This Cyber Incident Response Policy and Process is tailored for a SaaS application based in India and is designed to meet the strict legal requirement of reporting incidents to CERT-In (Indian Computer Emergency Response Team) within six hours of noticing or being brought to notice of the incident, as mandated by the CERT-In Direction 20(3)/2022.
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1. Purpose & Scope
- Purpose: To define a systematic, phased approach for managing security incidents to minimize impact, ensure business continuity, protect customer data, and comply with all regulatory requirements, especially the CERT-In 6-hour reporting mandate.
- Scope: Applies to all systems, networks, applications (all Zeonix Global Ltd. Products), and personnel involved in the operation and maintenance of the company’s SaaS infrastructure.
2. Incident Response Team (IRT)
- The IRT is led by the IR Team Lead (e.g., CTO or Head of Security) and includes members from Technology/Engineering, Legal, Management, and Communications.
Role | Responsibility |
IR Team Lead | Overall command, decision-making, coordinating containment. |
Technical Team | Detection, analysis, containment, eradication, recovery. |
Legal/Compliance | Mandatory CERT-In reporting, regulatory compliance, evidence handling. |
Management | Business impact assessment, resource allocation, external communication approval. |
3. Cyber Incident Response Process (CIRP)
The CIRP follows six key phases to ensure a structured and compliant response.
Phase 1: Preparation (Proactive)
This phase ensures the company is ready to respond before an incident occurs.
- Asset Inventory: Maintain an up-to-date register of all critical assets, systems, and data locations.
- Tools & Access: Ensure the IRT has necessary tools (logging, forensic software) and secured, tested out-of-band communication channels.
- Playbooks: Develop and test scenario-specific response playbooks (e.g., Ransomware, Data Breach, DDoS).
- Training: Conduct mandatory, regular incident response training and simulations (tabletop exercises).
Phase 2: Detection & Analysis (The Clock Starts Here)
This phase focuses on identifying and understanding the incident.
- Detection: Identify a potential incident via monitoring system alerts, user reports, or third-party intelligence.
- Initial Triage: The Technical Team immediately verifies the incident’s legitimacy and classifies its severity (e.g., Low, Medium, High, Critical).
- Evidence Preservation: Immediately isolate and snapshot logs, system memory, and network data from affected systems before any changes are made.
- Root Cause Analysis (Initial): Determine the initial vector (e.g., phishing, unpatched vulnerability, compromised credential) and scope.
⏰ CRITICAL ACTION: CERT-In 6-Hour Reporting Mandate
Action | Deadline | Detail |
Internal Notification | IMMEDIATE | Notify the IR Team Lead and Management. |
Mandatory Regulatory Reporting | Within 6 hours of noticing or being brought to notice of the incident. | The Legal/Compliance team must report the incident to CERT-In (Indian Computer Emergency Response Team) via email (incident@cert-in.org.in) and/or phone (1800-11-4949). The initial report must include the nature of the incident, time of detection, and preliminary scope. |
Phase 3: Containmenter
- The goal is to stop the incident from spreading and causing further damage.
- Short-Term Containment: Isolate the compromised component (e.g., disconnecting a server from the internet, blocking a malicious IP at the firewall).
- Long-Term Containment: Change compromised passwords/keys, deploy patches, and implement stronger access controls across the network.
- Backup Integrity: Ensure that clean, verified backups are maintained and secured from the threat.
Phase 4: Eradication & Recovery
- This phase removes the threat and restores operations.
- Eradication: Completely remove all malicious components, backdoors, and rootkits identified during analysis.
- System Rebuild: Rebuild or restore critical systems from the verified, clean backups. Never restore a system without confirming the root cause is fixed.
- Validation: Monitor systems aggressively post-recovery to confirm the threat is completely gone and service integrity is restored.
- Communication: Inform stakeholders (internal and external/customers, if necessary, as advised by Legal) that service has been fully restored.
Phase 5: Post-Incident Review (Lessons Learned)
- Document: Create a final, comprehensive report detailing:
Incident timeline.
Root cause analysis and contributing factors.
Actions taken and their effectiveness.
Data and financial impact.
Final reports submitted to CERT-In or other regulators. - Lessons Learned: Identify failures in the process, technology, or people that allowed the incident to occur or hindered the response.
- Policy Update: Propose and implement corrective actions (e.g., new monitoring rules, security architecture changes, revised playbooks).
