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Incident Response Plan

MazeVault Security Incident Detection, Response, and Recovery Procedures

Document ID: MV-LEG-007
Version: 1.0.0
Classification: Confidential
Owner: Chief Information Security Officer (CISO)
Last Updated: 2026-05-01
Review Cycle: Annual (and after each significant incident)
Approved By: CEO / Board of Directors
Regulatory Basis: Act No. 264/2025 Sb. §15, NIS2 Directive Art. 23, DORA Art. 17-19, ISO/IEC 27001:2022 A.16


1. Purpose and Scope

1.1 Purpose

This Incident Response Plan ("Plan") establishes the formal procedures for detecting, reporting, responding to, recovering from, and learning from security incidents affecting MazeVault systems, services, and customer data. The Plan ensures a coordinated, efficient, and legally compliant response to all security events, minimizing impact to operations and stakeholders.

1.2 Scope

This Plan applies to:

  • All security incidents affecting the MazeVault platform, infrastructure, and services
  • All customer data processed, stored, or transmitted by MazeVault systems
  • All MazeVault personnel, contractors, and third-party service providers
  • All environments: production (PRO), non-production (NPR), development, and staging
  • All deployment models: cloud-hosted, on-premise gateway installations, and hybrid configurations
  • All connected infrastructure: backend services, gateways, agents, databases, and supporting systems

1.3 Definitions

Term Definition
Security Event Any observable occurrence in a system or network that may indicate a security policy violation
Security Incident A confirmed security event that compromises the confidentiality, integrity, or availability of information assets
Data Breach An incident resulting in unauthorized access to, or disclosure of, personal data or customer secrets
Incident Response Team (IRT) The designated group responsible for managing incident response activities
Incident Commander (IC) The individual with overall authority and responsibility during an incident

2. Incident Classification

2.1 Severity Classification Matrix

Severity Description Examples Initial Response Time Escalation
Critical (P1) Imminent or confirmed compromise of customer data, complete service unavailability, or active exploitation Data breach, Remote Code Execution (RCE), authentication bypass, customer secret/key exposure, ransomware deployment Immediate (≤15 min) CISO + CEO immediately
High (P2) Significant security degradation, privilege escalation, or major availability impact without confirmed data loss Privilege escalation, significant DoS impacting SLA, unauthorized admin access, gateway compromise without data exfiltration ≤1 hour CISO within 30 min
Medium (P3) Limited information disclosure, contained denial of service, or degraded security controls Limited information disclosure, localized DoS, failed exploitation attempts with partial success, misconfiguration exposing non-sensitive data ≤4 hours Security team lead
Low (P4) Minor security concerns, reconnaissance activity, or opportunities for defensive improvement Port scanning, minor information leakage (version disclosure), policy violations without impact, phishing attempts (no compromise) ≤24 hours Next business day

2.2 Impact Classification

Each incident SHALL additionally be classified by the following impact dimensions:

Dimension High Medium Low
Confidentiality Customer secrets, encryption keys, or personal data exposed to unauthorized parties Internal system data or metadata exposed; no customer secrets compromised Information of minimal sensitivity exposed (e.g., public configuration)
Integrity Customer data modified, audit logs tampered with, or cryptographic operations compromised System configuration altered; no direct customer data impact Minor data inconsistencies with no operational impact
Availability Complete service outage or >50% capacity degradation affecting production customers Degraded performance or partial service disruption; workarounds available Minimal impact; non-production environments or isolated components

2.3 Regulatory Classification Trigger

An incident SHALL be classified as reportable to regulatory authorities when any of the following conditions are met:

  • Confirmed unauthorized access to customer personal data (GDPR Art. 33)
  • Significant impact on essential service provision (NIS2 Art. 23)
  • Major ICT-related incident affecting financial entity customers (DORA Art. 19)
  • Incident meeting criteria defined in Act No. 264/2025 Sb. §15

3. Incident Response Team (IRT)

3.1 Team Composition and Roles

Role Primary Responsibility Deputy
Incident Commander (IC) — CISO Overall incident coordination, regulatory communication decisions, escalation authority, final sign-off on containment/recovery actions CTO
Technical Lead — CTO / Sr. Engineer Technical investigation, containment execution, forensic evidence collection, system recovery Senior Platform Engineer
Communications Lead Internal communications, customer notifications, press coordination, status page updates Head of Customer Success
Legal Counsel Regulatory notification assessment, legal obligation compliance, evidence preservation guidance, liability assessment External Legal Advisor
Customer Relations Customer-facing communication, impact assessment per customer, support coordination Account Management Lead
Operations Lead Infrastructure actions, backup/restore operations, system monitoring during incident DevOps Engineer

