Safeguard 17.6: Define Mechanisms for Communicating During Incident Response

Safeguard 17.6 requires you to pre-define how your organization will communicate during an incident—who can send messages, which channels are approved, what templates to use, and how you will coordinate internal teams and third parties under pressure ¹. Operationalize it by establishing an incident communications plan, secure communication paths, and repeatable execution plus evidence capture.

Key takeaways:

• Define approved incident communication channels, roles, and escalation paths before the incident ².
• Build “go kits” (contact trees, templates, secure tools) so responders can communicate fast without improvising.
• Treat communication as an auditable control: test it, log it, and retain artifacts that prove it ran as designed.

Safeguard 17.6: define mechanisms for communicating during incident response requirement is about preventing chaos when the stakes are highest. During an incident, delays and conflicting messages are common failure modes: responders can’t reach decision-makers, teams argue in public Slack channels, executives call the wrong third party, or legal/comms approvals bottleneck critical notifications. CIS expects you to design communication mechanisms ahead of time so your incident response is coordinated, secure, and repeatable ¹.

For a Compliance Officer, CCO, or GRC lead, the practical goal is simple: you need a documented, exercised incident communications approach that (a) protects sensitive details, (b) reaches the right people quickly, (c) supports required stakeholder notifications, and (d) produces evidence an assessor can follow end-to-end. This page translates the requirement into concrete operational steps, identifies the artifacts you should retain, and calls out the places audits bog down: unclear authority to speak, unapproved tools, and missing records of what was communicated and when.

Regulatory text

Framework requirement (excerpt): “CIS Controls v8 safeguard 17.6 implementation expectation (Define Mechanisms for Communicating During Incident Response).” ¹

Operator interpretation: You must decide—before an incident—how communications will work across the incident lifecycle. That includes:

• Channels: which tools are approved for incident coordination (and which are banned).
• Participants and roles: who is on the distribution lists, who can declare an incident, and who can communicate externally.
• Escalation: how communications escalate by severity.
• Security: how you protect incident details (need-to-know, encryption, access control).
• Execution: how the mechanism is used during real incidents and exercises, with retained evidence.

Plain-English interpretation (what the requirement really asks)

If your incident response plan says “communicate as needed,” you will fail this safeguard in practice. CIS 17.6 expects a mechanism, meaning a defined and workable system that people can follow under stress:

• People know where to go (war room) and how to reach leadership.
• You have a secure way to share sensitive indicators, impacted assets, and containment steps.
• You can coordinate with third parties (cloud providers, IR firms, outside counsel, critical vendors) without scrambling for contact info.
• You reduce the risk of unauthorized disclosure and inconsistent statements.

Who it applies to

Entities: Any enterprise or technology organization adopting CIS Controls v8 as a security baseline ¹.

Operational contexts where this becomes non-negotiable:

• You run a SOC or on-call security rotation that must coordinate across IT, Legal, Privacy, HR, and Communications.
• You rely on third parties for hosting, payment processing, customer support platforms, EDR/MDR, or managed infrastructure.
• You operate in a regulated environment where notification duties exist (you still need counsel to interpret the laws, but you need the communication mechanism regardless).
• You support remote/hybrid operations where “go find someone in the office” is not a plan.

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

The steps below are written so you can assign owners, track completion, and produce audit-ready artifacts.

1) Define incident communication objectives and constraints

Document what “good” looks like:

• Fast internal coordination without exposing sensitive details broadly.
• Clear authority for external statements.
• Traceability: you can reconstruct a timeline of decisions and notifications.

Practical constraint list to capture:

• Approved tools (and tools explicitly disallowed for incident details).
• Data handling rules for incident intel (screenshots, logs, customer data).

2) Establish roles, authority, and decision rights

Create a RACI-style mapping for incident communications:

• Incident Commander (IC): runs the response bridge/war room and sets cadence.
• Comms Lead: drafts internal updates and coordinates with PR/Corp Comms.
• Legal/Counsel: reviews external communications and preserves privilege where applicable.
• Executive Sponsor: authorizes high-impact notifications and resource decisions.
• Third-Party Coordinator: manages communications with critical third parties (including vendors and incident response retainers).

