Safeguard 17.8: Conduct Post-Incident Reviews

To meet the safeguard 17.8: conduct post-incident reviews requirement, you must run a documented “lessons learned” review after security incidents, produce corrective actions with owners and due dates, and track those actions to completion. Operationalize it by defining review triggers, a standard agenda, required outputs, and an evidence trail that auditors can follow. ¹

Key takeaways:

• Define clear triggers so post-incident reviews happen consistently, not ad hoc. ¹
• Treat the post-incident review as a control with required outputs: root cause, control gaps, and tracked remediation. ¹
• Build recurring evidence capture (templates, tickets, approvals, metrics) so you can prove the control operated. ²

Safeguard 17.8 sits in the part of the CIS Controls that expects you to improve incident response based on what actually happened, not what your plan predicted. The operational risk is simple: if you do not consistently learn from incidents, you repeat them, and you cannot demonstrate control maturity during an assessment. CIS does not frame this as a “write-up for the file.” It is an expectation that post-incident reviews are conducted and that outcomes drive concrete changes. ¹

For a Compliance Officer, CCO, or GRC lead, the fastest path to implementation is to treat post-incident reviews as a repeatable workflow with defined inputs, required outputs, and retention requirements. That means: (1) deciding which events require a review, (2) assigning facilitation and approval roles, (3) standardizing the review deliverables, (4) forcing remediation work into your ticketing/change processes, and (5) retaining evidence in a way that a third party can validate without tribal knowledge. ²

This page gives you requirement-level guidance you can hand to Security/IR, IT Ops, and application owners, then audit against next quarter.

Regulatory text

Framework requirement: “CIS Controls v8 safeguard 17.8 implementation expectation (Conduct Post-Incident Reviews).” ¹

Operator interpretation (what this means in practice): You are expected to conduct a formal review after incidents, document what happened, identify control/process gaps, and make improvements based on lessons learned. A “review” must produce actionable remediation that is tracked to closure, or it will not stand up as an operating control during assessment. ¹

Minimum outcomes an auditor will expect you to show:

• A consistent trigger for when a post-incident review is required.
• A written record of the review (not just a chat or meeting).
• Corrective/preventive actions with owners and due dates.
• Evidence those actions were completed and validated. ²

Plain-English interpretation

Post-incident reviews are your feedback loop. After an incident, you gather the right stakeholders, reconstruct the timeline, identify root causes and contributing factors (technical and procedural), and decide what changes prevent recurrence. You then implement those changes through normal engineering/IT change mechanisms, and you keep the paper trail. ¹

This requirement is easiest to fail in two ways:

1. You do reviews only after “big” incidents, with no defined threshold, so the control operates inconsistently.
2. You hold the meeting but do not drive durable remediation, so the review has no measurable effect. ²

Who it applies to

Entities: Enterprises and technology organizations adopting CIS Controls v8 as a security baseline or assessment framework. ¹

Operational context (where this control lives):

• Security Incident Response (IR) and SOC operations
• IT operations (identity, endpoint, network, cloud)
• Application and product engineering (for software/security defects)
• Third-party management (when a third party contributed to the incident)
• GRC/Compliance (for control mapping, evidence, and reporting) ²

Incidents that should trigger a post-incident review (define this explicitly): Use your incident severity model. Common triggers include confirmed security incidents, material service-impacting security events, and repeated “near misses” that exposed control weaknesses. Your policy should avoid subjective phrases like “significant incident” without a definition. ¹

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

1) Define and publish the “post-incident review required” triggers

Write a short standard that states:

• Which incident severity levels require a review
• Who can declare a review required (IR lead, CISO delegate, on-call incident commander)
• Time expectation (“as soon as practical after containment and initial recovery”) without hardcoding a number you cannot meet consistently ¹

Execution tip: Put the trigger in your incident ticket workflow so closure cannot happen until the review record exists (or an approved exception is attached). ²

2) Assign roles and decision rights

Document these roles:

• Facilitator: typically Incident Commander or IR manager; accountable for producing the write-up
• Scribe: captures timeline, decisions, and actions
• Control owners: IAM, Vulnerability Mgmt, Backup/DR, Logging/SIEM, SDLC, etc.
• Approver: security leadership or delegated authority who signs off that actions are adequate ¹

Decision point: If the incident involves a third party, require their participation or a documented attempt to obtain their RCA and mitigation plan, then record what you received and what you could not validate.

3) Standardize the post-incident review package (your required outputs)

Use a template that forces consistency. Minimum fields:

• Incident summary (what happened, impacted assets, business impact description)
• Detection method (how you found it) and missed detection opportunities
• Timeline (key events from initial compromise/symptom to containment to recovery)
• Root cause and contributing factors (include process/control failures)
• What worked (controls, playbooks, comms)
• What failed (gaps in tooling, access, processes, approvals, training)
• Corrective and preventive actions (CAPA): action, owner, due date, priority, validation method
• Risk acceptance decisions (if any) with approver and rationale
• Mapping to affected controls/policies (so GRC can update control narratives) ¹

Practical bar for “done”: The review is not complete until CAPA actions are in your system of record (ticketing, backlog, or GRC tool) with ownership and tracking.

4) Convert lessons learned into tracked remediation work

For each action item:

• Create a ticket/change record with a unique ID
• Attach the post-incident review as context
• Define acceptance criteria (what evidence proves the fix is effective)
• Link to implementation evidence (config change, code PR, test results, monitoring alert) ²

Common pattern that auditors dislike: “We will improve monitoring” as a vague action. Rewrite as measurable engineering work (new alert logic, new log source onboarded, tested runbook, paging routing updated).

