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Threat Protection & Incident Response

Cybersecurity Incident Response

Who decides what in the first hour, day and 72 hours of a cybersecurity incident, which breach notice deadlines apply in Canada and the US, and what cyber insurers check before they pay.

How a 30 to 200 person company should handle the first hour, first day and first 72 hours of a cybersecurity incident

A common pattern we see in the incident response plans we review: the document describes six phases of incident handling in detail and never says who may shut down remote access at 11 p.m. on a Friday. When something real happens, nobody opens it. People phone whoever they trust and improvise.

Verizon's 2025 DBIR small business snapshot found ransomware in 88% of the breaches it analysed at small and medium businesses, against 39% at large organisations. The 2026 DBIR puts ransomware in 48% of all breaches, and exploited software vulnerabilities (31%) have now overtaken stolen passwords as the most common way in. The DBIR is a dataset of investigated incidents, not a survey. Our posts on ransomware against SaaS businesses and phishing scams cover prevention. This one assumes prevention has failed and sets out the plan we would write for a company with no full-time security staff.

What belongs in an incident response plan for a small company?

In April 2025 NIST replaced its 2012 incident handling guide with SP 800-61 Rev. 3. The new version is a community profile of the Cybersecurity Framework (CSF) 2.0, and it treats incident response as part of everyday risk management rather than a separate lifecycle. For a small company the lesson is simple. A plan is a set of decisions and owners, not a phase diagram.

Keep the core plan to two or three pages and put the detail in appendices. The Canadian Centre for Cyber Security publishes guidance you can start from. Ours usually holds seven parts:

  1. Three severity levels, each with two real examples from your business.

  2. Named roles and deputies, with phone numbers that do not depend on company email.

  3. Decision rights: who can isolate systems, disable accounts, notify the insurer, hire counsel and speak to customers.

  4. A printed contact sheet covering insurer, breach counsel, forensic firm, MSP, bank and key cloud vendors.

  5. A notification matrix by jurisdiction and by customer contract.

  6. Short playbooks for ransomware, business email compromise, a hijacked SaaS admin account and a lost laptop.

  7. Evidence rules and an out-of-band channel for when email and chat may be compromised.

Print that contact sheet. In ransomware cases the plan often sits on the same file server the attacker has just encrypted. Our vCISO service builds these appendices from your actual systems rather than a template.

Who owns what during a cybersecurity incident?

Here is how we assign roles at companies of this size, including who we think should not hold each one.

Role

Usually held by

Decides

Should not be

Incident Lead

COO, CTO or a virtual CISO

Severity, isolation, escalation, when to close

The CEO, who must run the business and face customers

Technical Lead

IT manager, MSP Tech Lead or internal Engineer

Containment, evidence preservation, restore order

Your MSP alone, if their tools or access could be the entry point

Legal and Privacy

External breach counsel plus your Privacy Officer

Harm assessment, regulatory notifications, privilege

Your general corporate lawyer, unless they do breach work

Insurer Liaison

CFO or Controller

Claim notice, vendor approval, ransom discussions

Anyone who has not read the policy wording

Communications

CEO with Head of customer success

Customer, staff and media statements

Marketing working without legal review

Scribe

A calm operations coordinator

Timestamped log of every decision

Nobody, which is what usually happens

The MSP point is the one vendors dispute. A managed service provider is scoped and paid for uptime. In an incident, uptime and evidence pull in opposite directions. If the attacker came in through a remote management tool, your MSP is also a party to the investigation. Let them run the keyboard, and keep the decisions inside your company.

The First hour, First Day and first 72 hours

The first hour: stop the spread, keep the evidence

Attribution and recovery come later. Whoever spots the problem phones the incident lead, not email or chat, because both may be watched. The lead sets a severity level within 15 minutes and asks the scribe to start the timeline. The technical lead isolates affected machines through the endpoint detection and response (EDR) console, disables compromised accounts and revokes active sessions. Nobody powers off or reimages anything yet.

At the same time, the insurer liaison calls the breach hotline and records the claim number. If personal information may be involved, the lead calls breach counsel. Ask counsel whether they should engage the forensic firm, which in some jurisdictions may help protect privilege, though courts have not always agreed. Then move every incident conversation to the out-of-band channel. If money has moved through business email compromise, call your bank's fraud line inside the hour.

Hours 1 to 24: Scope it

The forensic firm, usually from the insurer's panel, collects logs and disk images. The technical lead resets credentials, starting with administrator and service accounts. Before any restore, someone confirms the backups are clean and complete. Restoring an infected backup is a common way to have the same incident twice.

Counsel starts the harm assessment. Which records were exposed? Whose? Where do those people live? Communications drafts a short holding statement: what you know, what you are doing and when you will update customers, with no guesses about causes.

Hours 24 to 72: Decide and Notify

You should now know enough to make the notification decisions below. The GDPR clock, if it applies, is already running. Restore systems in the order your business impact analysis set, not in the order people complain. Report the crime to police and to the Cyber Centre in Canada or the FBI's IC3 in the US. Book the post-incident review within two weeks.

