ISO 27001: Incident Policy & Incident Action Plan

Think of ISO 27001:2022 as the ultimate rulebook for information security, kind of like the secret manual for keeping your digital fortress impenetrable. It’s the global gold standard for setting up, running, and fine-tuning your Information Security Management System (ISMS). And guess what? Handling incidents is a huge part of this game.

So, here’s the lowdown on the Incident Policy and Incident Action Plan according to the legendary ISO 27001:2022:

Incident Policy

An Incident Policy in the context of ISO 27001:2022 outlines the organization’s approach to managing information security incidents. This policy sets the foundation for how incidents should be identified, reported, managed, and resolved. The key components of an Incident Policy include:

Purpose and Scope

Purpose: The purpose of the Incident Policy is to establish a structured approach for managing information security incidents. This includes defining the organization’s commitment to identifying, reporting, and handling incidents to minimize damage and recover from disruptions.
Scope: The scope specifies which incidents are covered by the policy. It may include data breaches, cyber-attacks, physical security breaches, and any other events that compromise the confidentiality, integrity, or availability of information.

Roles and Responsibilities

Incident Response Team (IRT): A dedicated team responsible for managing incidents. This team typically includes IT security professionals, legal advisors, communication specialists, and relevant department heads.
Management: Senior management is responsible for ensuring that adequate resources are allocated for incident management and for making strategic decisions during major incidents.
All Employees: Employees must be aware of their role in identifying and reporting potential incidents. This includes understanding the reporting procedures and the importance of timely reporting.

Incident Identification and Reporting

Identification: Guidelines for recognizing potential security incidents. This includes suspicious activity, system anomalies, or any unauthorized access attempts.
Reporting Process: Detailed steps on how to report incidents, including the use of incident reporting forms or dedicated reporting tools. Specifies who to report to (e.g., IT helpdesk, IRT) and the timeline for reporting.

Response and Resolution Procedures

Initial Assessment: Procedures for evaluating the severity and impact of the incident. This may involve determining the affected systems, data, and users.
Containment: Immediate actions to limit the spread of the incident. This could include isolating affected systems, blocking malicious IP addresses, or disabling compromised accounts.
Eradication: Steps to remove the cause of the incident. This might involve patching vulnerabilities, removing malware, or addressing configuration issues.
Recovery: Actions to restore affected systems and services to normal operation. This includes data restoration from backups and ensuring systems are secure before going back online.

Communication and Escalation

Internal Communication: Guidelines for keeping relevant stakeholders informed about the incident. This includes regular updates to senior management and affected departments.
External Communication: Procedures for communicating with external parties, such as customers, partners, regulatory bodies, and the media.
Escalation: Criteria for escalating incidents to higher authorities within the organization based on severity and impact.

Monitoring and Review

Ongoing Monitoring: Procedures for continuous monitoring of the incident until it is fully resolved. This includes tracking progress and ensuring that response actions are effective.
Post-Incident Review: A formal review process after the incident is resolved to identify what went well and what needs improvement. This review helps to update the incident management process and policies.

Compliance and Legal Considerations

Regulatory Compliance: Ensuring that the incident management process complies with relevant laws, regulations, and industry standards.
Legal Implications: Addressing potential legal consequences of incidents, such as data breaches that may require notification to affected individuals and regulatory bodies.

Training and Awareness

Employee Training: Regular training programs for all employees on incident identification, reporting, and response procedures.
Awareness Campaigns: Initiatives to promote a culture of security awareness within the organization. This includes regular reminders and updates about the importance of incident reporting.

Incident Action Plan

An Incident Action Plan (IAP) is a detailed plan created in response to a specific incident. It is a dynamic document that outlines the actions to be taken to address and resolve the incident. Key elements of an Incident Action Plan include:

Incident Description: A comprehensive account of the incident, including how it was detected, the systems affected, and the type of threat (e.g., malware, phishing, unauthorized access).

Objectives and Goals

Containment Goals: Immediate goals to contain the incident and prevent further damage.
Recovery Goals: Steps to restore affected services and data to normal operations.
Prevention Goals: Measures to prevent recurrence of similar incidents in the future.

Action Steps

Containment Actions: Specific steps to isolate affected systems, such as disconnecting from the network or shutting down services.
Eradication Actions: Detailed procedures for removing the root cause of the incident, such as deleting malware or patching vulnerabilities.
Recovery Actions: Steps to restore systems from backups, reconfigure settings, and test systems before bringing them back online.
Post-Incident Actions: Procedures for conducting a post-incident review and implementing lessons learned.

Resource Allocation

Personnel: Identification of key personnel involved in the incident response and their specific roles.
Technology: Tools and technologies required for incident response, such as forensic analysis tools, backup systems, and communication platforms.


Phases: Breakdown of the response into phases with specific timelines for each phase, such as initial response, containment, eradication, and recovery.
Deadlines: Specific deadlines for each action step to ensure timely resolution of the incident.

Roles and Responsibilities

Incident Manager: Person responsible for coordinating the entire response effort.
Technical Teams: Teams responsible for executing specific technical tasks, such as containment, eradication, and recovery.
Communication Leads: Individuals responsible for managing internal and external communications.

Communication Plan

Internal Updates: Regular updates to management and affected departments about the status of the incident.
External Notifications: Guidelines for notifying external stakeholders, such as customers and regulatory bodies, including the content and timing of such notifications.

Monitoring and Documentation

Progress Monitoring: Continuous monitoring of the incident response progress to ensure that all actions are effective and on schedule.
Documentation: Detailed documentation of all actions taken, decisions made, and changes to the action plan. This documentation is crucial for post-incident review and compliance purposes.

Review and Adjustment

Regular Reviews: Periodic reviews of the action plan during the incident to assess its effectiveness and make necessary adjustments.
Adjustments: Modifications to the plan based on new information or changes in the incident dynamics.

Post-Incident Review:

Lessons Learned: Identification of what worked well and what didn’t during the incident response.
Recommendations: Specific recommendations for improving the incident management process and preventing future incidents.
Report: A comprehensive report summarizing the incident, response actions, and lessons learned. This report is shared with senior management and other relevant stakeholders.

The Incident Policy and Incident Action Plan are critical components of an effective ISMS under ISO 27001:2022. The Incident Policy sets the overarching framework and guidelines for managing incidents, while the Incident Action Plan provides a detailed, step-by-step approach to handling specific incidents. Both are essential for ensuring a structured and efficient response to information security incidents, thereby minimizing their impact and improving the organization’s resilience.

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