3.2 Escalation Matrix

Level 1: Security Operations (on-call engineer)
    ↓ [P3/P4 confirmed or P2/P1 suspected]
Level 2: Security Team Lead + Technical Lead
    ↓ [P2 confirmed or P1 suspected]
Level 3: CISO (Incident Commander) + Full IRT activation
    ↓ [P1 confirmed or regulatory notification required]
Level 4: CEO + Board notification + External counsel

3.3 Contact and Availability

  • The Incident Commander and Technical Lead SHALL be reachable 24/7/365 via designated emergency contact channels.
  • All IRT members SHALL acknowledge activation within 15 minutes during business hours and 30 minutes outside business hours.
  • A duty roster SHALL be maintained ensuring at least one qualified responder per role is available at all times.

3.4 Authority

The Incident Commander is authorized to:

  • Shut down any system or service to contain an incident
  • Revoke any access credentials or certificates
  • Engage external forensic specialists or legal counsel
  • Authorize emergency changes without standard change management approval
  • Communicate with regulatory authorities on behalf of MazeVault

4. Detection Mechanisms

4.1 Automated Detection

4.1.1 AnomalyDetectionService

The AnomalyDetectionService provides real-time behavioral analysis:

  • Access Pattern Tracking: Establishes baseline behavior for each user and device, detects statistical deviations from normal patterns
  • Deviation Detection: Triggers alerts when access patterns exceed defined thresholds (frequency, timing, volume, geographic origin)
  • Risk Scoring: Assigns dynamic risk scores to sessions based on behavioral anomalies
  • Integration: Feeds into ZeroTrustService for enforcement decisions

4.1.2 ZeroTrustService

The ZeroTrustService enforces continuous verification:

  • Untrusted Device Detection: Identifies devices not meeting security posture requirements; blocks access to critical resources
  • Critical Resource Access Control: Prevents access from untrusted contexts to high-sensitivity operations (secret retrieval, key management, administrative functions)
  • Session Termination: Automatically terminates sessions exhibiting suspicious characteristics
  • Alert Generation: Creates security events for investigation when enforcement actions are taken

4.1.3 SIEM Detection Rules

Seventeen (17) detection rules are deployed covering the following threat categories:

Rule Category Detection Scenario Alert Severity
Authentication Brute force (>10 failed attempts in 5 min per account) High
Authentication Credential stuffing (distributed failed logins across accounts) High
Authentication Impossible travel (logins from geographically distant locations within implausible timeframes) Critical
Authorization Privilege escalation (role elevation outside normal workflow) Critical
Data Exfiltration Bulk export (>100 secrets accessed in 1 hour) Critical
Data Exfiltration Unusual download volume (>3x baseline) High
Operational Mass revocation (>50 certificates revoked in 1 hour) High
Operational Mass secret deletion (>20 secrets deleted in 30 min) Critical
Infrastructure Unauthorized configuration change High
Infrastructure Service account abuse (use outside designated service) High
Network Lateral movement indicators Critical
Network C2 communication patterns Critical
Availability DDoS pattern detection (traffic spike >10x normal) High
Compliance Audit log gap (>5 min without expected log entries) High
Compliance Tamper detection (hash chain validation failure) Critical
API API abuse (rate limit exceeded + unusual endpoints) Medium
Cryptographic Key usage anomaly (signing operations outside maintenance window) High

4.1.4 GatewayHealthMonitor

  • Heartbeat Monitoring: Timeout threshold of 2 minutes; gateways must report health within this interval
  • Failure Threshold: 3 consecutive missed heartbeats triggers alert and potential failover
  • Health Check Interval: Every 30 seconds
  • Alert Escalation: Missed heartbeat → warning; 3 consecutive failures → critical alert + IRT notification

4.1.5 Prometheus Alerting

  • Infrastructure metrics monitoring (CPU, memory, disk, network)
  • Application-level metrics (request latency, error rates, queue depths)
  • SLA threshold alerts (response time, availability percentage)
  • Certificate expiration warnings (30, 14, 7, 3, 1 day)
  • Database connection pool exhaustion

4.2 Manual Detection

Source Process
Customer Reports Received via support channels; triaged by support team; escalated to security if incident indicators present
Employee Reports Internal reporting channel (info@mazevault.com); any employee may report suspected incidents
Third-Party Notification Vulnerability researchers, CERT teams, partner organizations, law enforcement; routed to CISO
Audit Findings Internal or external audit identifies control failures or evidence of compromise
Threat Intelligence Industry feeds, vendor advisories, NUKIB warnings indicating active threats to similar systems

5. Response Phases

5.1 Phase 1: Detection & Triage

Objective: Confirm the incident, assess initial severity, and activate appropriate response resources.

