Building A Cybersecurity Incident Response Team
Teamwork is a critical element of CMMC compliance. In today’s cyber threat landscape, organizations handling sensitive data such as FCI and CUI must be ready to respond quickly to cybersecurity incidents. Having an incident response team (IRT) in place allows your company to plan for incident response, minimizing risks beforehand and maintaining compliance with CMMC, and to effectively respond in the event of a breach, mitigating any damage and ensuring business continuity.
Team Structure
The structure of your team will depend on the size of your organization and its available budget and resources. Smaller organizations or those centered in a single location might rely on a single IRT to handle incidents throughout the organization. A larger or more geographically widespread organization might consider implementing a team at each location, with a central coordinating team to provide direction and advice.
An effective IRT requires the involvement of certain people within your organization or from third parties working with your organization, such as a Managed Security Service Provider (MSSP). Working with an MSSP can be a cost-effective way for a resource-constrained company to plan for and respond to incidents. If you engage an MSSP, look for one with CMMC experience to ensure your incident response plan complies with CMMC requirements. Review their Shared Responsibility Matrix and verify that it maps to NIST SP 800-171. Also review their Service Level Agreement to understand the level of support you will receive and how they handle incident response. It is also a good idea to request references from companies similar to yours to confirm that the MSSP understands your environment.
Roles and Responsibilities
The key roles of an IRT are as follows. As with the compliance team, roles can overlap or be shared.
- Executive Leadership: As with all CMMC-related efforts, security starts at the top. For incident response planning to be effective, executive leaders need to champion the team’s efforts, provide direction, and ensure adequate resources are allocated.
- Incident Response Manager: This role oversees the incident response process from planning ,to execution in the event of an incident, to following up on lessons learned. They work with the legal advisor to ensure CMMC compliance, and they coordinate the efforts of all team members to ensure the team functions smoothly.
- Security Analysts: These team members assess and address vulnerabilities as part of ongoing planning. They monitor security alerts, investigate potential threats, and escalate critical incidents. During an escalated incident, they determine impact and recommend mitigation strategies.
- Forensic Analyst: This is a specialized type of security analyst who analyzes malware, logs, and network traffic for evidence of compromise. When needed, they provide forensic evidence for legal and compliance reporting.
- Threat Intelligence Analyst: This role tracks emerging cyber threats and analyzes the potential impacts of these threats on the organization. They work with the team to form a defense strategy for new threats.
- Legal Advisor: This role ensures that the team is aware of legal considerations and that incident response planning efforts comply with CMMC and other regulations. They also handle legal considerations for incident reporting and data breach notifications.
- Communications Lead and Delegates: One or more persons should be delegated to handle communications within and outside of the company, ensuring essential communication while freeing the incident responders to get the incident under control. As needed, they coordinate with government agencies, customers, and other stakeholders, maintaining transparency while complying with CMMC reporting requirements.
- IT/Infrastructure Support: Administrators for each of the in-scope systems and networks must be involved to ensure their systems are secure. They implement security measures and keep systems up to date to reduce vulnerabilities. In the event of an incident, they work toward recovery and implement measure to prevent recurrence.
- Business Asset Owners: As with IT support, business owners for each of the systems should be involved in planning and incident response.
- Facilities Management: Because cyber incidents can occur through physical security breaches and vice versa, your team should include physical security representatives to be involved with the planning and to be on hand during an incident, for example if physical access is needed to a certain area.
- HR/Training Support: This role provides training to team members to ensure they have the skills needed to respond to threats, as well as training all employees within the organization on how to prevent threats and what they can do if an incident should occur. HR may also need to be involved if one or more employees are suspected of causing an incident.
Important Activities
The major activities that your IRT will be responsible for include:
- Developing an Incident Response Plan: This crucial document is required by CMMC and ensures that you have an effective plan in place to reduce risks and respond to threats. The plan should identify specific roles, responsibilities, and escalation procedures.
- Identifying and resolving vulnerabilities: Security analysts identify areas where a system is vulnerable and work to mitigate those risks. This can be done using periodic risk assessments and penetration testing or by simulating cyberattacks to test the organization’s response capabilities.
- Identifying, documenting, and reporting incidents: This involves continuous monitoring for potential incidents and identifying and communicating problems. The team might consider using automated reporting tools to aid in this process. They also need to keep detailed records of actual incidents for compliance audits.
- Ensuring secure communication channels: Using encrypted messaging and out-of-band communication for critical incident discussions is essential for protecting data and mitigating further damage.
- Training and education: Training support team members provide ongoing cybersecurity training to team members and the organization as a whole. This creates awareness and fosters a culture of security. Training activities range from sending out daily tips on identifying threats, to classes, online training sessions, and formal tabletop exercises.
- Coordinating with government entities and other third parties: The communications lead should establish relationships with the DoD, CISA, and other government agencies to facilitate communication when incidents occur. They should also work with the legal advisor to ensure their reporting mechanisms align with DoD contract requirements.
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Resources
- https://dodcio.defense.gov/CMMC/About/
- https://cybernines.com/cmmc-overview
- https://nvlpubs.nist.gov/nistpubs/specialpublications/nist.sp.800-61r2.pdf
- https://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.800-61r3.ipd.pdf
- https://www.pipelinepub.com/cybersecurity-assurance-2024/CMMC-cybersecurity-certification-guide
- https://info.cybernines.com/demystifying-cmmc-compliance-your-guide-to-cmmc-compliance
- https://blog.cybernines.com/tech-at-the-top-c-levels-crucial-involvement-with-it-and-cybersecurity
- https://blog.cybernines.com/ttx-the-game-that-can-make-you-a-winner