5) Validate fixes and close the loop

Closure needs more than “ticket resolved.” Require:

• Verification by someone other than the implementer when feasible
• Proof the change is deployed (screenshots, change approval, CI/CD reference, config baseline output)
• Proof the change works (tabletop replay, alert test, control check, sampling) ¹

6) Feed the results back into governance

Make post-incident reviews drive updates to:

• Incident response plan and playbooks
• Security standards (logging, IAM, patching, backup)
• Training (IR, engineering, service desk)
• Risk register entries where an exposure remains and is accepted ¹

Required evidence and artifacts to retain

Retain artifacts in a way that supports both operational learning and assessment readiness:

Core evidence ¹:

• Incident record/ticket with severity classification and dates
• Post-incident review report (template output)
• Attendee list or meeting record (calendar invite, minutes)
• CAPA list with owners and due dates
• Links to remediation tickets/changes and closure evidence
• Approval/attestation that review is complete (email, ticket approval, e-sign) ²

Program-level evidence (shows the control is institutionalized):

• Written SOP/policy for post-incident reviews and triggers
• Metrics or reporting showing reviews completed and action closure status
• Exception process (when a review is waived) with documented approval ¹

Common exam/audit questions and hangups

Auditors and assessors typically probe:

1. “Show me the last few incidents and the corresponding post-incident reviews.”
   Hangup: you have reviews for major incidents only, or the “review” is a slide deck with no action tracking.

2. “How do you ensure actions are completed?”
   Hangup: no linkage between the review and your ticket/change systems, or actions have no owners.

3. “How do you decide which incidents require a review?”
   Hangup: severity criteria are undefined, subjective, or inconsistently applied.

4. “What changed as a result of these reviews?”
   Hangup: no evidence of program improvement, only narratives. ¹

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails	Fix
Treating post-incident review as optional	Control operation becomes inconsistent and unverifiable	Put triggers in the incident workflow; require approver sign-off for waivers 1
“Lessons learned” captured but not actioned	No closed-loop remediation	Convert each lesson into CAPA tickets with acceptance criteria 2
Single-person write-ups with no stakeholder review	Misses cross-functional root causes	Require attendance from impacted control owners; document dissent/constraints
Over-focusing on technical RCA only	Process gaps remain (access, change control, monitoring, training)	Include procedural/control failure sections in the template 1
Evidence scattered across tools	Hard to audit and easy to lose	Store a single review record with links to source artifacts; set retention expectations

Enforcement context and risk implications

CIS Controls v8 is a security framework, not a law in the provided source set, so “enforcement” usually shows up indirectly: customer audits, contractual security requirements, insurer questionnaires, and internal audit findings. The practical risk of weak post-incident reviews is repeat incidents, delayed detection, and inability to prove you improved controls after known failures. ¹

If you align CIS to other frameworks in your environment, post-incident review evidence often becomes the shared artifact that demonstrates “continuous improvement” and incident response maturity across multiple assessments. Keep it consistent and easy to retrieve. ²

A practical 30/60/90-day execution plan

First 30 days (stand up the workflow)

• Publish the post-incident review SOP: triggers, roles, required outputs, waiver rules. ¹
• Create the review template and a CAPA action register format (spreadsheet is acceptable if controlled).
• Update incident ticket workflow: add a required field/link for post-incident review record before closure.
• Pick a system of record for storing reviews (GRC repository, case management, or controlled document store).

By 60 days (run it on real incidents and prove tracking)

• Conduct post-incident reviews for newly closed incidents that meet your trigger criteria. ¹
• Convert all review actions into tickets with owners and acceptance criteria.
• Establish a monthly CAPA review meeting (Security + IT + Engineering) focused on overdue actions and blockers.
• Build a simple dashboard: reviews completed, actions open/closed, high-risk overdue items.

By 90 days (make it audit-ready and durable)

• Sample completed CAPA items and document validation (proof the fix works). ²
• Train incident commanders and scribes on the template and evidence expectations.
• Add a quarterly management readout: themes, systemic issues, and policy/control updates made as a result.
• If you use Daydream for GRC operations, map Safeguard 17.8 to the documented control operation and set recurring evidence capture so the audit packet is generated continuously, not assembled at the end. ²

Frequently Asked Questions

What counts as an “incident” for a post-incident review under Safeguard 17.8?

Define “incident” using your incident classification and severity model, then specify which severities require a review. Write the trigger so two different incident commanders would make the same call. ¹

Do we need a post-incident review for third-party incidents?

Yes if the incident impacted your environment, data, or service commitments, even if root cause sits with a third party. Record what you requested from the third party (RCA, mitigations) and track your own compensating actions. ¹

How formal does the post-incident review document need to be?

Formal enough that an independent reviewer can reconstruct what happened, see decisions made, and verify corrective actions were completed. A consistent template beats a long narrative. ²

Can we waive a post-incident review for low-impact events?

Yes, if your SOP includes a waiver path with documented rationale and approval. Auditors usually accept waivers when they are rare, consistent, and evidence-based. ¹

What evidence is most often missing during audits?

Closure evidence for corrective actions. Teams can usually produce the meeting notes; they struggle to prove fixes shipped, were validated, and reduced recurrence risk. ²

How do we show the control is “operating” over time?

Maintain a repeatable cadence of reviews tied to incident records, plus a CAPA tracker that shows actions aging, escalation, and closure. Keep a small set of completed examples ready to produce on request. ¹

Footnotes

1. CIS Controls v8

2. CIS Controls Navigator v8