Actions:

  1. Validate Alert: Confirm the security event is a genuine incident (eliminate false positives)
  2. Assign Incident ID: Generate unique identifier in format INC-YYYY-MMDD-NNN (e.g., INC-2026-0501-001)
  3. Classify Severity: Apply classification matrix (Section 2) to determine priority level
  4. Assess Scope: Determine affected systems, data, customers, and environments
  5. Activate IRT: Notify team members per escalation matrix (Section 3.2)
  6. Initiate Incident Record: Create formal incident record with all known details
  7. Preserve Initial Evidence: Ensure logging continues; initiate evidence preservation (Section 8)
  8. Determine Regulatory Obligations: Assess whether notification thresholds are met (Section 6)

Output: Incident record created, IRT activated, initial assessment documented.

Time Constraint: Triage SHALL be completed within 30 minutes of initial detection for P1/P2 incidents.

5.2 Phase 2: Containment

Objective: Limit the scope and impact of the incident while preserving evidence.

5.2.1 Short-Term Containment (Immediate)

  • Isolate Affected Systems: Network segmentation, disable compromised gateway connections
  • Revoke Compromised Credentials: Invalidate tokens, API keys, sessions, certificates confirmed or suspected compromised
  • Block Malicious Sources: IP blocking, geo-blocking, firewall rule updates
  • Disable Compromised Accounts: Lock user accounts exhibiting unauthorized activity
  • Enable Enhanced Monitoring: Increase logging verbosity, reduce alert thresholds on related systems
  • Activate GatewayEnvironmentLock: If gateway compromise suspected, ensure fencing token prevents split-brain

5.2.2 Long-Term Containment

  • Apply Emergency Patches: Deploy fixes for exploited vulnerabilities
  • Reconfigure Affected Systems: Harden configurations, rotate all potentially exposed secrets
  • Implement Additional Controls: Deploy new detection rules, tighten access policies
  • Establish Clean Recovery Environment: Prepare verified-clean systems for restoration
  • Rotate Encryption Keys: If key compromise suspected, execute emergency key rotation procedure

Decision Gate: Incident Commander must approve transition from containment to eradication, confirming active threat is neutralized.

5.3 Phase 3: Eradication

Objective: Remove the root cause and verify no persistence mechanisms remain.

Actions:

  1. Identify Root Cause: Complete forensic analysis to determine attack vector and method
  2. Remove Malicious Artifacts: Delete malware, backdoors, unauthorized accounts, persistence mechanisms
  3. Patch Vulnerabilities: Apply permanent fixes for all exploited vulnerabilities
  4. Verify Clean State: Scan all potentially affected systems; validate integrity of binaries and configurations
  5. Verify No Lateral Movement: Confirm attack did not spread to other systems or environments
  6. Update Detection Rules: Add signatures/patterns from this incident to detection capabilities
  7. Validate Audit Log Integrity: Verify chain-hashed audit logs show no tampering during incident

Output: Root cause analysis document, confirmation of clean system state, updated threat indicators.

5.4 Phase 4: Recovery

Objective: Restore affected systems to full operational status and confirm normal operations.

Actions:

  1. Restore from Verified Backups: If system integrity cannot be confirmed, restore from last known-good backup (per BCP/DR procedures MV-LEG-008)
  2. Verify Data Integrity: Compare restored data against backup checksums; validate database consistency
  3. Gradual Service Restoration: Bring systems back online incrementally, monitoring for anomalies at each stage
  4. Verify Security Controls: Confirm all security mechanisms (ZeroTrust, AnomalyDetection, SIEM rules) are active and functioning
  5. Monitor for Recurrence: Maintain enhanced monitoring for minimum 72 hours post-recovery
  6. Confirm SLA Restoration: Verify system performance meets defined SLA thresholds
  7. Customer Communication: Notify affected customers of service restoration and any actions they must take (e.g., credential rotation)

Decision Gate: Incident Commander authorizes transition to post-incident phase when all systems are confirmed operational and stable for ≥24 hours.