Minimum decision rights to nail down:

• Who can declare an incident and open the war room.
• Who can approve communications to customers, regulators, or the media.
• Who can engage outside counsel or an IR firm.

3) Define approved communication channels (primary + backup)

Build a channel matrix that is explicit and usable.

Example channel matrix (adapt to your environment):

Use case	Primary channel	Backup channel	Access control expectation
Incident “war room” collaboration	Dedicated secure chat/workspace	Conference bridge + email distro	Restricted membership, logged access
Executive notifications	Pager/SMS + phone	Email	Limited to exec roster
Technical coordination (IOCs, logs)	Ticketing/IR case tool	Encrypted file share	Need-to-know, retention rules
Third party engagement	Pre-approved contact path	Alternate contacts	Documented contacts + call script

Key implementation detail: include an “if corporate systems are compromised” option. Many organizations fail here because their communication mechanism depends on the same identity provider or email system that could be down.

4) Build contact trees and distribution lists that survive real life

Create and maintain:

• On-call lists for Security/IT.
• Exec escalation list.
• Legal/Privacy/HR contacts (primary + alternate).
• Critical third party contacts (account reps, emergency support, IR retainer hotline).
• After-hours procedure.

Operational rule: put a named owner on contact list maintenance (GRC can govern; Security Ops usually runs updates).

5) Create message templates and approval workflows

Templates reduce delay and prevent accidental disclosure. Create:

• Internal status update template (what happened, what’s impacted, what’s being done, next update time).
• Executive briefing template (business impact, decisions needed).
• Third party outreach template (request logs, containment action, point of contact).
• Customer holding statement template (high-level, non-technical; legal reviewed).
• “Do not share” guidance for employees.

Approval workflow must be explicit:

• What requires Legal review vs. what the IC can send immediately.
• What can be shared with which audiences.

6) Integrate communications into the incident response playbooks

Add communications steps into the playbooks you actually run:

• At incident declaration: open war room, start incident log, notify distribution list.
• During containment: set update cadence and decision checkpoints.
• During recovery: notify stakeholders of service restoration actions.
• Post-incident: share lessons learned and required follow-ups.

This is where many teams stumble: they maintain a comms policy that never appears in the runbook, so responders improvise.

7) Test the mechanism and retain evidence

Run tabletop exercises that include communications injects:

• Simulate conflicting information and force the approval process.
• Simulate an outage of normal tools and require fallback comms.
• Include at least one critical third party coordination scenario.

Capture results:

• What channels worked, what failed, who couldn’t be reached.
• Action items with owners.

8) Operationalize ongoing evidence capture (audit readiness)

Map the requirement to a recurring evidence routine (recommended control in the provided guidance). The goal is that every incident and exercise yields a small, consistent evidence pack you can produce quickly.

Daydream can help by turning the evidence pack into a repeatable workflow: control narrative, evidence requests, artifact storage, and assessor-ready exports aligned to CIS v8 language ¹.

Required evidence and artifacts to retain

Keep artifacts lightweight but complete. Auditors want proof the mechanism exists and was used.

Core artifacts:

• Incident Communications Plan (or IR Plan section) describing channels, roles, escalation ¹.
• Channel matrix with primary/backup channels and access rules.
• Contact tree and distribution lists with owners and review history.
• Templates and approval workflow documentation.
• Exercise records: agenda, scenario, attendance, outcomes, action items.
• Incident records (for real incidents): timeline of notifications, copies of key internal updates, approvals for external statements, and third party communication logs.
• Access control evidence for incident collaboration spaces (membership lists, admin settings snapshots).

Retention approach (practical):

• Store artifacts in a controlled repository with restricted access.
• Keep an index so you can answer “show me the last time you used this mechanism” without hunting.

