IT has deployed the appropriate security controls. You've updated your policies and procedures and raised awareness. And you've got your incident response plan in place. What could possibly go wrong? The answer is: the plan itself. All the planning and preparation in the world won't protect your business from a data breach if the response plan doesn't work. It's necessary to ensure that your response plan stays current and functional. This webinar will provide a checklist of items to review when auditing your response plan. It will also review how often you should audit, test, and update your plan.

1. How To Audit Your
Incident Response Plan

2. Agenda
• Introductions
• Incident Response Plans
• Audit Checklist
• Q&A
Page 2

3. Introductions: Today‟s Speakers
• Ted Julian - Chief Marketing Officer, Co3
• Security / Compliance entrepreneur
• Security industry analyst
• Michael Bruemmer – Vice President, Experian®
Data Breach Resolution
• CIPP/US, CHC
• IAPP Certification Advisory Board
Page 3

4. Co3 Automates Breach Management
PREPARE ASSESS
Improve Organizational Quantify Potential
Readiness Impact, Support Privacy
• Assign response team Impact Assessments
• Describe environment • Track events
• Simulate events and incidents • Scope regulatory requirements
• Focus on organizational gaps • See $ exposure
• Send notice to team
• Generate Impact Assessments
REPORT MANAGE
Document Results and Easily Generate Detailed
Track Performance Incident Response Plans
• Document incident results • Escalate to complete IR plan
• Track historical performance • Oversee the complete plan
• Demonstrate organizational • Assign tasks: who/what/when
preparedness • Notify regulators and clients
• Generate audit/compliance reports • Monitor progress to completion
Page 4

5. Experian® Data Breach Resolution
Pre-Breach Risk
Forensics
Assessment
Breach Response
& Fraud Resolution
• Inventory of • Preservation of
Systems evidence • Incident
Management
• Threat and • Reconstruction of
vulnerability data sources • Notification
assessment • Forensic analysis
• Call Center
of preserved or
• Evolution of Support
reconstructed
controls data sources • Identity Theft
• Risk Ranking • Searches for Protection
suspected kinds • Fraud Resolution
• Communicating
of PII
and Monitoring
• Aggregation of • Reporting
identified PII
Page 5

6. Incident Response Plan
• Crucial to have in place
• Streamlines the process
• What to Include:
• The Team and Responsibilities
• Testing / Fire drills
• Third Party Support
• Outside counsel
• Compliance
• Forensics
• Data Breach Resolution Vendor
Page 6

7. Why Auditing Your IR Plan Is A Must
• Ensures you have accurate, up-to-date information
• Allows the process to be refined
• Identifies errors in advance
• Ensures everything in order before a breach occurs
• Doesn‟t cut into crucial response time post-breach
Page 7

8. 7 Checklist Items To Keep In Mind
• Update your internal contact list
• Verify that your plan is comprehensive
• Double check your vendor contracts
• Review notification guidelines(State and Federal)
• Check up on third parties that have access to your data
• Evaluate IT security
• Review staff security awareness
Page 8

9. Update Your Contact List
• Make sure the contact info for each member is up-to-date
• Internal
• External
• Note department heads
• People are 100% committed during a breach
• Re-distribute list once updated
Page 9

10. Verify That Your Plan Is Comprehensive
• Plan Revisions
• Major company changes
• New departments
• Data management policy adjustments
• Ensure Departments Know Their Roles
• Fire Drillls / Rehearsals
Page 10

11. Double Check Your Vendor Contracts
• Forensics Team
• Attorneys
• Data Breach Resolution Provider
• Law Enforcement
• Current / Accessible
• Ensure They Still Match Your Needs
Page 11

12. Review Notification Guidelines
• Ensure your plan reflects the latest state legislation
• Notification letter templates address new laws
• Update contact list
• State AGs
• Government Agencies
• Media
• Healthcare Providers: DHHS and OCR contacts
• Response team should understand reporting procedures
Page 12

13. Check On 3rd Parties With Access To Your Data
• Are they following your protection rules?
• Educate them on any new relevant legislation
• Stress the importance of immediate notification
• Go over the resolution process
• Healthcare companies: HIPAA requirements
• Establish Business Associate Agreements (BAAs)
Page 13

14. Evaluate IT Security
• Re-evaluate where sensitive / regulated data is stored
• Ensure proper access controls are in place
• Check that software and system updates are installed
• Verify that monitoring / reporting systems are working and
up-to-date
• Ensure back-ups are securely stored
Page 14

15. Review Staff Security Awareness
• Are Initial Background Checks valid? Random updates?
• Regular employee Security Awareness Training
• Practice and audit proper information disposal(hard & soft)
• Train staff to identify cyber threats
• Require password changes every three months
• Physical security for all devices
Page 15

16. POLL

17. How Often You Should Audit?
• HCCA recommends regular monitoring where PHI handled
• Monitoring is part of any risk assessment plan
• Audit when objective results needed and integrity is critical
• Independent (outside) audits provide the best perspective
• OIG - „annual audit to minimize risk‟
Page 17

18. POLL

19. When Should You Update Your Response Plan?
• When new legislation passes (state, federal, and industry
regulators)
• When response team members leave the company
• When new vendors join the process
• When new security procedures are implemented
Page 19

20. QUESTIONS

21. “Co3 Systems makes the process of
planning for a nightmare scenario as
painless as possible, making it an Editors‟
Choice.”
PC MAGAZINE, EDITOR’S CHOICE
One Alewife Center, Suite 450
“Co3…defines what software packages
Cambridge, MA 02140 for privacy look like.”
PHONE 617.206.3900
GARTNER
WWW.CO3SYS.COM
“Platform is comprehensive, user
friendly, and very well designed.”
PONEMON INSTITUTE
Michael Bruemmer, Vice President, Experian®
Data Breach Resolution
Michael.Bruemmer@Experian.com
www.Experian.com/DataBreach
Blog: www.Experian.com/DBBlog