5.5 Phase 5: Post-Incident

Objective: Learn from the incident, improve processes, and fulfill remaining obligations.

Actions:

  1. Conduct Post-Incident Review (PIR): Blameless retrospective within 5 business days of incident closure
  2. Document Lessons Learned: What worked well, what could be improved, what was missing
  3. Update Policies and Procedures: Revise this Plan, runbooks, and other documents based on findings
  4. Implement Preventive Measures: Address root cause to prevent recurrence
  5. Submit Final Regulatory Reports: Complete all required final reports (Section 6)
  6. Update Risk Register: Reflect new risks or risk reassessments in the organizational risk register
  7. Brief Stakeholders: Provide executive summary to leadership and board as appropriate
  8. Close Incident Record: Formally close the incident with complete documentation

Output: Post-Incident Report, updated risk register, action items with owners and deadlines.


6. Regulatory Notification Requirements

6.1 Notification Timeline Matrix

Authority / Recipient Trigger Initial Notification Intermediate Report Final Report Method
NUKIB (per Act No. 264/2025 Sb. §15) Significant security incident affecting essential service Within 24 hours of incident detection Within 72 hours Within 1 month of incident closure NUKIB electronic portal (ESVZ)
Customer Notification Incident directly affecting customer data or service Immediate for Critical (P1) affecting their data; within 24 hours for High (P2) Ongoing updates as material information becomes available Final summary upon incident closure Email + in-platform notification + status page
GDPR — Data Protection Authority (ÚOOÚ) (Art. 33) Personal data breach likely to result in risk to rights and freedoms Within 72 hours of becoming aware As additional information becomes available Upon completion of investigation DPA electronic reporting form
GDPR — Data Subjects (Art. 34) Personal data breach likely to result in high risk to rights and freedoms Without undue delay N/A N/A Direct communication to affected individuals
DORA — Competent Authority (Art. 19) Major ICT-related incident (financial sector customers) Within 4 hours of incident classification Within 72 hours Within 1 month Regulatory reporting channel per financial authority requirements
CNB (Czech National Bank) Incident affecting regulated financial entity customers Support customer's own reporting obligation (provide evidence and impact assessment) Ongoing support Provide final technical report for customer's use Via customer; direct if requested
Law Enforcement Evidence of criminal activity As directed by Legal Counsel As requested As requested Direct contact with relevant authority

6.2 Critical Timelines

T+0         Incident detected
T+15 min    P1 triage complete, IRT activated
T+4 hours   DORA initial notification (if applicable) — MANDATORY
T+24 hours  NUKIB initial notification — MANDATORY
T+72 hours  GDPR DPA notification — MANDATORY
T+72 hours  Intermediate reports (NUKIB, DORA)
T+1 month   Final reports (NUKIB, DORA)

CRITICAL: Failure to meet the 24-hour NUKIB reporting requirement or the 4-hour DORA initial notification constitutes a regulatory violation and may result in administrative penalties. The Incident Commander SHALL ensure timely notification even if full incident details are not yet available.

6.3 Notification Decision Authority

  • NUKIB notification: Authorized by Incident Commander (CISO) or CEO
  • GDPR DPA notification: Authorized by Data Protection Officer (DPO) in consultation with Legal Counsel
  • DORA notification: Authorized by Incident Commander (CISO) with Legal Counsel confirmation
  • Customer notification: Authorized by Incident Commander; content approved by Communications Lead and Legal Counsel
  • Law enforcement contact: Authorized exclusively by Legal Counsel and CEO

7. Communication Templates

7.1 Internal Escalation Template

Subject: [SEVERITY] Security Incident - INC-YYYY-MMDD-NNN

INCIDENT SUMMARY
- Incident ID: [INC-YYYY-MMDD-NNN]
- Severity: [Critical / High / Medium / Low]
- Detected: [Timestamp UTC]
- Detection Method: [Automated/Manual - specifics]
- Affected Systems: [List]
- Affected Customers: [Count / "Under Investigation"]
- Current Status: [Detected / Investigating / Contained / Resolved]

INITIAL ASSESSMENT
- Description: [Brief description of the incident]
- Suspected Impact: [Confidentiality / Integrity / Availability]
- Estimated Scope: [Systems, data types, customer count]

IMMEDIATE ACTIONS TAKEN
- [Action 1]
- [Action 2]

REQUIRED ACTIONS
- [Action required from specific team/individual]

NEXT UPDATE: [Timestamp or "Within X hours"]

Incident Commander: [Name]
Contact: [Emergency channel]

7.2 Customer Notification Template

Subject: Security Notice - Action Required / For Your Information

Dear [Customer Name],

We are writing to inform you of a security incident that [may affect / has affected]
your MazeVault environment.

