Information sharing and stakeholder coordination

Compliance teams often “share information” informally, but auditors and assessors look for a repeatable capability: the right cyber information reaches the right people fast enough to change outcomes. For CCOs and GRC leads, the practical challenge is coordination friction: security has technical detail, operations needs service impact, legal needs privilege boundaries, procurement needs third-party reach, and executives need decision options.

This requirement page focuses on building a light but defensible operating model for information sharing and stakeholder coordination. You will define what qualifies as actionable cyber information, set triggers for when sharing happens, and standardize the channels and artifacts that prove it happened. The goal is not more communication. The goal is controlled, trusted communication that measurably supports incident response, vulnerability management, third-party risk, and enterprise governance.

The underlying source requirement is from DOE’s Cybersecurity Capability Maturity Model (C2M2). It is framed as a capability expectation, so your evidence must show both design (policy/process) and operation (real examples). Daydream can help you document triggers, workflows, and artifacts in one place so you can answer assessor questions with primary evidence instead of narratives.

Regulatory text

Requirement (C2M2-09): “Share actionable cyber information with internal and external stakeholders.” ¹

What the operator must do

You must implement a repeatable mechanism to distribute actionable cybersecurity information to:

• Internal stakeholders (people who can decide, approve, fix, or prepare), and
• External stakeholders (third parties and coordination partners who need the information to reduce shared risk).

“Actionable” means the information is packaged so the recipient can take a specific step: authorize containment, prioritize patching, notify customers, coordinate with a managed service provider, or validate compensating controls. Raw telemetry alone rarely qualifies unless the recipient is explicitly responsible for analysis and response.

Plain-English interpretation (what assessors mean)

Assessors typically interpret this requirement as:

1. you know who your stakeholders are, 2) you know what you will share, 3) you share it through trusted channels, and 4) you can prove sharing led to coordination or decisions.

If you can only show ad hoc emails and meeting chatter, you will struggle to demonstrate a controlled capability. If you can show defined triggers, named recipients, approved channels, and real records of sharing during incidents or material vulnerabilities, you will meet the intent.

Who it applies to

Entity scope

This requirement is most directly relevant to:

• Critical infrastructure operators
• Energy sector organizations ¹

Operational context (where it shows up in real life)

You need this capability wherever cyber risk crosses team boundaries or organizational boundaries, including:

• Incident response (containment decisions, outage coordination, executive updates)
• Vulnerability and patch management (risk-based prioritization, maintenance windows)
• Third-party and supply chain events (shared IOCs, affected product notices, vendor coordination)
• OT/ICS environments (coordination between IT security, engineering, safety, and plant operations)
• Regulatory or contractual notification workflows (internal alignment before external notices)

What you actually need to do (step-by-step)

Use the steps below as a build sheet. The goal is a minimal, auditable process that scales.

Step 1: Define “actionable cyber information” for your org

Create a one-page definition with examples and non-examples.

Include common categories:

• Incident indicators (IOCs, TTPs, observed behaviors) packaged with what to block or monitor
• Vulnerabilities and exposures (affected assets, severity rationale, recommended mitigations)
• Service impact and operational risk (systems affected, expected downtime, safety implications)
• Third-party security notifications that affect you (breach notices, critical product advisories)
• Required actions (patch by date, isolate host, rotate keys, disable account, notify partner)

Avoid a common trap: shipping raw scans or SIEM alerts to executives. Convert technical data into a decision brief for non-technical stakeholders.

Step 2: Build a stakeholder map with “need-to-act” logic

Create a stakeholder register that answers:

• Who must be notified for each event type?
• Who approves key decisions (shutdown, public comms, legal positions)?
• Who executes response actions?
• Who needs situational awareness only?

Stakeholder groups to consider

• Internal: SOC/IR, IT Ops, OT Ops/Engineering, Legal, Privacy, Compliance, Communications, HR, Procurement/TPRM, Product, Finance, Executive leadership, Board liaison
• External: critical vendors/MSPs, cloud providers, sector ISACs, upstream/downstream partners, key customers (as contractually required)

Tie recipients to event types. If you cannot explain why someone receives a class of information, reduce the list.

