IRO-16.1: Situational Awareness For Incidents
Mechanisms exist to document, monitor and report the status of cybersecurity and data protection incidents to internal stakeholders all the way through the resolution of the incident.
Renumbered: Formerly IRO-09 in SCF 2025.4.
Control Question: Does the organization document, monitor and report the status of cybersecurity and data protection incidents to internal stakeholders all the way through the resolution of the incident?
General (36)
US (17)
| Framework | Mapping Values |
|---|---|
| USA Federal CMS MARS-E 2.0 | IR-5 |
| USA Federal CISA CPG 2022 | 1.D |
| USA Federal C2M2 2.1 | RESPONSE-1c RESPONSE-2f |
| USA Federal CJIS Security Policy 6.0 | IR-5 |
| USA Federal FedRAMP R5 (low) | IR-05 |
| USA Federal FedRAMP R5 (moderate) | IR-05 |
| USA Federal FedRAMP R5 (high) | IR-05 |
| USA Federal FedRAMP R5 (LI-SaaS) | IR-05 |
| USA Federal IRS 1075 2021 | IR-5 |
| USA Federal GLBA CFR 314 2023 | 314.4(h)(6) |
| USA Federal HIPAA Security Rule NIST SP 800-66 R2 | § 164.308(a)(1)(ii)(D) |
| USA Federal HIPAA Administrative Simplification 2013 | § 164.308(a)(1)(ii)(D) |
| USA Federal NERC CIP 2024 | CIP-008-6 2.3 |
| USA Federal FCA CRM 2023 | 609.930(c)(3)(iv) |
| USA Texas DIR SCSC 2.2 2025 | IR-05 |
| USA Texas TX-RAMP Level 1 | IR-05 |
| USA Texas TX-RAMP Level 2 | IR-05 |
EMEA (7)
| Framework | Mapping Values |
|---|---|
| EMEA Germany C5 2026 | OPS-13.02B.5 OPS-24.01B SIM-06.01B COM-03.01AC.3 COM-04.02AC.2 |
| EMEA EU GDPR 2016 | Article 33.5 |
| EMEA EU NIS2 Annex 2024 | 3.5.3(b) 3.5.4 6.10.2(a) |
| EMEA Israel CDMO 2.0 | Appendix A, 13.1 |
| EMEA LUX CCSF 20/750 2020 | 3.5.1-60.d |
| EMEA Saudi Arabia SACS-002 2022 | VII.B.TPC-90 |
| EMEA UAE NIAF 2023 | 3.3.1 |
APAC (5)
| Framework | Mapping Values |
|---|---|
| APAC Australia Essential 8 2024 | ISM-0123 |
| APAC Australia ISM June 2026 | ISM-0123 ISM-0125 ISM-0137 ISM-0733 ISM-1609 ISM-1803 |
| APAC India DPDPA 2023 | 8(6) |
| APAC India SEBI CSCRF 2024 | RS.CO.S3 |
| APAC New Zealand NZISM 3.9 | 3.2.16.C.01 7.3.6.C.01 7.3.6.C.02 |
Americas (2)
| Framework | Mapping Values |
|---|---|
| Americas Canada ITSP-10-171 2025 | 03.06.02.A 03.06.02.B |
| Americas Canada OSFI B-13 2022 | 2.7 |
Capability Maturity Model
Level 0 — Not Performed
Practices are non-existent, based on the inability to demonstrate an implemented and operational capability. A reasonable person would conclude the control is not being performed.
Level 1 — Performed Informally
SCR-CMM Level 1 criteria definitions are not available for this control: ▪ A reasonable person would conclude this control requires a structured process. ▪ At this level of maturity, the "ad hoc" nature of performing a capability informally would indicate the intent of the control is not met due to a lack of consistency and formality.
