Here’s a polished Incident Response & Breach Notification Policy for Method13. I’ve written it in the same professional, compliance-ready format as your Vulnerability Remediation Policy and aligned it with PCI DSS v4.0 requirements (12.10.x) and common regulatory expectations (e.g., GDPR, CCPA, state breach laws).

Incident Response & Breach Notification Policy

1. Purpose

The purpose of this policy is to establish a clear framework for responding to security incidents and breaches at Method13. This policy ensures that all security events are managed in a timely, consistent, and effective manner to minimize business impact, protect sensitive data, and comply with PCI DSS and applicable legal or contractual requirements.

2. Scope

This policy applies to all Method13 employees, contractors, systems, applications, and services that process, store, or transmit company or customer data, including PCI in-scope systems. It also applies to any third-party service providers operating on behalf of Method13.

3. Policy Statement

Method13 will maintain and execute an Incident Response Plan (IRP) to identify, contain, eradicate, and recover from security incidents. Breach notifications will be made promptly in accordance with PCI DSS, applicable data protection regulations, and contractual obligations.

4. Definitions

• Security Incident: Any event that threatens the confidentiality, integrity, or availability of Method13 systems, services, or data.

• Breach: A confirmed security incident where sensitive or regulated data (e.g., cardholder data, personal data) has been exposed, accessed, altered, or exfiltrated without authorization.

5. Roles and Responsibilities

• Incident Response Team (IRT): Responsible for coordinating detection, investigation, containment, and recovery efforts.

• Security Team: Monitors systems, escalates potential incidents, and ensures evidence is collected and preserved.

• System Owners / Administrators: Provide technical support and remediation for affected systems.

• Executive Management: Ensures adequate resources and authorizes customer and regulatory communications.

• Legal & Compliance: Advises on notification obligations and communication requirements.

6. Incident Response Lifecycle

Method13 will follow a structured process for handling incidents:

1. Preparation

   • Maintain documented IR procedures.

   • Conduct regular staff training and tabletop exercises (at least annually).

2. Identification

   • Detect incidents through monitoring, vulnerability scans, penetration tests, or external reporting.

   • Classify incidents by severity (Low, Medium, High, Critical).

3. Containment

   • Isolate affected systems to limit impact.

   • Apply temporary compensating controls where necessary.

4. Eradication

   • Remove root cause (e.g., malicious code, compromised accounts, misconfigurations).

   • Apply patches or fixes.

5. Recovery

   • Restore affected systems and validate business functionality.

   • Conduct enhanced monitoring to ensure no recurrence.

6. Lessons Learned

   • Perform a post-incident review within 10 business days.

   • Document findings, update policies and controls, and adjust training as needed.

7. Breach Notification Requirements

If a breach is confirmed involving customer or regulated data, Method13 will:

• Notify impacted customers and stakeholders without undue delay, and no later than legally required (e.g., PCI DSS requires immediate notification of cardholder data breaches, GDPR requires 72 hours, state laws vary).

• Provide clear and timely information, including:

  • Description of the breach.

  • Data involved.

  • Steps Method13 has taken to mitigate harm.

  • Recommended actions for affected customers.

• Notify relevant regulators, card brands, acquiring banks, or other authorities as required.

• Engage third-party forensic investigators if mandated by PCI DSS or contractual agreements.

8. Evidence Handling & Forensics

• All incident-related evidence must be collected, preserved, and protected from tampering.

• Access to evidence is restricted to authorized IRT members.

• Chain-of-custody documentation must be maintained for any forensic investigations.

9. Testing and Training

• Method13 will test its incident response procedures at least annually and after significant changes.

• Employees will receive annual training on recognizing and reporting potential security incidents.

10. Documentation & Reporting

• All incidents will be logged in Method13’s incident tracking system.

• Incident reports will be retained in accordance with record retention requirements.

• Monthly summaries of incidents and remediation actions will be reviewed by management.

11. Enforcement

Failure by employees or contractors to follow this policy may result in disciplinary action, up to and including termination of employment or contract.

12. Review and Updates

This policy will be reviewed at least annually or after a major incident to ensure its continued effectiveness and compliance with PCI DSS and legal requirements.