IR-2(3): Breach

IR-2(3): Breach requires you to train your workforce to recognize a breach, take the right first-response actions, and follow your organization’s breach reporting process. To operationalize it quickly, define “breach” for your environment, build role-based training with a reporting decision tree, run a simple tabletop, and retain completion and effectiveness evidence. ¹

Key takeaways:

• Train people on breach identification, immediate response, and your internal breach reporting path. ¹
• Make reporting operational: clear triggers, channels, contacts, time expectations, and escalation rules. ¹
• Keep assessor-ready evidence: training content, attendance/completions, exercises, and updates tied to incidents and lessons learned. ¹

The ir-2(3): breach requirement is not asking for another generic security awareness module. It is a narrow, operational control enhancement: you must teach your people how to spot a breach and how to report it through your organization’s defined process. That means your training has to reflect how breaches actually surface in your environment (alerts, user reports, third-party notifications, lost devices, misdirected data, unusual admin activity) and what the first responder should do in the first minutes after discovery.

For a CCO, GRC lead, or incident response owner, the fastest path is to treat IR-2(3) as an “outcome control.” The outcome is predictable human behavior: prompt internal reporting, correct triage, and reduced evidence spoliation. You will be assessed on whether the training exists, is delivered to the right roles, covers reporting procedures, and is repeatable with retained artifacts.

If you operate federal information systems or contractor systems handling federal data, IR-2(3) also becomes a readiness control: during an assessment, lack of training content or proof of completion is a common, easily avoidable gap. ²

Regulatory text

Requirement (verbatim): “Provide incident response training on how to identify and respond to a breach, including the organization’s process for reporting a breach.” ¹

Operator interpretation: You need a documented, delivered training component within your incident response training program that covers:

1. how personnel identify a breach in practice,
2. what actions they must take immediately after identifying/suspecting a breach, and
3. the exact internal process for reporting it (who, how, what information, and escalation). ¹

This is not satisfied by a policy PDF alone. Assessors typically expect training materials and objective evidence that the training was completed and maintained.

Plain-English interpretation (what “good” looks like)

A trained employee can answer, without guessing:

• “What counts as a breach here?”
• “What do I do first to avoid making it worse?”
• “How do I report it right now, and what details do I include?”
• “How do I escalate if the normal channel is unavailable?”

A trained responder (SOC, IT, incident commander, privacy/legal liaison) can also execute role-specific tasks: preserve logs, isolate endpoints, maintain chain-of-custody for evidence, and route notifications through the correct internal governance path.

Who it applies to

Entities: Federal information systems and contractor systems handling federal data. ²

Operational context: Any environment where an incident may rise to a “breach” (confirmed or suspected unauthorized access, use, or disclosure) and where internal reporting triggers downstream actions (containment, legal review, customer/agency notifications, third-party coordination, and communications).

Roles in scope (typical):

• All workforce members (baseline breach identification + reporting)
• IT service desk / helpdesk (intake, triage, ticket classification)
• Security operations / IR team (technical response steps)
• Application owners / data owners (business impact inputs)
• Legal/privacy and communications (internal escalation path and approvals)
• Third-party management (coordination when a third party reports a breach or is involved)

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

1) Name a control owner and define the training boundary

• Assign ownership to the incident response program owner (often Security/IR) with GRC support for evidence management.
• Define which populations must complete the training (employees, contractors, privileged users, and in-scope third parties where you can enforce training).

Deliverable: IR-2(3) control statement with owner, scope, and training cadence expectation.
Tip: Daydream can track control ownership, map training artifacts to IR-2(3), and keep recurring evidence organized for audits.

2) Define “breach” for your environment and translate it into triggers

Write a one-page “Breach recognition” handout that includes:

• High-signal examples: suspicious mailbox rules, mass downloads, lost devices with sensitive data, misdirected sensitive emails, exposed storage, third-party notification of compromise.
• “If you see X, do Y” triggers tied to your tooling (ticketing, hotline, SOC channel).

Deliverable: Breach indicators + triggers sheet aligned to your incident taxonomy.

3) Document the reporting process as an executable workflow (not prose)

Build a simple reporting workflow your workforce can follow under stress:

• Primary reporting channel (e.g., “report in ServiceNow category ‘Suspected Breach’”)
• Backup channel (phone number, dedicated email, on-call pager)
• Required fields (who, what, when, system, data type, screenshots, affected third party)
• Escalation criteria (confirmed sensitive data exposure, admin credential compromise, active ransomware, third-party involvement)

Deliverable: “Breach reporting runbook” and a one-screen decision tree.

4) Create role-based training modules

Minimum recommended modules:

• General workforce (short): recognize, report, preserve (do not delete evidence, do not “test” by clicking again, do not contact attacker).
• Managers: how to support reporting, avoid interference, route media/customer inquiries.
• Technical responders: containment do’s/don’ts, evidence preservation, communication protocols.
• Third-party managers: how to intake a third-party breach notice and route it internally.

Deliverable: Slide deck or LMS module plus a short knowledge check.

5) Run an exercise that tests reporting behavior

Choose a scenario that forces people to use the reporting process:

• Example: third party sends an email: “We detected unauthorized access to your tenant.” Who gets it? How is it escalated? What is logged?
• Example: employee reports misdirected sensitive attachment.

