Incident Response Plan
Version 1.1 — Effective Date: May 20, 2026 Last Reviewed: May 20, 2026
This Incident Response Plan (IRP) establishes procedures for detecting, containing, eradicating, and recovering from security incidents affecting the Lead Validator Pro platform and the personal data we process on behalf of our customers.
1. Response Phases
Phase 1: Detection
Incidents may be detected through the following channels:
- Automated Monitoring: Security dashboard alerts, login anomaly detection, rate limit triggers, health check failures
- Log Analysis: Security log review (security.log), audit trail anomalies, unusual API access patterns
- External Reports: Customer reports, third-party notifications, responsible disclosure submissions
- System Alerts: Edge WAF alerts, error-monitoring alerts, automated health alerts
Action: Log the detection event, assign initial severity level, and notify the Incident Commander.
Phase 2: Containment
Immediate actions to limit the scope and impact of the incident:
- Short-term containment:
- Revoke compromised credentials and sessions immediately
- Block malicious IP addresses at the edge security / CDN layer
- Disable affected API keys or user accounts
- Isolate affected systems from the network if necessary
- Evidence preservation:
- Capture system logs, database state, and network logs before remediation
- Create forensic copies of affected systems where applicable
- Document timeline of events
Phase 3: Eradication
Remove the root cause of the incident:
- Identify and patch the vulnerability or misconfiguration
- Remove malicious code, unauthorized access, or compromised components
- Force password resets for potentially affected accounts
- Update security rules and firewall configurations
- Verify that all attack vectors have been closed
Phase 4: Recovery
Restore systems to normal operation:
- Restore from clean backups if data was corrupted
- Gradually re-enable services with enhanced monitoring
- Verify data integrity through automated checks
- Confirm that all systems are functioning normally
- Implement additional monitoring for recurrence
Phase 5: Notification
Notify affected parties in accordance with applicable law and contractual obligations:
Notification Timelines
- Affected customers (DPA): Within 24 hours of the Incident Response Team confirming a Personal Data Breach (per DPA § 11). The 24-hour clock starts on confirmation, not first alert.
- CCPA (California residents): Within 30 days of discovery for breaches affecting 500+ California residents (written notice to individuals)
- State AG notification: As required by applicable state breach notification laws (varies by state; many require 30-60 day notification)
- GLBA Safeguards Rule: Notify the FTC within 30 days for incidents affecting 500+ consumers' NPI (16 C.F.R. § 314.4)
- Law enforcement: When criminal activity is suspected or required by law
2. Severity Levels
| Level | Description | Examples | Response Time | Escalation |
|---|---|---|---|---|
| P1 - Critical | Active data breach, system compromise, or complete service outage affecting all customers | Confirmed PII exfiltration, database compromise, ransomware, unauthorized admin access | Immediate (within 15 min) | CEO, CTO, Legal; affected Customers notified within 24 hrs of Breach confirmation per DPA § 11 |
| P2 - High | Potential data exposure, partial service degradation, or targeted attack in progress | Brute force attack succeeding, API key leak, SQL injection attempt succeeding, single-tenant data exposure | Within 1 hour | CTO, Security team, affected customer(s) |
| P3 - Medium | Security vulnerability discovered, failed attack detected, non-critical service issues | Vulnerability in dependency, failed brute force (blocked), intermittent API errors, misconfiguration | Within 4 hours | Security team, Engineering lead |
| P4 - Low | Minor security concern, policy violation, informational alert | Unusual login pattern (resolved), expired certificate warning, non-sensitive log exposure | Within 24 hours | Security team (logged for review) |
3. Incident Response Team
| Role | Responsibilities |
|---|---|
| Incident Commander | Coordinates response, makes containment decisions, manages timeline, approves communications |
| Security Lead | Technical investigation, forensic analysis, vulnerability assessment, evidence preservation |
| Engineering Lead | System remediation, patching, deployment, recovery operations |
| Communications Lead | Drafts customer notifications, coordinates with legal, manages external communications |
| Legal Counsel | Regulatory compliance, breach notification requirements, law enforcement liaison |
4. Communication Templates
4.1 Initial Internal Alert (P1/P2)
4.2 Customer Breach Notification (24-hour)
4.3 Consumer Notification (CCPA - 30 day)
5. Post-Incident Review
Within 5 business days of incident resolution, the Incident Response Team shall conduct a post-incident review ("post-mortem") covering:
- Timeline: Complete chronology from detection through resolution
- Root Cause Analysis: Technical root cause and contributing factors
- Impact Assessment: Scope of data affected, systems compromised, service disruption duration
- Response Evaluation: Effectiveness of detection, containment, and communication
- Lessons Learned: What worked well, what needs improvement
- Action Items: Specific remediation tasks with owners and deadlines
- IRP Updates: Changes to this plan based on lessons learned
6. Testing and Maintenance
- This IRP shall be reviewed and updated at least annually
- Tabletop exercises simulating P1/P2 incidents shall be conducted at least semi-annually
- Contact information and escalation paths shall be verified quarterly
- All IRP updates shall be documented with version number and effective date
7. Regulatory Reference
Key Compliance Requirements:
- CCPA (Cal. Civ. Code § 1798.82): Notification to California residents within 30 days when breach affects 500+ residents; notification to California AG when 500+ residents affected
- Texas (Bus. & Com. Code § 521.053): Notification without unreasonable delay (60 days) to affected Texas residents
- GLBA Safeguards Rule (16 CFR § 314.4): Maintain incident response plan; notify FTC within 30 days for incidents affecting 500+ consumers' NPI
- State Breach Notification Laws: 50 states + DC have breach notification laws with varying timelines (30-90 days); we target the most restrictive deadline applicable