Third-Party Data Breach Scenario

Scenario Overview

Exercise Type: Facilitated Discussion-Based Tabletop Exercise Scenario: Third-Party Data Breach Impacting PII and Financial Data Target Audience: Data Protection Officers, Legal Counsel, IT Security Teams, Customer Relations Duration: 90-120 minutes Exercise Objective: Evaluate organizational response to third-party data breach involving sensitive customer/seller data and extortion demands

Facilitator Guidelines

Present injects sequentially with 10-15 minutes discussion per inject
Encourage cross-departmental collaboration in responses
Highlight regulatory compliance requirements (GDPR, CCPA, PCI-DSS)
Track decision timelines and stakeholder accountability

Exercise Script

INJECT 1: Initial Breach Notification (Day 1 - 08:30 AM)

Situation:

Security Operations Center receives automated alert from Threat Intelligence Platform:
- "[WithPCI.com Company Name]" listed on DarkNimbus forum post titled "New Retail Dataset - 50k Records"
- Sample data includes customer names, order IDs, and partial email addresses
- Threat actor demands 0.5 BTC ($30,000) for full dataset deletion
Initial analysis shows:
- Sample data format matches [WithPCI.com Company Name]'s customer database structure
- No obvious signs of internal system compromise detected

Facilitator Notes:

Observe if participants activate incident response plan
Note discussions about ransom payment considerations

DISCUSSION PROMPT: "What are the immediate next steps? Who needs to be involved in initial response decisions?"

INJECT 2: Data Verification (Day 1 - 2:15 PM)

Situation:

Digital Forensics team completes analysis:
- Purchased sample dataset matches 98% of [WithPCI.com Company Name] customer records
- Exposed data fields:
  - Customer: Full names, physical addresses, purchase histories
  - Sellers: Business names, contact emails, inventory lists
- No payment card data or bank account information found
Legal team identifies potential violations:
- 23 US state breach notification laws
- GDPR Article 33 (72-hour reporting rule)

Facilitator Notes:

Assess understanding of breach classification thresholds
Note discussions about regulatory triage

DISCUSSION PROMPT: "What notification obligations exist? How do you verify full data scope?"

INJECT 3: Third-Party Vector Identified (Day 2 - 10:00 AM)

Situation:

Internal investigation reveals:
- No unauthorized access detected in [WithPCI.com Company Name] systems
- All sample data exists in VendorLink CRM (third-party sales platform)
- VendorLink last security audit: 14 months ago (contract requires annual audits)
VendorLink CISO acknowledges:
- Credential stuffing attack detected 45 days prior
- No customer notifications made due to "ongoing investigation"

Facilitator Notes:

Evaluate vendor risk management processes
Note contract compliance discussions

DISCUSSION PROMPT: "What immediate actions are required with VendorLink? How does this change liability considerations?"

INJECT 4: Public Exposure (Day 3 - 9:15 AM)

Situation:

KrebsOnSecurity publishes article:

"Major Retail Platform Suffers Third-Party Data Leak - 50k Records at Risk"
Social media trends show #DataBreach hashtag gaining 12k mentions/hour
Customer Service metrics:
- 427 calls received in first 2 hours
- 68% wait time over 15 minutes
- 22% call abandonment rate
Marketing reports 14% increase in shopping cart abandonment

Facilitator Notes:

Monitor crisis communication strategies
Evaluate scalability of customer support response

DISCUSSION PROMPT: "What is your public communication strategy? How will you manage stakeholder communications?"

INJECT 5: Full Data Exposure Revealed (Day 4 - 11:30 AM)

Situation:

Executive leadership authorizes $30k Bitcoin payment for full dataset:
- Confirms exposure of 5,182 customers / 1,037 sellers
- Newly revealed data fields:
  - Customers: Credit card numbers (PCI-DSS impacted)
  - Sellers: Bank account/routing numbers
Forensic analysis shows:
- Data exfiltration occurred via VendorLink API misconfiguration
- 87 days of data exposure prior to detection

Facilitator Notes:

Highlight PCI-DSS compliance implications
Assess breach response escalation processes

DISCUSSION PROMPT: "What regulatory notifications are now required? How will you handle financial remediation?"

INJECT 6: Customer/Seller Backlash (Day 5 - 1:00 PM)

Situation:

Post-notification metrics:
- 19% of notified customers request account deletion
- 37 sellers terminate contracts (12% of total seller base)
- Class action lawsuit filed in California federal court
Threat actor publishes:
- Internal [WithPCI.com Company Name] email discussing breach minimization
- VendorLink security audit discrepancies

Facilitator Notes:

Evaluate legal/PR coordination
Discuss customer retention strategies

DISCUSSION PROMPT: "How will you address escalating customer/seller demands? What lessons inform your strategy?"

INJECT 7: Regulatory Fallout (Day 30 - 10:00 AM)

Situation:

Regulatory developments:
- FTC launches Section 5 investigation
- EU DPA issues €4.2M preliminary GDPR fine
- PCI Security Standards Council revokes compliance certification
Operational impacts:
- Payment processors require 200% security deposit
- Cyber insurance premium increases 300%

Facilitator Notes:

Focus on long-term remediation planning
Discuss security program overhauls

DISCUSSION PROMPT: "What structural changes will prevent future incidents? How do you rebuild stakeholder trust?"

Exercise Debrief

Key Discussion Areas:

Third-Party Risk Management Gaps
Incident Response Timeline Analysis
Cross-Functional Coordination Effectiveness
Regulatory Compliance Shortfalls
Customer Trust Recovery Strategies

After-Action Report Components:

Vendor security assessment procedures update
Incident response playbook revisions
Cyber insurance policy review
Customer compensation framework development

Next Steps:

Implement 90-day security enhancement sprint
Conduct PCI-DSS readiness assessment
Schedule follow-up exercise for Q3 2025