Step 3: Define sharing triggers and thresholds

Write explicit triggers so the process does not depend on personal judgment alone.

Trigger examples (adapt to your environment):

• Confirmed incident with potential business impact
• Suspected incident requiring containment action outside the SOC
• Vulnerability requiring emergency change or compensating controls
• Third-party notice indicating your data or operations could be affected
• Detection of activity that may propagate across connected environments (IT/OT boundary, shared identity, shared remote access)

For each trigger, define:

• required recipients (by role, not by name)
• required message format (bullet brief, ticket, advisory)
• required channel (ticketing system, secure chat, phone bridge, encrypted email)
• required timeline expectation (your internal standard)

Step 4: Establish trusted coordination channels (and rules of use)

Assessors want to see that you control where sensitive cyber information goes.

Minimum channel controls

• A documented list of approved channels per information type (public, internal, confidential, restricted)
• Membership management for key channels (incident war room chat, bridge lines, distribution lists)
• An escalation path if a channel is unavailable
• A rule for handling sensitive content (e.g., credentials, exploit details, regulated data)

Practical pattern: treat the incident “war room” as a controlled record. Make sure invite lists and transcripts (if kept) align to legal and privacy expectations.

Step 5: Integrate sharing into existing workflows (don’t create a parallel process)

You will operationalize faster if you hook information sharing into work your teams already do:

• Incident tickets: required “stakeholder notification” field and checklist
• Vulnerability tickets: “business owner notified” and “operations window coordinated”
• Third-party risk: intake mechanism for vendor advisories and internal routing
• Change management: emergency changes require a security advisory to impacted owners
• Executive reporting: predefined cadence and template during active events

Step 6: Standardize message formats

Create templates. Templates reduce omissions.

Recommended templates

• Cyber advisory (internal): what happened, what’s affected, what to do now, owner, due date, where to ask questions
• Executive brief: impact, risk, options, decision needed, current actions, next update time
• Third-party coordination note: what you observed, what you need from them, what you will do, secure contact method

Step 7: Prove the loop closed (coordination outcomes)

Sharing is incomplete if it does not drive coordination. Capture:

• acknowledgments
• decisions and approvals
• task assignments
• completion evidence (patch applied, access disabled, rule deployed)
• after-action review items tied to communication gaps

Required evidence and artifacts to retain

Aim for “design + operating” evidence.

Design evidence (what should happen)

• Information sharing and stakeholder coordination procedure (or section in IR/vuln/TPRM procedures)
• Stakeholder register with roles, contact mechanisms, and alternates
• Trigger matrix (event type → recipients → channel → message template)
• Approved communication channels list, with access control approach
• Message templates (advisory, exec brief, third-party coordination)

Operating evidence (what did happen)

• Incident communications log (tickets, notifications, bridge notes)
• Vulnerability advisories sent to system owners and evidence of action taken
• Third-party coordination records (support cases, encrypted emails, portal messages)
• After-action reports documenting communication effectiveness and improvements
• Training/awareness records for on-call and coordinating roles

Retention tip: store artifacts in a system that preserves timestamps and access controls. Daydream can centralize the trigger matrix, stakeholder register, and evidence mapping so you can answer “show me” requests quickly.

Common exam/audit questions and hangups

Auditors and assessors commonly ask:

1. What makes information “actionable” here? Show your definition and examples.
2. Who are your internal and external stakeholders? Provide a role-based register.
3. How do you decide when to notify executives or operations? Show trigger criteria and samples.
4. How do you prevent oversharing sensitive information? Show channel approvals and access controls.
5. Show evidence from a real incident or vulnerability. Provide an end-to-end record: trigger → notification → decision/task → completion.
6. How do you coordinate with third parties? Show contracts/contacts where relevant and actual coordination records.

Hangup to expect: teams can often show incident comms, but not vulnerability comms or third-party advisory routing. Build all three.

