatory Notification Matrix

Upon confirmation that a security incident constitutes a reportable breach under one or more of the following frameworks, the IR Lead and General Counsel shall initiate notifications per the timelines below. All notifications are coordinated through outside breach counsel to preserve attorney-client privilege.

10.1 Ransomware Detection and Response Playbook

Phase: Detect

• CrowdStrike EDR alert: RansomwareActivity, SuspiciousEncryption, or ShadowCopyDeletion
• Splunk SIEM correlation: high-volume file rename events (>1,000 files/minute with entropy change), vssadmin/wmic shadow delete commands, known ransomware C2 beacon patterns
• User reports: inability to open files, ransom note displayed

Phase: Analyze (concurrent with Detect)

• Determine scope: which hosts, network segments, data stores are affected
• Identify ransomware variant (file extension, ransom note content, YARA signature)
• Determine encryption status: in progress (containable) vs. complete
• Identify initial access vector: phishing email, exposed RDP, vulnerability exploit, supply chain
• Assess whether PHI or payment card data is in affected systems (triggers HIPAA and PCI notification)

Phase: Contain

1. Isolate affected systems — Network isolation via CrowdStrike network containment or VLAN changes. Do NOT power off systems (preserves memory artifacts).
2. Block C2 infrastructure — Add ransomware C2 domains/IPs to firewall and DNS sinkhole. Update threat intelligence feeds in Splunk.
3. Disable compromised accounts — Reset passwords and revoke active sessions for all accounts on affected systems. Revoke OAuth tokens and API keys.
4. Preserve forensic evidence — Capture memory dumps and disk images of affected systems BEFORE any remediation. Tag and document chain of custody.
5. Assess lateral movement — Review authentication logs for credential reuse across systems. Check for persistence mechanisms (scheduled tasks, services, registry run keys).

Phase: Coordinate (parallel)

• Legal hold: Activate immediately. Suspend all data destruction schedules for affected systems and user accounts.
• Outside counsel: Engage Beazley panel breach counsel within 1 hour.
• Cyber insurance: Notify Beazley claims within 2 hours. Do NOT engage non-panel forensics vendors.
• Law enforcement: Notify FBI field office if criminal prosecution is desired. Do NOT pay ransom without OFAC sanctions screening (risk of payment to designated entity/jurisdiction).
• Do NOT pay ransom without: (1) confirmation that payment would not violate OFAC sanctions, (2) legal counsel approval, (3) insurance carrier consultation, (4) assessment of data recovery alternatives.

Phase: Eradicate and Recover

1. Identify and remove persistence mechanisms on all affected and laterally-connected systems
2. Patch the exploited vulnerability or close the initial access vector
3. Rotate ALL credentials in the environment (not just affected accounts)
4. Restore from known-good backups — verify backup integrity before restoration (ransomware may have corrupted backups during dwell time)
5. Rebuild systems from gold images where backup integrity cannot be confirmed
6. Enhanced monitoring for 30 days post-recovery: watch for re-encryption, beacon activity, or new persistence

Phase: Post-Incident

• Lessons learned meeting within 2 weeks
• Root cause analysis documenting: initial access, dwell time, detection gap, containment effectiveness
• Update this playbook with new IOCs and detection rules
• Report MTTD and MTTR metrics to CISO and Board

Built-in Validation

The skill includes two validation tools: a completeness checker that validates the IRP against NIST phases and sector requirements, and a breach notification mapper that generates state-by-state notification timelines. The agent runs both automatically and surfaces gaps inline.

IRP Completeness Checker

Breach Notification Mapper

Covers all 50 US states plus DC with:

• Notification deadline (outer statutory limit for individual notification)
• AG notification requirement (required / not required, with resident thresholds)
• Special provisions (encryption safe-harbors, private rights of action, expanded PI definitions)

States with the strictest timelines (30 days): Colorado, DC, Florida, Maine, New Jersey, North Carolina, Utah, Washington, Wyoming.

Severity levels

• ERROR — A required IRP element is missing. The plan would fail a tabletop exercise, regulatory audit, or cyber insurance underwriting review.
• WARNING — A recommended element or sector-specific check that should be addressed based on the organization’s profile.

Example validation output

========================================================================
Cybersecurity IRP — Completeness Check (NIST SP 800-61r3, 2024)
========================================================================

--- Errors (must fix) ---
  [ERROR] Missing detection playbooks. Playbooks for ransomware,
    Business Email Compromise (BEC), and data exfiltration are required
    per NIST SP 800-61r3 Prepare phase and cyber insurance underwriting
    standards.
  [ERROR] Missing evidence preservation and chain of custody procedures.
    Required for law enforcement referral, regulatory defense, and
    CIRCIA forensic data requests. Note PCI DSS: 365-day retention;
    DFARS: 90-day image preservation.
  [ERROR] Healthcare/HIPAA sector: HIPAA Breach Notification Rule
    requirements not addressed (individual notification ≤60 days from
    discovery; HHS notification ≤60 days for 500+ individuals).

--- Warnings (recommended) ---
  [WARNING] Missing legal hold procedures. Legal hold activation
    (suspend data destruction, notify custodians) must be a Day 1
    action on any confirmed incident involving potential litigation
    or regulatory enforcement.
  [WARNING] Financial services sector: verify NYDFS 23 NYCRR 500 is
    addressed if the organization is licensed/registered with DFS
    (72-hour notification to DFS).

========================================================================

The agent runs both tools automatically — the completeness checker after building the IRP structure, and the breach notification mapper when states of operation are identified — so you always know what gaps remain before the plan is finalized.