Common exam/audit questions and hangups

Expect questions like:

• “Show your approved incident communication channels. What happens if email is down?”
• “Who is authorized to communicate externally during an incident?”
• “How do you ensure sensitive incident details are shared on a need-to-know basis?”
• “Show evidence from a tabletop or incident that demonstrates the mechanism was followed.”
• “How do you communicate with critical third parties during an incident? Where are the contacts and SLAs documented?”

Hangups that slow assessments:

• Contact lists exist but have no owner, no review trail, and outdated names.
• War room tooling exists but lacks documented access restrictions.
• No preserved record of communications decisions (approvals happen in hallway conversations or ad hoc calls).

Frequent implementation mistakes (and how to avoid them)

1. Relying on one tool (usually email).
   Fix: document primary and fallback channels, including an out-of-band option for compromised environments.

2. No clear spokesperson authority.
   Fix: explicitly assign external communications authority and document approval steps.

3. Confusing “plan” with “mechanism.”
   Fix: make it executable: pre-built channels, templates, distribution lists, and a defined cadence.

4. Incident channels open to broad audiences.
   Fix: pre-create restricted groups, define membership rules, and log access changes.

5. No evidence trail.
   Fix: make evidence capture part of the playbook closeout checklist for incidents and exercises.

Enforcement context and risk implications

CIS Controls v8 is a framework, not a regulator. Still, communication failures routinely amplify incident impact: delayed containment decisions, inconsistent customer statements, accidental disclosure of sensitive data, and breakdowns in third party coordination. From a governance perspective, 17.6 is a “multiplier” control: if communications fail, many other controls may appear ineffective because teams cannot coordinate and prove actions taken.

A practical 30/60/90-day execution plan

Use phased execution without pretending every environment can change at the same speed.

First 30 days (Immediate)

• Assign ownership: Security (process owner) + GRC (governance) + Legal/Comms (approvals).
• Draft the channel matrix (primary + fallback) and get explicit tool approvals.
• Build or clean up contact trees, including critical third party emergency contacts.
• Create minimum viable templates: internal update, exec brief, third party outreach.

Days 31–60 (Near-term)

• Integrate comms steps into IR runbooks and ticketing/case tooling.
• Pre-provision incident collaboration spaces with access controls.
• Define external communications approval workflow (who approves what, how fast).
• Run a tabletop that forces fallback communications and third party coordination; track action items.

Days 61–90 (Operationalize)

• Fix gaps from the tabletop (missing contacts, tool failures, unclear authority).
• Establish recurring review of contacts, templates, and channel access.
• Implement consistent evidence packaging for each exercise/incident (a standard folder structure + checklist).
• Prepare an assessor-ready narrative mapping your implementation to CIS v8 Safeguard 17.6 language ¹.

Frequently Asked Questions

Do we need separate mechanisms for internal vs. external communications?

Yes in practice, even if documented in one plan. Internal coordination can move fast under the Incident Commander, while external statements should follow a tighter approval workflow with Legal and Communications.

What if our incident response is run by an MDR or another third party?

You still need defined communication mechanisms on your side: who receives alerts, who makes business decisions, and how you coordinate with the provider. Document the touchpoints, contacts, and escalation paths with that third party.

How do we handle communication if our identity provider or email is compromised?

Define an out-of-band fallback that does not depend on the potentially impacted environment. Document how responders authenticate to it, who can invite participants, and how you restrict membership.

What evidence is most persuasive to an auditor for Safeguard 17.6?

A tested plan plus records from an exercise or real incident showing the mechanism in use: invite logs, approved messages, and a communication timeline. Pair that with documentation of approved channels and contact list maintenance.

How detailed should message templates be?

Keep them short and decision-focused. Templates should prevent accidental oversharing and speed drafting, while leaving room for incident-specific facts that have been validated.

Can we treat Slack/Teams as “approved” if it’s our normal collaboration tool?

Only if you can secure it for incident use: restricted channels, controlled membership, and clear rules for what data can be posted. Document the configuration expectations and the fallback if that platform is unavailable.

Footnotes

1. CIS Controls v8; CIS Controls Navigator v8

2. CIS Controls v8