12.10.1 An incident response plan exists and is ready to be activated in the event of a suspected or confirmed security incident. The plan includes, but is not limited to:
Defined Approach Requirements
12.10.1 An incident response plan exists and is ready to be activated in the event of a suspected or confirmed security incident. The plan includes, but is not limited to:
- Roles, responsibilities, and communication and contact strategies in the event of a suspected or confirmed security incident, including notification of payment brands and acquirers, at a minimum.
- Incident response procedures with specific containment and mitigation activities for different types of incidents.
- Business recovery and continuity procedures.
- Data backup processes.
- Analysis of legal requirements for reporting compromises.
- Coverage and responses of all critical system components.
- Reference or inclusion of incident response procedures from the payment brands.
Customized Approach Objective
A comprehensive incident response plan that meets card brand expectations is maintained.
Defined Approach Testing Procedures
12.10.1.a Examine the incident response plan to verify that the plan exists and includes at least the elements specified in this requirement.
12.10.1.b Interview personnel and examine documentation from previously reported incidents or alerts to verify that the documented incident response plan and procedures were followed.
Purpose
Without a comprehensive incident response plan that is properly disseminated, read, and understood by the parties responsible, confusion and lack of a unified response could create further downtime for the business, unnecessary public media exposure, as well as risk of financial and/or reputational loss and legal liabilities.
Good Practice
The incident response plan should be thorough and contain all the key elements for stakeholders (for example, legal, communications) to allow the entity to respond effectively in the event of a breach that could impact account data. It is important to keep the plan up to date with current contact information of individuals designated as having a role in incident response. Other relevant parties for notifications may include customers, financial institutions (acquirers and issuers), and business partners.
Entities should consider how to address all compromises of data within the CDE in their incident response plans, including compromises to account data, wireless encryption keys, encryption keys used for transmission and storage or account data or cardholder data, etc.
Examples
Legal requirements for reporting compromises include those in most US states, the EU General Data Protection Regulation (GDPR), and the Personal Data Protection Act (Singapore).
Further Information
For more information, refer to the NIST SP 800-61 Rev. 2, Computer Security Incident Handling Guide.
purpose
Establish and maintain an incident response plan.
compliance strategies
- Documented response plan
- Annual review and testing
typical policies
- Incident Response Policy
common pitfalls
- No plan or outdated plan
- No testing performed
type
Process/Documentation Control
difficulty
Moderate
key risks
- Uncoordinated response to incidents
recommendations
- Test plan annually and after major changes
Eligible SAQ
- SAQ-A
- SAQ-A-EP
- SAQ-B
- SAQ-B-IP
- SAQ-C
- SAQ-C-VT
- SAQ-D MERCHANT
- SAQ-D SERVICE PROVIDER
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