WHAT HAPPENED
[Factual description without excessive technical detail]

WHAT INFORMATION WAS INVOLVED
[Types of data potentially affected, NOT specific contents]

WHAT WE ARE DOING
[Actions taken and planned by MazeVault]

WHAT YOU SHOULD DO
[Specific recommended actions: rotate credentials, review access logs, etc.]

ADDITIONAL INFORMATION
[Resources, support contact, timeline for updates]

We take the security of your data extremely seriously and are committed to
full transparency as our investigation continues.

For questions: [Dedicated incident support contact]
Next update: [Date/time]

[Signature]
MazeVault Security Team

7.3 Regulatory Notification Template (NUKIB Portal Format)

NOTIFICATION OF SECURITY INCIDENT

1. REPORTING ENTITY
   - Organization: MazeVault s.r.o.
   - IČO: [Registration Number]
   - Contact Person: [CISO Name]
   - Contact: [Phone] / [Email]

2. INCIDENT IDENTIFICATION
   - Internal Reference: [INC-YYYY-MMDD-NNN]
   - Date/Time of Detection: [ISO 8601 timestamp]
   - Date/Time of Occurrence (if known): [ISO 8601 timestamp]
   - Reporting Deadline Compliance: [Yes - within 24h / Explanation if late]

3. INCIDENT DESCRIPTION
   - Category: [Unauthorized access / Data breach / DoS / Malware / Other]
   - Affected Service: MazeVault Secret Management Platform
   - Description: [Factual summary]

4. IMPACT ASSESSMENT
   - Affected Systems: [List]
   - Affected Users/Customers: [Count]
   - Data Types Affected: [Categories]
   - Service Disruption: [Duration, scope]
   - Cross-border Impact: [Yes/No - details]

5. ACTIONS TAKEN
   - Containment: [Measures implemented]
   - Mitigation: [Steps to reduce impact]
   - Recovery: [Status and timeline]

6. ADDITIONAL INFORMATION
   - Root Cause (if known): [Description]
   - Indicators of Compromise: [If shareable]
   - Assistance Requested: [If any]

Status: [Initial / Intermediate / Final]

7.4 Press Statement Template (If Required)

FOR IMMEDIATE RELEASE

MazeVault Addresses Security Incident

[City], [Date] — MazeVault acknowledges a security incident affecting
[general scope]. We detected [general description] on [date] and
immediately activated our incident response procedures.

[If customer data affected]:
We are directly notifying all affected customers and providing guidance
on recommended protective actions.

Our investigation is ongoing in coordination with relevant authorities.
The security and privacy of our customers' data remains our highest priority.

We will provide updates as our investigation progresses.

Media Contact: [Name, email, phone]

8. Evidence Preservation

8.1 Principles

All evidence collection and preservation SHALL adhere to the following principles:

  • Integrity: Evidence must not be altered during collection or storage
  • Chain of Custody: Complete documentation of who accessed evidence, when, and why
  • Admissibility: Collection methods must support potential legal proceedings
  • Completeness: All relevant evidence types must be collected
  • Timeliness: Evidence must be collected before it is overwritten or expires

8.2 Evidence Types and Collection

Evidence Type Collection Method Priority Retention
Audit Logs Chain-hashed, tamper-evident logs exported from AuditService Critical Minimum 3 years
System Logs Centralized log aggregation export (structured JSON) Critical Minimum 3 years
Application Logs Export from log management system High Minimum 3 years
Network Captures PCAP from affected network segments (if available) High Duration of investigation + 1 year
Memory Dumps Live memory capture from affected systems (if applicable and feasible) Medium Duration of investigation + 1 year
Disk Images Forensic disk image (bit-for-bit copy) of affected systems High (if compromise confirmed) Duration of investigation + 3 years
Configuration Snapshots System configuration at time of incident High Minimum 3 years
Authentication Logs All auth events for affected accounts/systems Critical Minimum 3 years
SIEM Alerts/Correlations Complete alert chain and correlation data Critical Minimum 3 years

