Safeguard 17.4: Establish and Maintain an Incident Response Process

To meet the safeguard 17.4: establish and maintain an incident response process requirement, you must run a documented, repeatable incident response (IR) process that defines roles, triggers, triage, containment, eradication, recovery, communications, and post-incident learning, then retain evidence that the process runs in real incidents and exercises. Your fastest path is to standardize intake-to-closure workflows and make evidence capture automatic. ¹

Key takeaways:

• A written IR plan is not enough; auditors look for a working process with tickets, timelines, decisions, and approvals.
• Define severity levels and decision rights so containment and communications happen quickly and consistently.
• Build an evidence pack template ² so you can prove control operation without scrambling. ¹

Safeguard 17.4 sits in the “Incident Response Management” control family and expects an organization to have an incident response process that people can follow under pressure, not a shelf document. In practice, this requirement becomes a test of operational readiness: can you detect, declare, coordinate, contain, and recover from security incidents in a controlled way, with clear accountability and records that stand up in an exam?

For a Compliance Officer, CCO, or GRC lead, the hard part is translating “have a process” into concrete operating procedures that engineering, IT, security, privacy, and legal will actually use. The second hard part is evidence. Many teams can describe what they would do; fewer can produce a consistent trail of incident tickets, decision logs, stakeholder notifications, and post-incident actions that prove the process ran as designed.

This page gives requirement-level implementation guidance you can operationalize quickly: what to scope, what to build, how to run it, what artifacts to retain, and what auditors commonly challenge. It is written to help you map safeguard 17.4 to day-to-day operations and recurring evidence capture. ¹

Regulatory text

Excerpt (as provided): “CIS Controls v8 safeguard 17.4 implementation expectation (Establish and Maintain an Incident Response Process).” ¹

Operator interpretation (plain English)

You need a defined incident response process that:

• Starts with intake (how potential incidents are reported and logged),
• Moves through triage and classification (what makes something an incident and how you set severity),
• Coordinates response actions (containment, eradication, recovery),
• Manages communications (internal stakeholders and relevant external parties, when applicable),
• Closes with learning (post-incident review and tracked remediation),
• Produces evidence that the process is followed in both real incidents and exercises. ¹

This is a process control. Auditors will test consistency: same types of incidents should produce similar records, approvals, and timelines, even when responders change.

Who it applies to (entity and operational context)

Safeguard 17.4 applies broadly to enterprises and technology organizations that need to manage cybersecurity incidents in a controlled way. ¹

Operationally, it applies wherever you have:

• Production systems (cloud, on-prem, SaaS administration),
• Sensitive data (customer data, employee data, regulated data),
• Third parties that can introduce incident pathways (outsourced IT, managed security providers, key SaaS providers),
• A security monitoring function (in-house or outsourced) that detects and escalates events.

If you run a lean team, your “process” may be lightweight, but it still needs defined roles, decision rights, and an evidence trail.

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

Step 1: Define scope and incident taxonomy

1. Define what counts as an incident for your organization (security incident vs. operational outage vs. privacy incident).
2. Create severity levels with objective triggers (examples: confirmed unauthorized access, suspected malware execution, credential compromise, data exposure risk).
3. Map each severity to required actions: who must be paged, who declares the incident, and who approves high-risk actions (e.g., blocking customer access, rotating keys, taking systems offline).

Deliverable: an “Incident Criteria & Severity Matrix” that responders can use without debate.

Step 2: Establish roles, responsibilities, and decision rights (RACI)

Define, at minimum:

• Incident Commander (IC): runs the incident bridge, owns the timeline, assigns actions.
• Technical Leads: endpoint, cloud, identity, application, network (use what you have).
• Comms Owner: internal updates; coordinates with Legal/Privacy for external notifications when required.
• Scribe: maintains decision log and timeline in the ticket.
• Approvers: who can authorize production-impacting actions and customer-facing statements.

Make this a one-page RACI that fits on a screen. If a role is outsourced, name the service and escalation path.

Step 3: Build the end-to-end workflow in a system of record

Pick one system of record for incidents (common choices: ticketing platform, incident management tooling, or a dedicated IR case management queue). Configure:

• A single “Security Incident” ticket type with required fields (severity, status, affected assets, data types, third parties involved, containment actions, timestamps).
• Status states that reflect actual work: Reported → Triage → Confirmed/Not Confirmed → Containment → Eradication → Recovery → Post-Incident Review → Closed.
• Required approvals for key transitions (example: IC approval to declare Severity 1; CISO/CTO approval to close without PIR).

Goal: if it isn’t in the ticket, it didn’t happen (for audit purposes).

Step 4: Write the IR process document responders will follow

Keep it operational. Include:

• Intake channels: monitoring alerts, employee reporting, third-party notifications.
• Triage steps: validation, scoping, initial hypotheses, evidence preservation.
• Containment playbook pointers: isolate hosts, disable accounts, revoke tokens, block indicators, segment networks.
• Eradication and recovery: rebuild vs. clean, credential rotation, restore from backups, validation checks.
• Communications: update cadence, stakeholder list, external comms gating through Legal/Privacy.
• Evidence handling: log retention, chain-of-custody expectations if your org requires it.
• Post-incident review: required attendees, required outputs, remediation tracking.

Tie the document to the workflow so each step produces an artifact.

Step 5: Integrate third parties into the process

Operationalize third-party involvement:

• Maintain an incident contact list for critical third parties (account owner, security contact, escalation route).
• Define when to notify a third party (example: if their product is implicated or your tenant shows suspicious behavior).
• Require timely notification to you from third parties for security events affecting your environment, where contractually feasible.
• Capture third-party touchpoints in the incident ticket (time contacted, response received, actions taken).

