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5X - Incident Response Plan

Version
Date
Nature of the change
1
1.0
February 20, 2023
Initial Release
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1. Introduction

1.1 Objectives

This Incident Response Plan (IRP) ensures that 5X responds effectively to all types of incidents that may impact our operations, security, or reputation. Our goals are to:
Minimize disruption to business operations
Protect customer data and company assets
Comply with legal and regulatory requirements
Maintain stakeholder trust
Learn from incidents to continually improve our resilience
The IRP must be tested bi-annually and updated based on test results and real-world incidents.

1.2 Scope

This plan covers all incidents that could affect 5X globally, including but not limited to:
Security incidents
Operational disruptions
Data integrity issues
Compliance violations
Third-party vendor issues
Physical incidents
Reputational crises
It applies to:
All 5X staff (permanent or temporary)
All contractors and suppliers
Anyone with access to 5X systems or data

1.3 Definitions

Term
Definition
1
Event
An observable occurrence relevant to company operations, data, systems, or networks
2
Incident
A situation that negatively impacts or threatens 5X operations, security, or reputation
3
Security Incident
A violation or imminent threat of violation of security policies or practices
4
Operational Incident
Any disruption to normal business operations or service delivery
5
Data Integrity Incident
Events affecting the accuracy, consistency, or reliability of data
6
Compliance Incident
Any breach of regulatory or contractual compliance obligations
7
Severity
The scale of impact an incident has on the company and stakeholders
8
Incident Response Team (IRT)
Cross-functional group responsible for managing incident response
9
IRT Manager
Individual coordinating the incident response efforts
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2. Incident Response Framework

2.1 General Requirements

All incidents must be reported, tracked, and investigated to determine root causes
Relevant authorities and stakeholders must be notified as required by law or contracts
Incident response capabilities must be tested and reviewed at least annually
All staff must be trained on incident reporting procedures

2.2 Incident Response Process

Identification and Reporting
Detect and report potential incidents
Record initial details
Assessment and Triage
Determine incident type and severity
Activate appropriate response team
Containment and Mitigation
Implement immediate actions to limit impact
Preserve evidence for investigation
Investigation and Analysis
Conduct root cause analysis
Determine full scope of the incident
Resolution and Recovery
Implement long-term fixes
Restore normal operations
Post-Incident Activities
Conduct lessons learned review
Update policies and procedures
Provide stakeholder notifications

2.3 Incident Severity Levels

Level
Description
Response Time
Resolution Target
1
SEV-1
Critical impact on operations or major data breach
Immediate
4 hours
2
SEV-2
Significant impact on part of the business or minor data issue
Within 1 hour
8 hours
3
SEV-3
Limited impact, no data compromise
Within 4 hours
24 hours
4
SEV-4
Minor issue, minimal impact
Next business day
5 business days
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2.4 Incident Types and Specific Procedures

Incident Type
Description
Key Considerations
1
Security Breach
Unauthorized access or data exposure
Focus on customer metadata protection Secure AWS infrastructure
2
Service Outage
5X platform unavailability
Leverage AWS reliability features Communicate with affected customers Implement failover procedures
3
Data Integrity Issue
Inaccurate analytics or data corruption
Isolate affected datasets Verify data processing pipelines Notify customers of potential inaccuracies
4
API Abuse
Misuse or attack on 5X APIs
Implement API throttling and blocking Analyze unusual usage patterns Update API security measures
5
Compliance Violation
Breach of SOC2 or GDPR requirements
Engage legal and compliance teams Prepare regulatory notifications Conduct compliance gap analysis
6
Third-Party Vendor Incident
Issues with AWS or other critical vendors
Activate vendor management procedures Implement service continuity plans Coordinate communication with vendor
7
Reputational Crisis
Negative press or social media events
Engage PR and communications team Prepare official statements Monitor and respond to stakeholder concerns
8
Physical Incident
Natural disasters or office-related issues
Ensure employee safety Activate business continuity plans Assess impact on remote work capabilities
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2.5 Incident Response Team Structure

IRT Manager: Oversees the entire response process
Security Lead: Handles security-specific aspects of incidents
Operations Lead: Manages service and platform-related issues
Data Protection Officer: Addresses privacy and compliance concerns
Legal Counsel: Provides legal guidance and manages regulatory communications
Communications Lead: Handles internal and external communications
Customer Success Representative: Liaises with affected customers

