Sample Incident Response Plan for RIA and Accounting Firm 1. Purpose This Incident Response Plan (IRP) outlines procedures for identifying, responding to, and recovering from cybersecurity incidents (e.g., ransomware, data breaches, phishing) to protect client data, ensure business continuity, and comply with SEC (Regulation S-P, Form 8-K) and IRS (IRC Section 7216) requirements. 2. Scope Applies to all employees, contractors, and third-party vendors handling firm systems or client data (e.g., PII, tax records, investment portfolios). Covers incidents impacting confidentiality, integrity, or availability of data or systems. 3. Incident Response Team Role Responsibility Contact Incident Response Coordinator (Compliance Officer) Leads response, coordinates reporting compliance@firm.com, (555) 123-4567 IT Manager Isolates systems, restores backups it@firm.com, (555) 123-4568 CEO/Partner Approves major decisions (e.g., ransom payment) ceo@firm.com, (555) 123-4569 Legal Counsel Assesses liability, manages notifications legal@firm.com, (555) 123-4570 Accounting Lead Verifies financial data integrity accounting@firm.com, (555) 123-4571 HR Manager Handles employee communications, training hr@firm.com, (555) 123-4572 External Vendor (IT/Cyber Insurance) Provides technical support, insurance claims vendor@support.com, (555) 123-4573 4. Incident Definitions Incident: Any event compromising data security or system availability (e.g., unauthorized access, malware). Material Incident: An incident likely to significantly impact operations, clients, or compliance (e.g., PII breach requiring SEC Form 8-K). Examples: Ransomware, phishing, insider threats, system outages. 5. Response Phases 5.1 Preparation Training: Annual phishing and cybersecurity training for all staff. Backups: Maintain offline, encrypted backups of client data, tested monthly. Tools: Deploy endpoint detection, email filters, and multi-factor authentication (MFA). Testing: Conduct quarterly TTXs (e.g., ransomware simulation) and update plan based on findings. Documentation: Keep an updated Written Information Security Plan (WISP) per SEC and IRS requirements. 5.2 Identification Detection: Monitor for anomalies (e.g., unusual file activity, login attempts) using SIEM tools or IT alerts. Reporting: Employees report suspected incidents to the Coordinator within 1 hour via email or phone. Assessment: IT Manager confirms incident scope (e.g., systems affected, PII exposed) within 2 hours. Example: Phishing email opens malware; IT detects encrypted files. 5.3 Containment Short-Term: Isolate affected systems (e.g., disconnect workstation, disable network access) within 15 minutes. Long-Term: Apply temporary patches or restrict access to prevent spread (e.g., firewall rules). Preservation: Log all actions and preserve evidence (e.g., malware samples) for forensic analysis. 5.4 Eradication Remove Threat: IT Manager removes malware (e.g., using antivirus) and patches vulnerabilities (e.g., update Windows Server) within 24 hours. Verify: Ensure no residual threats remain via scans. Coordinate: Engage external vendor if needed (e.g., for advanced forensics). 5.5 Recovery Restore Systems: IT Manager restores data from offline backups within 48 hours, verifying integrity. Test: Accounting Lead confirms client data (e.g., tax records) is accurate. Monitor: Watch for re-infection for 7 days post-recovery. 5.6 Notification Internal: Coordinator notifies response team within 1 hour of confirmation. Clients: Legal Counsel drafts notifications per Regulation S-P (within 30 days) if PII is exposed. Regulatory: Compliance Officer files SEC Form 8-K within 4 business days for material incidents. Notify IRS if taxpayer data is compromised. External: Report to law enforcement (e.g., FBI) if data is exfiltrated. 5.7 Post-Incident Review Debrief: Conduct AAR within 1 week, identifying strengths and gaps. Update Plan: Revise IRP based on lessons (e.g., add MFA policy) within 2 weeks. Training: Implement new training within 1 month. Log: Maintain incident log for SEC/IRS audits. 6. Key Procedures Ransom Policy: Do not pay ransoms without CEO and Legal approval, considering cyber insurance and FBI guidance. Communication Plan: Use predefined templates for client and regulatory notifications. Vendor Coordination: Ensure third-party providers (e.g., cloud vendors) comply with GLBA via annual reviews. Backup Policy: Store backups offsite, encrypted, with weekly full and daily incremental backups. 7. Compliance Requirements SEC Regulation S-P: Notify affected clients within 30 days of PII breach. SEC Cybersecurity Rules: File Form 8-K for material incidents within 4 business days. IRS Section 7216: Protect taxpayer data; report unauthorized disclosures to IRS. GLBA Safeguards Rule: Maintain risk-based security controls and vendor oversight. CCPA (if applicable): Notify California residents of PII breaches within reasonable time. 8. Contact Information Internal Emergency Line: (555) 123-4567 (Compliance Officer) External Support: Cyber insurance provider (vendor@support.com), FBI Cyber Division (cyber@fbi.gov) Regulators: SEC (enforcement@sec.gov), IRS (safeguardreports@irs.gov) 9. Review and Updates Frequency: Review IRP annually or after major incidents. Responsible: Compliance Officer ensures updates align with regulations. Approval: CEO/Partner approves changes. 10. Appendices Appendix A: Incident Reporting Form Incident Reporting Form Date/Time: [Insert] Reporter: [Name/Role] Incident Type: [e.g., Phishing, Ransomware] Description: [Details] Systems/Data Affected: [e.g., Client database] Actions Taken: [e.g., Isolated workstation] Appendix B: After-Action Report Template After-Action Report Incident Date: [Date] Participants: [List] Strengths: [e.g., Quick containment] Gaps: [e.g., No MFA] Action Items: - [Role]: [Task] - [Deadline] Preparedness Score: [1-10]