Security breach notification is a critical process that every cloud-enabled organization needs to have nailed down. When (not if) a security incident occurs, you need a well-oiled process to promptly notify affected parties, meet your legal and contractual obligations, and minimize the blast radius. Having a solid plan can make the difference between a minor incident and a major catastrophe.

Where did this come from?

This control comes from the CSA Cloud Controls Matrix v4.0.10 released on 2023-09-26. You can download the full CCM for free at https://cloudsecurityalliance.org/artifacts/cloud-controls-matrix-v4. The CCM provides a baseline of cloud security controls mapped to various industry standards. It's a great resource for any cloud security program.

For AWS-specific guidance on incident response, check out the AWS Security Incident Response Guide: https://docs.aws.amazon.com/whitepapers/latest/aws-security-incident-response-guide/welcome.html

Who should care?

Several roles should be intimately familiar with SEF-07:

• CISOs and security leadership responsible for the overall cloud security program
• Incident responders who will be on the front lines when a breach occurs
• Legal counsel who need to ensure breach notification meets all regulatory requirements
• Public relations who will need to communicate details of the breach to customers and the public
• Relationship managers who own the communication with key partners and suppliers

What is the risk?

Failure to properly notify in the event of a breach can lead to:

• Regulatory fines and penalties for non-compliance with breach notification laws
• Lawsuits from customers and partners for violating contractual notification timelines
• Reputational damage and loss of customer trust
• Delayed incident response if notifications are not timely

While having a solid process won't prevent the breach itself, it can significantly limit the downstream fallout. Swift, transparent communication is key.

What's the care factor?

For most organizations, this should be a top priority, especially those dealing with sensitive data (PII, PHI, PCI, etc.). The consequences of mishandling breach notifications can be severe.

However, the level of effort required is relatively low compared to technical security controls. It mostly comes down to preparation, process, and practice. For the high impact and low effort, this is an easy win.

When is it relevant?

Breach notification processes should be established for any system that processes sensitive data, whether in the cloud or on-prem. It's especially important for:

• Public-facing applications
• Systems handling regulated data types
• Multi-tenant environments with many customer/partner dependencies

It may be less critical for isolated dev/test environments or systems with only public data. But in general, it's better to over-prepare than underestimate.

What are the trade offs?

Implementing SEF-07 requires an investment of time from legal, PR, and leaderships teams to align on requirements and messaging. Incident response teams will need training and practice to execute consistently.

Some specific tradeoffs:

• Readiness vs agility: Being fully prepared for timely notification may slow down release cycles slightly as incident response is worked into the process.
• Transparency vs liability: There can be a temptation to minimize or downplay breaches to avoid reputational damage. But cover-ups often backfire spectacularly. Work with legal to find the right balance.

How to make it happen?

1. Identify all applicable breach notification regulations and contractual requirements. This will vary based on jurisdiction, industry, and data types.
2. Create a data classification policy that defines sensitive data types and required notification timelines for each in the event of suspected exposure.
3. Document roles and responsibilities for incident response and breach notification. Identify primary and backup personnel for each role.
4. Create notification templates for various scenarios that can be quickly customized. Have these pre-approved by legal. Include required elements like:
   • Description of the breach
   • Types of data exposed
   • Remediation steps taken
   • Recommended actions for affected parties
   • Contact information for further inquiries
5. Set up secure communication channels to use during an incident:
   • Pager duty and conference bridges for response teams
   • Email distribution lists for internal updates
   • Web page templates for public updates
6. Conduct tabletop exercises at least annually to practice assembling key facts, making notifications,and handling inbound inquiries. Identify areas for improvement.
7. Integrate breach notifications into the incident response plan. Automate notifications tied to specific events where possible.
8. Review and update the process regularly to account for new threats and changing requirements.

What are some gotchas?

• Ensure all key responders have appropriate training and access before an incident occurs. You don't want to be scrambling for permissions in a crisis.
• Legal requirements can vary widely by jurisdiction. Don't assume a one-size-fits-all approach will suffice.
• Notification timelines are often very tight (e.g. 72 hours under GDPR). Have templates and contact lists prepared in advance.
• Don't forget about internal notifications. Employees and executives should hear about major incidents from you, not the press.
• Have a plan for triaging inbound inquiries after a notification. An understaffed help desk or unmonitored inbox will just pour fuel on the fire.

For AWS environments specifically:

• Ensure incident response roles have appropriate IAM permissions to investigate incidents across the environment. The AWS managed policy arn:aws:iam::aws:policy/SecurityAudit is a good starting point.
• Enable AWS GuardDuty and/or SecurityHub for automated incident detection. Time is of the essence.
• Use AWS Cloudtrail to track critical API calls during an incident for notification and forensics.

What are the alternatives?

There's not really an alternative to breach notifications - they're legally required in most cases. However, some key decisions:

• Outsource vs in-house response: For smaller teams, engaging an external incident response firm can provide 24/7 coverage without having to staff up internally. Just make sure they're intimately familiar with your environment and notification requirements.
• Apologetic vs defensive posture: You may be tempted to deflect blame, but a sincere apology and commitment to improvement is usually the best approach. Work with PR to strike the right tone.

Explore further

• NIST SP 800-184 Guide for Cybersecurity Event Recovery: https://csrc.nist.gov/publications/detail/sp/800-184/final
• AWS Security Incident Response Guide: https://docs.aws.amazon.com/whitepapers/latest/aws-security-incident-response-guide/welcome.html
• CIS Critical Security Control 19: Incident Response and Management: https://www.cisecurity.org/controls/incident-response-and-management/

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