Think about service providers. If service providers
were involved, examine what personal information they can access and
decide if you need to change their access privileges. Also, ensure your
service providers are taking the necessary steps to make sure another
breach does not occur. If your service providers say they have remedied
vulnerabilities, verify that they really fixed things.
Check your network segmentation. When you set up
your network, you likely segmented it so that a breach on one server or
in one site could not lead to a breach on another server or site. Work
with your forensics experts to analyze whether your segmentation plan
was effective in containing the breach. If you need to make any changes,
do so now.
Work with your forensics experts. Find out if
measures such as encryption were enabled when the breach happened.
Analyze backup or preserved data. Review logs to determine who had
access to the data at the time of the breach. Also, analyze who
currently has access, determine whether that access is needed, and
restrict access if it is not. Verify the types of information
compromised, the number of people affected, and whether you have contact
information for those people. When you get the forensic reports, take
the recommended remedial measures as soon as possible.
Have a communications plan. Create a comprehensive
plan that reaches all affected audiences — employees, customers,
investors, business partners, and other stakeholders. Don’t make
misleading statements about the breach. And don’t withhold key details
that might help consumers protect themselves and their information.
Also, don’t publicly share information that might put consumers at
further risk.
Anticipate questions that people will ask. Then, put
top-tier questions and clear, plain-language answers on your website
where they are easy to find. Good communication up front can limit
customers’ concerns and frustration, saving your company time and money
later.
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