Which data breach notification deadlines apply in Canada and the US?

Each law has its own trigger, and the clocks do not start at the same moment.

Law

Applies to

Trigger

Deadline

PIPEDA and its breach regulations

Private-sector commercial activity in most provinces

Real risk of significant harm

OPC and individuals "as soon as feasible"; records of every breach kept 24 months

Quebec Law 25 (private sector act)

Organizations holding Quebec residents' data

Confidentiality incident with risk of serious injury

CAI and affected people promptly; every incident logged in a register

Provincial health laws (for example Ontario PHIPA)

Health information custodians

Theft, loss or unauthorised use or disclosure

Individuals at the first reasonable opportunity; some cases go to the regulator

US state breach laws

Residents of each state

Each state's definition of personal information

All 50 states have one; some set fixed limits such as 30 days

HIPAA

US covered entities and business associates

Breach of unsecured health information

Individuals without unreasonable delay, no later than 60 days after discovery; if 500 or more people are affected, also HHS and, for 500 or more in one state, prominent media in the same window; smaller breaches go to HHS within 60 days of year end

FTC Safeguards Rule

US non-bank financial institutions

Unencrypted data of 500 or more consumers

FTC as soon as possible, no later than 30 days after discovery

SEC Form 8-K Item 1.05

US public companies

Material cybersecurity incident

Four business days after deciding it is material

GDPR Article 33

Organisations in the EU, or outside it when they offer goods or services to, or monitor, people in the EU

Personal data breach

Supervisory authority within 72 hours of awareness, where feasible

Summary only; confirm the deadlines that apply to you with Legal Counsel.

Two things catch small companies out. First, the PIPEDA record rule covers every breach of security safeguards involving personal information, including those below the harm threshold, and the OPC can ask to see them. Second, customer contracts can be stricter than any law. Enterprise customers often write 24 to 72 hour notice clauses into their data processing agreements. Add those to the matrix. Our data security and privacy team maps both.

What do cyber insurers ask about your incident response plan?

Applications differ by carrier, so treat this as a pattern rather than a checklist. Underwriters commonly ask whether you enforce multi-factor authentication on email, remote access and administrator accounts. They ask whether EDR runs on every endpoint and server, whether backups are offline or immutable, and when you last tested a restore. They ask about patch timelines, phishing training and whether you have a written incident response plan.

Our view is that the plan question carries less weight than the others. An underwriter will rarely read your plan. A claims adjuster may, and will compare what you did against what you declared on the application. If you said MFA was everywhere and the attacker logged in to an account without it, expect a harder claim conversation.

Three policy terms belong in the plan itself: the breach hotline number, whether you must use panel vendors for forensics and counsel, and whether insurer consent is needed before any ransom discussion (sanctions rules may also apply). Read them with your broker before an incident.

How to run a tabletop exercise in 90 minutes

A plan nobody has rehearsed is a draft. CISA publishes free tabletop exercise packages you can adapt, but scenarios built from your own systems teach more.

  1. Pick one scenario from your environment, such as finance's Microsoft 365 account emailing new bank details to your largest customer.

  2. Invite only role holders and deputies, with a facilitator who is not the incident lead.

  3. Release three injects 15 minutes apart: discovery, escalation (the attacker claims to hold customer data), then a complication (the incident lead is unreachable).

  4. At each inject, ask who decides, what they need and how they reach the next person.

  5. Have the scribe write down every "we don't know".

  6. Spend the last 20 minutes choosing the three biggest gaps, each with an owner and a date.

A common pattern we see in these exercises is mundane: the contact list lives only in the system that is down. Pair it with staff awareness training so everyone else knows how to report what they see.

What an incident response plan will not fix

A plan is a set of decisions. It is not a control.

It will not restore backups you never tested. If your restore takes four days, the plan just documents a four-day outage. It will not produce logs you never kept. If audit logging was off or retention was short, the forensic firm cannot scope the breach. Counsel may then advise notifying everyone whose data could have been touched, which is a far larger and costlier exercise.

It will not stop the attack either. Missing MFA, unmanaged laptops and unpatched edge devices are prevention problems, and the DBIR numbers above show where attackers are getting in. It will not rescue a leadership team that overrules its own incident lead in the first hour. And on its own it will not make you SOC 2 or ISO 27001 compliant, although both frameworks expect one. If you do not know where your controls stand, our free Cybersecurity Baseline Assessment gives you a starting score.

Where to start this month

Four weeks is enough to go from nothing to a tested first version.

  1. Week 1: name the six roles and deputies, and print the contact sheet.

  2. Week 2: build the notification matrix with counsel, including customer contract clauses.

  3. Week 3: read your cyber policy with your broker and copy the hotline, panel and consent terms into the plan.

  4. Week 4: run the 90 minute tabletop and fix the top three gaps.

If you would rather not do this alone, IRM writes and tests incident response plans as part of our vCISO engagements. Our pricing starts from US$2,000 a month for 15 to 20 hours. Book a consultation and we will tell you which of the four weeks you can skip.

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