3. Incident Handling Procedures

3.1 Reporting Channels

Email:
we@5x.co
⁠
,
datasecurity@5x.co
⁠
,
legal@5x.co
⁠
⁠

3.2 Initial Response Actions

Acknowledge the incident report within 60 minutes
Assess severity and categorize the incident
Notify relevant IRT members based on incident type
Create a secure communication channel (e.g., dedicated Slack channel)
Begin incident documentation

3.3 Communication Guidelines

Internal Updates:
Provide regular status updates to leadership
Use secure channels for sensitive information
External Communication:
Coordinate all external messages with PR team
Follow customer notification procedures as per contracts
Adhere to regulatory notification timelines

3.4 Evidence Collection and Handling

Proper evidence collection and handling are crucial for incident investigation, potential legal proceedings, and improving our security posture. All steps must be performed following the four-eye principle (two employees performing the activities).

3.4.1 General Requirements

All evidence collection must be conducted by trained personnel or qualified third-party experts.
Maintain a clear chain of custody for all collected evidence.
Ensure all activities comply with relevant laws and regulations.
Use synchronized time sources across all systems to maintain accurate timestamps.

3.4.2 Evidence Collection by Environment

Cloud-based Systems (AWS)
System
Collection Method
1
EC2/ECS Instances
• Create snapshot of the affected instance • Use AWS CloudTrail for API call analysis • Leverage Amazon GuardDuty for threat insights
2
EBS Volumes
• Create snapshot of the affected volume •Analyze snapshot in isolated environment
3
RDS Databases
• Create database snapshot • Analyze database logs and access patterns
4
CloudWatch Logs
• Export relevant log groups for analysis
5
VPC Flow Logs
• Capture and analyze for network insights
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API and Application Logs
Preserve API gateway logs and application logs
Analyze for:
Unusual patterns
Unauthorized access attempts
Signs of data exfiltration
Anomalies in data access or processing
User Devices (Laptops, Mobile Devices)
While 5X primarily operates in the cloud, employee devices may be subject to forensic analysis:
Secure the device:
If powered on: Do not shut down; disconnect from networks
If powered off: Do not boot.
Create forensic image:
Laptops: Use write-blockers and forensic imaging tools for bit-by-bit copy
Mobile devices: Use specialized mobile forensic tools.
Analyze the forensic image on a separate, secure workstation

3.4.3 Evidence Handling Procedure

For each piece of evidence collected:
Attribute
Details to Record
1
Evidence ID
Unique identifier (e.g., 5X-INC-2024-001-E1)
2
Evidence Name
Descriptive name of the evidence
3
Type
e.g., Log file, Database snapshot, Disk image
4
Method of collection
Tools and processes used
5
Date and time of collection
Precise timestamp (UTC)
6
Hash value
SHA-256 hash of the evidence
7
Collector's name
Name and role of the person who collected the evidence
8
Storage location
Secure location where evidence is stored
9
Chain of custody
Chronological documentation of evidence handling
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3.4.4 Evidence Storage

Store all digital evidence in a secure, access-controlled environment
Encrypt sensitive evidence at rest using AES-256 encryption
Maintain backup copies of critical evidence, stored separately
Regularly verify the integrity of stored evidence (check against original hash)

3.4.5 Chain of Custody Documentation

Maintain a detailed log for each piece of evidence:
Date/Time
Handler
Action
Location
Purpose
1
[Timestamp]
[Name]
[Collected/Transferred/Analyzed]
[Location]
[Reason for handling]
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3.4.6 Forensic Analysis

Conduct analysis in a isolated environment to prevent contamination
Use industry-standard forensic tools appropriate for the evidence type
Document all steps of the analysis process
Correlate findings across different evidence sources for a comprehensive view

3.4.7 Reporting

Prepare a detailed forensic report for each investigation, including:
Executive summary
Detailed timeline of events
Description of evidence collected
Analysis methodology
Findings and their significance
Technical details (may be included in an appendix)
Recommendations for remediation and future prevention