8.3 Chain-Hashed Audit Log Integrity

MazeVault's AuditService produces tamper-evident audit logs using cryptographic hash chaining:

  • Each audit event includes a hash of the previous event, creating an immutable chain
  • Any modification to historical log entries breaks the hash chain and is immediately detectable
  • Hash chain validation is performed automatically and can be verified during forensic analysis
  • These logs serve as authoritative evidence of system activity during an incident

8.4 Chain of Custody Requirements

For each piece of evidence collected:

  1. Label: Unique evidence identifier linked to incident ID
  2. Record: Date/time of collection, collector identity, collection method
  3. Secure Storage: Evidence stored in access-controlled, integrity-protected storage
  4. Access Log: All access to evidence must be logged (who, when, purpose)
  5. Transfer Records: Any transfer between parties documented and signed
  6. Integrity Verification: Hash values computed at collection and verified at each access

8.5 Evidence Retention

  • Minimum retention period: 3 years from incident closure for all critical evidence
  • Extended retention: If legal proceedings are initiated or anticipated, evidence SHALL be retained until proceedings conclude plus applicable appeal periods
  • Regulatory requirements: Evidence supporting regulatory notifications SHALL be retained for the period specified by the relevant regulation (minimum 5 years for DORA)
  • Disposal: Evidence disposal requires Incident Commander approval and SHALL be documented

9. Incident Notification Service

9.1 Technical Implementation

The IncidentService provides automated incident lifecycle management and notification:

9.1.1 Incident Creation and Notification

When a security incident is created in the system:

  1. IncidentService generates a unique incident identifier
  2. Automatic notifications are triggered to all active notification channels:
  3. Email: Sent to IRT distribution list and configured escalation contacts
  4. Slack: Posted to designated security incident channel
  5. Microsoft Teams: Posted to security operations team channel
  6. Jira: Incident ticket created with appropriate priority and assignment
  7. Webhook: HTTP POST to configured external endpoints (SIEM, SOAR integration)
  8. Audit event INCIDENT_DETECTED is logged with full incident metadata
  9. Incident status is set to open

9.1.2 Status Lifecycle

open → investigating → contained → resolved → closed
Status Description Trigger
open Incident detected, awaiting triage Automatic on creation
investigating IRT actively analyzing and responding Manual: IC confirms triage complete
contained Active threat neutralized, scope limited Manual: IC confirms containment
resolved Root cause removed, systems recovered Manual: IC confirms recovery
closed Post-incident complete, all reports submitted Manual: IC final sign-off

Each status transition generates notifications to all active channels and creates an audit event.

9.1.3 Notification Channel Configuration

All notification channels are managed through the administrative interface. Each channel can be independently enabled/disabled. Channel health is monitored; delivery failures trigger fallback notifications via alternative channels.


10. Testing and Exercises

10.1 Exercise Program

Exercise Type Frequency Scope Participants
Tabletop Exercises Semi-annual (every 6 months) Scenario-based discussion of incident response procedures; decision-making practice Full IRT + management
Simulation Exercises Annual Realistic simulated incident with hands-on response activities; end-to-end process validation Full IRT + operations
DR Failover Tests Quarterly Technical disaster recovery procedure execution; gateway failover, database restore Operations + Infrastructure
Communication Tests Quarterly Verify notification channels functional; test escalation contacts reachable Communications Lead + IRT
Post-Real-Incident Review After each P1/P2 incident Comprehensive review of actual incident response; identify improvements All involved personnel

10.2 Exercise Requirements

  • All exercises SHALL have defined objectives, scenarios, and success criteria
  • Exercise results SHALL be documented, including identified gaps and improvement actions
  • Improvement actions SHALL be tracked to completion with assigned owners and deadlines
  • Exercise scenarios SHALL be updated annually to reflect current threat landscape
  • At least one annual exercise SHALL include a regulatory notification simulation

10.3 Exercise Scenarios (Minimum)

  1. Customer data breach via exploited vulnerability
  2. Ransomware attack affecting production database
  3. Insider threat: privileged user exfiltrating secrets
  4. Supply chain compromise via compromised dependency
  5. Gateway compromise and lateral movement attempt
  6. Encryption key compromise requiring emergency rotation

