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IRO-17: Incident Tracking Repository

IRO 7 — High Identify

Mechanisms exist to maintain a repository of cybersecurity events and incidents that documents: (1) Details of the incident (e.g., category, severity and affected parties); (2) Remediation actions taken through incident closure; and (3) A summary from the Root Cause Analysis (RCA), if applicable.

Control Question: Does the organization maintain a repository of cybersecurity events and incidents that documents: (1) Details of the incident (e.g., category, severity and affected parties); (2) Remediation actions taken through incident closure; and (3) A summary from the Root Cause Analysis (RCA), if applicable?

US (3)
Framework Mapping Values
USA Federal C2M2 2.1 RESPONSE-2f
USA Massachusetts 201 CMR 17.00 2008 17.03(2)(j)
USA Vermont Act 171 2018 2447(b)(10)(A)
EMEA (2)
Framework Mapping Values
EMEA EU DORA RTS 2024 Article 27.2(c)
EMEA LUX CCSF 20/750 2020 3.5.1-60.a

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.

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 maintain a repository of cybersecurity events and incidents that documents: (1) Details of the incident (e.g., category, severity and affected parties); (2) Remediation actions taken through incident closure; and (3) A summary from the Root Cause Analysis (RCA), if applicable.

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

  1. IRO-17_A01 a repository to document cybersecurity events and incidents is defined.
  2. IRO-17_A02 details of the incident are documented in the repository, including at a minimum: category, severity and affected parties.
  3. IRO-17_A03 remediation actions taken through incident closure are documented in the repository.
  4. IRO-17_A04 for incidents where a Root Cause Analysis (RCA) is performed, a summary of the RCA is documented in the repository.

Evidence Requirements

E-IRO-03 Incident Tracking

Documented evidence of a centralized repository to track cybersecurity & data privacy incidents.

Incident Response
E-IRO-13 Incident Response Records

Documented evidence of records of response to cybersecurity and/or data protection 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

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