3.4.8 Third-party Forensic Services

For incidents requiring specialized expertise or independent analysis:
Maintain a list of pre-approved forensic service providers
Ensure providers comply with 5X's security and confidentiality requirements
Establish clear rules of engagement and reporting expectations
Include confidentiality and data handling clauses in service agreements

3.4.9 Evidence Retention and Disposal

Retain evidence in accordance with legal and compliance requirements
Securely dispose of evidence when retention period expires:
Physically destroy hard drives and other storage media
Use secure deletion methods (e.g., multiple overwrites) for digital files
Document the disposal process, including method, date, and authorizing personnel

3.4.10 Legal Considerations

Consult with legal counsel before sharing any evidence externally
Ensure all evidence collection and handling comply with relevant data protection laws
Be prepared to demonstrate the integrity and authenticity of evidence if required for legal proceedings
All forensic activities must be conducted in a manner that preserves the integrity of evidence, maintains confidentiality, and complies with legal and regulatory requirements. The designated security lead must be informed of and oversee all forensic activities.

3.5 Post-Incident Activities

Conduct a thorough post-mortem analysis
Document lessons learned and action items
Update IRP and related procedures based on findings
Conduct follow-up training if necessary
Prepare final incident report for management review

4. Training and Awareness

All employees must complete annual incident response training
IRT members receive specialized training for their roles
Conduct regular tabletop exercises to test the IRP
Share sanitized incident summaries to increase organizational awareness

5. Plan Maintenance

Review and update the IRP annually
Incorporate lessons from actual incidents and simulations
Ensure alignment with evolving business operations and compliance requirements


6. Appendices

Appendix A: Incident Report Template

Incident Overview
Incident ID:
Date and Time of Discovery:
Reporter:
Severity Level:
Incident Description
Type of Incident:
Systems/Data Affected:
Initial Impact Assessment:
Response Actions
Containment Measures:
Investigation Steps:
Resolution Actions:
Root Cause Analysis
Identified Cause:
Contributing Factors:
Impact Assessment
Business Impact:
Customer Impact:
Data Breach Details (if applicable):
Lessons Learned
What Worked Well:
Areas for Improvement:
Recommendations
Immediate Actions:
Long-term Improvements:
Communication Log
Internal Communications:
External Communications:
Approval
Prepared by:
Reviewed by:
Approved by:



Appendix B: Communication Templates

Initial Internal Notification
Subject: Incident Alert: [Brief Description]
Team,
We are currently investigating a [severity] incident affecting [system/service]. Initial details:
Time of Discovery: [Time]
Affected Systems: [Systems]
Current Status: [Status]
The Incident Response Team has been activated. Updates will follow.
Customer Notification (Data Breach)
Subject: Important Security Notice
Dear Valued Customer,
We are writing to inform you of a data security incident that may have affected your account.
What Happened: [Brief description] When: [Date range] What Information: [Types of data potentially affected]
We are taking this matter very seriously and have implemented the following measures: [List measures]
If you have any questions, please contact us at [contact information].
We sincerely apologize for any inconvenience this may cause.
Service Disruption Update
Subject: 5X Service Status Update
Hello,
We are experiencing a service disruption affecting [describe impact]. Our team is actively working on resolving this issue.
Current Status: [Brief status] Estimated Resolution: [Time if known, or "We are working to provide an ETA"]
We will provide updates every [timeframe] or as significant developments occur.
We apologize for any inconvenience and appreciate your patience.

Appendix C: Regulatory Notification Requirements

SOC 2 Reporting Requirements
While not a regulatory body, incidents affecting SOC 2 controls must be reported to the auditor
Timeframe: During the next audit or immediately if it significantly impacts the validity of the current SOC 2 report
Information to Provide:
Description of the incident
Impact on SOC 2 controls
Remediation steps taken
Changes to controls or processes as a result
AWS Notification Requirements
Report security events affecting AWS resources as per AWS Shared Responsibility Model
Contact: AWS Trust & Safety team via AWS Support
Information to Provide:
AWS account ID
Instance IDs or resource ARNs involved
Relevant log data
Description of suspected security event
Note: This list is not exhaustive. Always consult with legal counsel to ensure all applicable regulatory requirements are met based on the specific nature of the incident and the data involved.

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