11. Metrics

11.1 Key Performance Indicators

Metric Target Measurement
Mean Time to Detect (MTTD) <15 min (P1), <1 hour (P2) Time from incident occurrence to detection
Mean Time to Respond (MTTR) <30 min (P1), <2 hours (P2) Time from detection to containment initiation
Mean Time to Recover <4 hours (P1), <8 hours (P2) Time from containment to service restoration
Regulatory Notification Compliance 100% on-time Percentage of notifications submitted within required timeframes
Incidents by Severity per Quarter Trending downward Count of incidents per severity level
False Positive Rate <5% for P1/P2 alerts Percentage of alerts that are false positives
Exercise Completion Rate 100% per schedule Percentage of planned exercises completed
Post-Incident Action Completion 100% within 30 days Percentage of PIR actions completed on time

11.2 Reporting

  • Monthly: Security operations dashboard (incidents, alerts, trends) to CISO
  • Quarterly: Incident summary report to CEO and Board
  • Annual: Comprehensive incident response program review, including metrics trends, exercise results, and improvement plan

12. Integration with Other Processes

12.1 Vulnerability Management (MV-LEG-006)

  • A vulnerability actively exploited in the wild or confirmed exploited against MazeVault systems SHALL be escalated to an incident
  • Incident forensics may identify previously unknown vulnerabilities; these SHALL be entered into the vulnerability management process
  • Critical vulnerability patches may be deployed under emergency change authority granted by Incident Commander

12.2 Change Management

  • Failed changes that result in security degradation SHALL be treated as incidents
  • Emergency changes during incident response SHALL be retrospectively documented and reviewed
  • Post-incident remediation changes follow standard change management with incident reference

12.3 Business Continuity / Disaster Recovery (MV-LEG-008)

  • A Critical (P1) incident causing extended service outage (>RTO threshold) SHALL trigger BCP activation
  • The Incident Commander coordinates with BCP roles during combined incident/continuity events
  • DR procedures (failover, restore) may be invoked as part of incident recovery (Phase 4)
  • BCP activation does NOT supersede incident response; both processes run in parallel with coordinated leadership

12.4 Risk Management (MV-LEG-003)

  • Each P1/P2 incident SHALL result in a risk register update
  • Incident trends inform annual risk assessment updates
  • New risks identified during incident response are immediately added to the risk register

12.5 Access Control (MV-LEG-005)

  • Incidents involving unauthorized access trigger immediate access review for affected systems
  • Privilege escalation incidents require full access audit of the compromised account chain
  • Post-incident: access policies updated to prevent recurrence

13. Compliance Mapping

Requirement Section in This Document
Act No. 264/2025 Sb. §15 (Incident reporting to NUKIB) Section 6.1 (24-hour notification), Section 7.3
NIS2 Directive Art. 23 (Incident notification) Section 6.1, Section 6.2
DORA Art. 17 (ICT-related incident management) Sections 2-5 (full incident lifecycle)
DORA Art. 18 (Classification of ICT-related incidents) Section 2 (classification matrix)
DORA Art. 19 (Reporting of major ICT-related incidents) Section 6.1 (4-hour initial notification), Section 6.2
GDPR Art. 33 (Notification to supervisory authority) Section 6.1 (72-hour DPA notification)
GDPR Art. 34 (Communication to data subject) Section 6.1 (data subject notification)
ISO/IEC 27001:2022 A.5.24 (Information security incident management planning) Sections 1-5
ISO/IEC 27001:2022 A.5.25 (Assessment and decision on information security events) Section 2 (classification), Section 5.1 (triage)
ISO/IEC 27001:2022 A.5.26 (Response to information security incidents) Sections 5.2-5.4
ISO/IEC 27001:2022 A.5.27 (Learning from information security incidents) Section 5.5, Section 11
ISO/IEC 27001:2022 A.5.28 (Collection of evidence) Section 8
SOC 2 CC7.3 (Incident response) Sections 2-5, 8
SOC 2 CC7.4 (Incident recovery) Sections 5.4, 12.3

Document ID Title
MV-LEG-001 Information Security Policy
MV-LEG-002 Cryptography Policy
MV-LEG-003 Risk Management Policy
MV-LEG-004 Logging & Monitoring Policy
MV-LEG-005 Access Control Policy
MV-LEG-006 Vulnerability & Patch Management Policy
MV-LEG-008 Business Continuity & Disaster Recovery Plan

Document Control

Version Date Author Change Description
1.0.0 2026-05-01 CISO Initial release

END OF DOCUMENT