Level 2 — Planned & Tracked
Incident Response (IRO) capabilities are requirements-driven, but are not standardized across the entity (e.g., local/regional level consistency). Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Policies and standards associated with IRO domain capabilities are formally documented and centrally-managed by the entity. ▪ Standardized Operating Procedures (SOP) associated with DCH domain capabilities are documented and maintained by process owners. ▪ IT and/or cybersecurity personnel work with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with IRO domain capabilities to address applicable statutory, regulatory and/or contractual requirements for Technology Assets, Applications, Services and/or Data (TAASD). ▪ Incident response-related controls are primarily administrative and preventative in nature (e.g., policies, standards and procedures & guidelines). ▪ Incident response management may be a defined function (e.g., team or department) or assigned as an additional duty to existing IT and/or cybersecurity personnel. ▪ IT and/or cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery. ▪ IT and/or cybersecurity personnel facilitate prompt response to suspected or confirmed security incidents, including timely notification to affected stakeholders.
Level 3 — Well Defined
Incident Response (IRO) capabilities are standardized across the entity for applicability to People, Processes, Technologies, Data and/or Facilities (PPTDF) to ensure consistency for Technology Assets, Applications, Services and/or Data (TAASD). Capability criteria associated with this control reasonably expect the following criteria to exist: ▪ Policies and standards associated with IRO domain capabilities are formally documented and centrally-managed by the entity's Governance, Risk & Compliance (GRC) team, or similar function. ▪ Cybersecurity personnel operate an incident response capability using a documented and tested Incident Response Plan (IRP) to facilitate incident management operations that cover preparation, detection and analysis, containment, eradication and recovery. ▪ An incident response team, or similar function, is appropriately staffed and supported to implement and maintain IRO domain capabilities. ▪ Technology is leveraged to enhance the efficiency and accuracy of incident response operations (e.g., incident management software). ▪ The entity's Governance, Risk & Compliance (GRC) team, or similar function, works with business stakeholders and process owners to appropriately scope and reasonably implement cybersecurity and data protection controls associated with IRO domain capabilities to address Minimum Compliance Requirements (MCR) (e.g., applicable statutory, regulatory and/or contractual requirements) and Discretionary Security Requirements (DSR) (e.g., entity-required controls). ▪ An implemented and operational capability exists to document, monitor and report the status of cybersecurity and data protection incidents to internal stakeholders all the way through the resolution of the incident.
Level 4 — Quantitatively Controlled
Utilize SCR-CMM Level 3 criteria definitions: ▪ There are no defined Level 4 criteria, since it is reasonable to assume a quantitatively-controlled process is not necessary to operationalize this control. ▪ While it may be possible to develop “metrics-driven” capabilities for this control, the criteria would be organization-specific to define.
Level 5 — Continuously Improving
Utilize SCR-CMM Level 3 or Level 4 (if available) criteria definitions: ▪ There are no defined Level 5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to operationalize this control. ▪ Level 5 capabilities should be considered “world-class” where the control builds on Level 4 capabilities, but are continuously improving through Artificial Intelligence (AI) and/or Machine Learning (ML) technologies. ▪ While it may be possible to develop responsive capabilities for this control through the use of AI and/or ML technologies, the criteria would be organization-specific to define.
Assessment Objectives
- IRO-16.1_A01 the status of cybersecurity and data protection incidents is documented, monitored and reported to internal stakeholders through incident resolution.
- IRO-16.1_A02 system security incidents are tracked / reported to internal stakeholders.
- IRO-16.1_A03 system security incidents are documented.
- IRO-16.1_A04 system security incidents are tracked.
Evidence Requirements
- E-IRO-03 Incident Tracking
-
Documented evidence of a centralized repository to track cybersecurity & data privacy incidents.
Incident Response
Technology Recommendations
Micro/Small
- Basic incident response plan
- Designate incident response contact
Small
- Documented incident response plan
- Incident log
- Designated IR team
Medium
- Formal incident response program
- IR playbooks
- Tabletop exercises
Large
- Enterprise incident response program
- 24/7 SOC monitoring
- SOAR platform
Enterprise
- Enterprise SOC with SIEM/SOAR (e.g., Splunk SOAR, Palo Alto XSOAR)
- IR retainer
- Threat hunting