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails in practice	How to avoid it
Treating “sharing” as forwarding raw alerts	Recipients can’t act; noise erodes trust	Require a “what to do” section in every advisory
No trigger definition	Notifications depend on personalities and availability	Publish a trigger matrix tied to event types
Overbroad distro lists	Confidential info spreads; stakeholders disengage	Role-based, need-to-act recipients; review membership
Uncontrolled channels (personal email, consumer chat)	Evidence is fragmented; confidentiality risk	Document approved channels and enforce them for incidents
No proof of outcomes	You can’t show coordination happened	Capture decisions, tasks, and closure evidence in tickets
External coordination handled ad hoc	Third-party issues stall; contractual duties get missed	Maintain third-party contacts, escalation paths, and templates

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement. Treat the risk primarily as operational and assurance risk: poor coordination increases the chance of delayed containment, inconsistent messaging, and missed third-party dependencies. In a C2M2 assessment context, weak evidence often shows up as “process exists but is not institutionalized,” especially when communication artifacts are missing or inconsistent.

Practical 30/60/90-day execution plan

First 30 days: define and align

• Draft your definition of actionable cyber information and get sign-off from Security, IT Ops/OT Ops, Legal, and Compliance.
• Build a stakeholder register (roles, primary/alternate contacts, escalation paths).
• Inventory current channels (ticketing, secure chat, bridge lines, email groups) and mark which are approved for restricted cyber information.
• Create two templates: executive brief and internal cyber advisory.

Days 31–60: implement triggers and integrate workflows

• Publish a trigger matrix mapped to incident severity, vulnerability criticality, and third-party notices.
• Update incident and vulnerability tickets to include required fields: “stakeholders notified,” “channel,” “time sent,” “decision/action required.”
• Stand up controlled “war room” mechanics: membership rules, naming convention, and evidence capture expectations.
• Run one tabletop focused solely on communications flow: SOC → Ops → Legal/Comms → executives → third parties.

Days 61–90: validate with operating evidence

• Collect operating evidence from at least one incident, vulnerability cycle, or third-party advisory event.
• Perform a lightweight QA review: did messages include actions, owners, and timelines; did recipients act; was sensitive info shared only in approved channels?
• Add gaps to an improvement backlog and assign owners.
• Load your artifacts and evidence mapping into Daydream so audits and assessments pull from a single system of record.

Frequently Asked Questions

What counts as “external stakeholders” for the information sharing and stakeholder coordination requirement?

External stakeholders are third parties and coordination partners who need cyber information to reduce shared risk, such as critical vendors, service providers, and key partners. Define them in a role-based register so sharing is intentional, not ad hoc.

Do we have to share indicators of compromise (IOCs) externally?

Share externally when it is necessary for coordination and permitted by your policies and contractual or legal constraints. The requirement focuses on actionable information, so pair IOCs with context and requested actions when you do share.

How do we balance rapid sharing with confidentiality and privilege?

Pre-approve channels and define what content can travel in each channel, then use templates that separate technical details from legal-sensitive analysis. Route legal assessments through counsel-directed paths while still sending operational actions to responders.

We already have incident bridges. Is that enough?

Not by itself. Assessors typically expect defined triggers, stakeholder mapping, and evidence that communications drove actions, plus coverage for vulnerabilities and third-party notices, not only major incidents.

What evidence is most persuasive in an assessment?

End-to-end records that show a trigger occurred, stakeholders were notified through an approved channel, decisions/tasks were assigned, and actions completed. Tickets, advisories, bridge notes, and after-action reports usually carry more weight than narratives.

How should we handle stakeholder coordination in OT/ICS environments?

Treat engineering, safety, and operations as primary stakeholders with clear escalation paths and decision rights. Build OT-specific triggers and templates that translate cyber findings into operational risk, maintenance constraints, and safety considerations.

Related compliance topics

• 2025 SEC Marketing Rule Examination Focus Areas
• Access and identity controls
• Access Control (AC)
• Access control and identity discipline
• Access control lifecycle management

Footnotes

1. DOE C2M2