Cyber threats are escalating rapidly, with data breaches and ransomware attacks making headlines almost daily. In 2025, organizations face increasingly sophisticated attacks, and the average cost of a breach continues to rise. A robust, tested incident response plan is essential for minimizing impact and ensuring a swift, coordinated response.
During a cyber incident, stress levels run high and events unfold quickly. Your incident response plan must be detailed, actionable and clear about what steps to take, who to contact and what actions to avoid. Responding to a security incident is fundamentally different from recovering from hardware failures; improper actions can destroy evidence critical for identifying the attack vector or supporting legal proceedings.
Essential Elements of an Incident Response Plan
- Incident Identification and Categorization: Define processes for recognizing and classifying incidents.
- Incident Response Team: Clearly list team members, their contact information and detailed roles and responsibilities for each department.
- Authority to Declare an Incident: Specify who is authorized to declare an incident and activate the response team.
- Containment, Investigation and Recovery Procedures: Outline step-by-step actions, including internal communication protocols.
- External Communication Plan: Provide contact information for third-party response services, vendors, law enforcement and regulatory agencies. Members should receive communication as well, as coordinated by your Public Relations/Communications provider.
- Incident Logging: Include forms to document the incident and all related activities. Comprehensive logs are vital for post-incident review and potential legal action.
- Post-Incident Evaluation: Establish a process to assess the incident and implement security improvements.
Include alternate communication methods and ensure the plan can be retrieved if your systems are inaccessible. Hard copies or externally hosted sites are recommended.
Team Composition
Management must ensure the incident response team is properly staffed and that all members understand their roles. At a minimum, the team should include:
- Chief Technology Officer/Chief Information Officer
- Information Security Officer
- Senior Network Engineer, System Engineer, Core Staff
- Network Security Team
- Incident Response Team Coordinator (responsible for team communications)
- Senior Management
- Human Resources
- Legal
- Public Relations/Communications
Additional members may be included as needed.
Testing and Maintenance
Test your incident response plan at least annually with all primary and alternate team members. Regular exercises, such as cyber tabletop scenarios led by an experienced facilitator, help identify gaps in the plan and ensure everyone is prepared. After each exercise, management should review and update the plan as necessary.
Verifying Cyber Insurance Coverage
Cyber insurance is a critical component of incident response readiness. To ensure your organization is protected:
- Review Policy Details: Confirm coverage limits, deductibles, exclusions and sub-limits for specific incident types (e.g., ransomware, business interruption, regulatory fines).
- Maintain Current Documentation: Keep certificates of insurance and policy documents up to date and accessible to the Incident Response Team.
- Understand Carrier Requirements: Know your carrier’s minimum requirements for coverage, including mandatory controls, reporting timelines and approved vendors.
- Pre-Engage Approved Vendors: Work with your insurance broker and legal counsel to identify and pre-approve breach attorneys, incident response and forensics partners. Maintain a list of carrier-approved vendors and ensure agreements are in place for rapid engagement.
- Test Claims Process: Conduct tabletop exercises that include filing a mock claim to ensure familiarity with the process and carrier expectations.
Identifying and Engaging Critical Partners
A successful response depends on rapid access to specialized expertise. Your plan should include:
Breach Attorney
Role: Provides legal guidance, ensures regulatory compliance and helps preserve attorney-client privilege during incident response.
Pre-Engagement: Establish relationships with breach counsel in advance. Get the list of preapproved firms from your cyber insurance carrier to ensure they are covered and have experience in privacy, data security and breach notification laws.
Contact Information: Maintain up-to-date contact details for breach attorneys, including rates and engagement procedures.
Breach Response Partner
Role: Provides technical expertise in incident containment, eradication and recovery. May include managed security service providers (MSSPs), incident response firms and notification/credit monitoring vendors.
Pre-Engagement: Identify and retain breach response partners approved by your insurance carrier. Ensure contracts and statements of work are in place for rapid activation.
Coordination: The Incident Response Team should know how to engage these partners and document procedures for activation.
Forensics Partner
Role: Conducts forensic analysis to determine the root cause, scope and impact of the incident. Preserves evidence for legal and regulatory purposes.
Pre-Engagement: Retain a forensics firm with proven expertise and ensure they are on your carrier’s approved panel. Document engagement procedures and ensure the team understands when and how to involve forensics experts.
Evidence Preservation: Forensics partners should guide the team on preserving digital evidence and maintaining chain of custody.
Other Partners
Notification/Credit Monitoring: Identify vendors for breach notification and credit monitoring services as required by law or insurance.
Public Relations: Maintain contact information for PR firms experienced in breach communications.
Integration with Other Plans
The incident response plan should align closely with your Business Continuity Plan (BCP) and Disaster Recovery Plan (DRP). Depending on the incident’s impact, BCP and DRP processes may be invoked, so these plans must also be current and effective.
A well-developed incident response plan, supported by verified insurance and pre-engaged partners, is an investment in your credit union’s resilience. While you hope never to use it, thorough preparation will pay dividends if a cyber incident occurs.