Step 6: Exercise the process and fix what breaks

Run incident response exercises so you can prove the process works:

• Tabletop scenarios aligned to your highest-risk systems (identity compromise, ransomware, cloud key exposure, SaaS admin compromise).
• Validate your severity matrix, paging, decision rights, and communications approvals.
• Convert exercise findings into tracked remediation work.

Exercises are also where you discover missing access, unclear ownership, and broken escalation paths.

Step 7: Operationalize recurring evidence capture (audit-ready by default)

Map safeguard 17.4 directly to evidence streams:

• Per incident: ticket, timeline, approvals, containment actions, comms log, PIR, remediation tracking.
• Per exercise: scenario, attendees, decisions, after-action report, remediation plan.
• Per quarter or cadence you choose: metrics snapshot (volume, time-to-triage themes), process review notes, roster validation.

This is the “control operation and recurring evidence capture” pattern auditors respond to. ¹

Required evidence and artifacts to retain

Use this as your evidence checklist:

Core documents

• Incident Response Process document (versioned, approved)
• Incident Criteria & Severity Matrix
• IR RACI and on-call/escalation roster
• Communications plan (internal and external gating)

Operational records (most important)

• Incident tickets/cases with required fields completed
• Incident timeline and decision log (who decided what, when)
• Containment/eradication/recovery task records (change tickets, runbooks, command outputs when appropriate)
• Post-incident review reports and remediation tickets
• Exercise/tabletop materials and after-action reports

Program governance

• Process review/refresh records (e.g., meeting notes, approval of updates)
• Training or onboarding evidence for responders (attendance, acknowledgments)

Retention period should align to your internal policy; safeguard 17.4 focuses on having the artifacts and showing repeatability. ¹

Common exam/audit questions and hangups

Auditors and assessors often probe these areas:

• “Show me two recent incidents end-to-end.” They want to see intake, classification, response actions, and closure artifacts.
• “How do you decide severity?” If severity is ad hoc, you’ll get a design finding.
• “Who can declare an incident and who can take production-impacting actions?” Missing decision rights creates execution risk.
• “How do third parties enter the process?” Many programs omit outsourced IT/security providers.
• “Where is your post-incident learning tracked?” A PIR with no remediation ticket trail reads as theater.

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails	Fix
Writing a long IR plan that nobody uses	Responders work from Slack and memory	Embed the process into the ticket workflow; make fields mandatory
No clear incident declaration criteria	Incidents are under-reported or over-escalated	Publish a severity matrix with examples and decision rights
Evidence scattered across tools	You can’t reconstruct what happened	Define a system of record and link artifacts into the incident case
Post-incident review is optional	Repeat incidents, no closure	Require PIR for defined severities; track remediations like any other risk
Third parties are excluded	Material gaps in visibility and response	Add third-party notification and escalation steps and test them in exercises

Enforcement context and risk implications

CIS Controls v8 is a framework, not a regulator, and this requirement page does not include public enforcement case sources in the provided catalog. Your risk is still real: if you cannot show a functioning incident response process with evidence, you invite audit findings, slower containment, inconsistent communications, and avoidable business impact during an incident. ¹

Practical 30/60/90-day execution plan

First 30 days (stand up the backbone)

• Appoint IR roles (IC, comms, scribe) and document decision rights.
• Publish severity matrix v1 and escalation roster.
• Implement the incident ticket type and required fields in your system of record.
• Draft the IR process document as a workflow-first guide, aligned to your ticket states.

Days 31–60 (make it real and testable)

• Run at least one tabletop exercise using your new workflow and capture artifacts like a real incident.
• Build PIR and after-action templates; require remediation tickets for findings.
• Integrate third-party contacts and notification steps for critical third parties.
• Start a lightweight metrics snapshot so you can show governance and improvement.

Days 61–90 (harden and audit-proof)

• Tune severity criteria based on exercise outcomes and any real incidents.
• Add minimum evidence standards per incident (what must be attached or linked).
• Train responders and backup responders; validate roster and paging.
• Prepare an “IR evidence binder” view (saved searches, linked templates, and export steps). Daydream can help structure this as recurring evidence capture tied to safeguard 17.4 so audits become retrieval, not reinvention. ¹

Frequently Asked Questions

Do we need a dedicated incident response tool to satisfy safeguard 17.4?

No. You need a consistent system of record and a repeatable workflow. A ticketing system can work if it enforces required fields, status states, and approvals. ¹

What’s the minimum proof an auditor will accept that our incident response process is operating?

Completed incident records or exercise records that show intake, classification, actions taken, communications decisions, and closure with post-incident outputs. A policy alone rarely passes an operating effectiveness check. ¹

How do we handle incidents that start at a third party (SaaS provider, MSP, cloud vendor)?

Treat third-party notifications as an intake channel, open an internal incident case, and document your decisions and compensating actions even if the third party performs the technical remediation. Capture their updates in your case record. ¹

Who should own the incident response process: Security, IT, or Compliance?

Security or IT usually runs execution, but compliance should own the control mapping, evidence expectations, and audit readiness. Assign an Incident Commander function and make RACI explicit so ownership doesn’t drift. ¹

Do we need to run formal post-incident reviews for every incident?

Define a threshold based on severity. Require PIRs for higher-severity events and for any incident with meaningful root-cause uncertainty or control gaps, then track remediation to closure. ¹

How do we keep evidence collection from slowing down responders during an incident?

Make evidence capture the byproduct of the workflow: required ticket fields, a timeline section, and linked tasks/changes. Use templates so scribes can capture decisions in real time without extra tools. ¹

Footnotes

1. CIS Controls v8; CIS Controls Navigator v8

2. CIS Controls v8