Personal Data Security Incident Response Plan

Structure a personal data security incident response plan for [COMPANY NAME], operating in the [INDUSTRY] sector, with [NUMBER] registered data subjects.\\\\\\\\n\\\\\\\\n**Risk Profile:**\\\\\\\\n- Sensitive data processed: [YES/NO — types]\\\\\\\\n- Financial data: [YES/NO]\\\\\\\\n- Record volume: [NUMBER]\\\\\\\\n- Critical systems: [LIST]\\\\\\\\n- Incident history: [NUMBER] in the past 24 months\\\\\\\\n\\\\\\\\n**Structure the plan in the following phases:**\\\\\\\\n\\\\\\\\n1) **Preparation (pre-incident):**\\\\\\\\n   - Incident response team: composition (IT, Legal, DPO, Communications, Executive Management)\\\\\\\\n   - Roles and responsibilities for each member\\\\\\\\n   - Emergency communication channels (outside compromised systems)\\\\\\\\n   - Contracts with digital forensics and crisis PR vendors\\\\\\\\n   - Periodic simulations (tabletop exercises): annual schedule\\\\\\\\n   - Detection tools: SIEM, monitoring, alerts\\\\\\\\n\\\\\\\\n2) **Detection and Analysis (0-24 hours):**\\\\\\\\n   - Incident classification criteria (severity levels 1-4)\\\\\\\\n   - Initial analysis checklist:\\\\\\\\n     - Incident type (breach, ransomware, unauthorized access, loss)\\\\\\\\n     - Data affected: categories and volume\\\\\\\\n     - Subjects impacted: number and profile\\\\\\\\n     - Identified attack vector\\\\\\\\n     - Extent of compromise\\\\\\\\n   - Escalation criteria: severity-based matrix\\\\\\\\n   - Evidence preservation (chain of custody)\\\\\\\\n\\\\\\\\n3) **Containment and Eradication (24-72 hours):**\\\\\\\\n   - Immediate containment measures by incident type\\\\\\\\n   - Isolation of compromised systems\\\\\\\\n   - Access revocation\\\\\\\\n   - Threat elimination\\\\\\\\n   - Backup integrity verification\\\\\\\\n\\\\\\\\n4) **Mandatory Notifications (Art. 48, LGPD):**\\\\\\\\n   - **To the ANPD** (deadline: 3 business days—Resolution CD/ANPD No. 15):\\\\\\\\n     - Notification form: all required fields\\\\\\\\n     - Minimum information: data nature, affected subjects, technical measures, risks, mitigation measures\\\\\\\\n   - **To Data Subjects** (deadline: 3 business days):\\\\\\\\n     - Clear and direct communication template\\\\\\\\n     - Channels: individual email + website notice + press (if necessary)\\\\\\\\n     - Required information (Art. 48, §1)\\\\\\\\n     - FAQ for subject inquiries\\\\\\\\n   - **Other authorities** (if applicable): Central Bank, Securities Commission, Telecommunications Agency\\\\\\\\n   - **Internal communication**: information levels by hierarchy\\\\\\\\n\\\\\\\\n5) **Recovery (72 hours-30 days):**\\\\\\\\n   - Secure system restoration\\\\\\\\n   - Intensive post-incident monitoring\\\\\\\\n   - Data integrity validation\\\\\\\\n   - Gradual return to normal operations\\\\\\\\n\\\\\\\\n6) **Post-Incident (30-90 days):**\\\\\\\\n   - Complete incident report (root cause analysis)\\\\\\\\n   - Lessons learned and implemented improvements\\\\\\\\n   - Policy and procedure updates\\\\\\\\n   - Corrective training\\\\\\\\n   - Follow-up communication to subjects\\\\\\\\n\\\\\\\\n**Appendices:**\\\\\\\\n- Activation checklist by incident type\\\\\\\\n- ANPD notification template\\\\\\\\n- Data subject communication template\\\\\\\\n- Emergency contact list\\\\\\\\n- Decision flowchart\\\\\\\\n\\\\\\\\nBase on LGPD (Arts. 46, 47, 48, and 49), Resolution CD/ANPD No. 15/2024, and NIST SP 800-61 and ISO 27035 frameworks.