Deliverable: Tabletop agenda, participant list, and after-action notes tied to training updates.

6) Close the loop with updates and retraining triggers

Set explicit triggers to update training content:

• New reporting channels or on-call rotation changes
• Lessons learned from real incidents
• Major system or data flow changes that alter breach indicators

Deliverable: Training change log with dates and rationale.

Required evidence and artifacts to retain (assessor-ready)

Maintain a tight evidence set that proves design and operation:

Design evidence

• IR training policy/standard referencing breach identification and reporting process ¹
• Breach reporting workflow/runbook (current version)
• Training materials (slides/LMS module scripts), including breach examples and reporting steps ¹
• Role-to-training matrix (who takes what)

Operating evidence

• LMS completion reports or signed attendance logs
• New hire onboarding assignment records (if applicable)
• Knowledge check results or attestations
• Tabletop/exercise records: agenda, roster, outputs, corrective actions
• Evidence retention map: where artifacts live, who can retrieve them quickly (this is where Daydream helps in practice)

Common exam/audit questions and hangups

Expect questions like:

• “Show me the training content that covers breach reporting, not just incident response broadly.” ¹
• “Who is required to take this training, and how do you ensure coverage for contractors or privileged users?”
• “How do you know the reporting process works outside normal business hours?”
• “Show me the last time you updated training based on a real breach or exercise.”
• “Where is the evidence? Can you pull completion and materials within the audit window?”

Hangups that slow teams down:

• Reporting process exists only in an IR plan that staff never read.
• Multiple reporting channels with no single “front door,” causing missed escalation.

Frequent implementation mistakes (and how to avoid them)

1. Mistake: Generic awareness training that never mentions your reporting workflow.
   Fix: Put the decision tree and reporting channels into the training, and test them in an exercise. ¹

2. Mistake: No role-based depth for frontline intake teams.
   Fix: Train service desk and managers on intake quality (minimum details) and escalation rules.

3. Mistake: Evidence is scattered across email, LMS, and shared drives.
   Fix: Centralize artifacts by control requirement and keep a retrieval checklist. Daydream is a practical fit when you want that mapping and recurring evidence to be consistent.

4. Mistake: Training is “one and done.”
   Fix: Tie updates to process changes and lessons learned. Keep a change log so you can show why content evolved.

Enforcement context and risk implications

No public enforcement cases were provided in the source data for this requirement, so don’t frame IR-2(3) as a “fine-avoidance” control based on specific case law. Treat it as an operational readiness requirement under NIST SP 800-53: weak breach identification and reporting increases dwell time, delays containment, and can lead to incomplete fact patterns for downstream notification obligations under other regimes. ²

Practical 30/60/90-day execution plan

First 30 days (stand up the minimum viable program)

• Assign control owner and approvers (IR, GRC, Legal/Privacy as needed).
• Write the breach recognition handout and reporting decision tree.
• Publish a single “report a suspected breach” intake path plus a backup channel.
• Build baseline training content for all staff and a separate module for intake/IR roles.
• Set up an evidence folder structure aligned to IR-2(3) so retrieval is predictable.

Next 60 days (prove it works under stress)

• Deliver training to priority populations: SOC/IR, service desk, IT admins, and managers.
• Run a tabletop that forces use of the reporting workflow.
• Fix friction: unclear on-call routing, missing ticket fields, slow escalations.
• Start recurring reporting to leadership: completion status and exercise findings.

By 90 days (make it durable and auditable)

• Expand training assignment coverage to the broader workforce and relevant contractors.
• Add knowledge checks and minimum intake quality criteria.
• Formalize retraining/update triggers and maintain a change log.
• Conduct a mini audit: can you produce training content, completion evidence, and exercise artifacts quickly on request?

Frequently Asked Questions

Does IR-2(3) require training the entire company or just the incident response team?

The requirement calls for “incident response training” focused on identifying and responding to a breach, including reporting. In practice, you should train all personnel on recognition and reporting, then provide deeper role-based training for responders and intake teams. ¹

What counts as a “breach” for purposes of this training?

NIST SP 800-53 doesn’t provide a single universal definition in the excerpt you’re implementing here, so define it for your environment in plain language and align it to your incident taxonomy. Make the definition actionable by listing examples and triggers. ¹

Can we satisfy IR-2(3) with a policy and an annual acknowledgment?

Acknowledgments help, but IR-2(3) specifically requires training on identification, response, and the reporting process. Auditors typically expect training content plus proof of completion, not only policy distribution. ¹

How do we handle breach reporting training for third parties?

If third parties operate your systems or handle federal data with you, include reporting obligations in contracts and onboarding, and provide a clear route for them to notify your organization. Where you can’t enforce your internal training, document an alternate mechanism (contractual notice + required points of contact).

What evidence is most persuasive in an assessment?

Current training materials that show reporting steps, LMS/attendance completion evidence for in-scope roles, and an exercise record that demonstrates the reporting process works in practice. Keep a change log showing updates after incidents or process changes. ¹

We have multiple reporting paths (helpdesk, SOC email, hotline). Is that a problem?

Multiple paths are fine if staff are trained on a primary “front door,” backups are documented, and triage/escalation rules prevent parallel, conflicting responses. Your training should explain exactly which channel to use in common scenarios.

Footnotes

1. NIST SP 800-53 Rev. 5 OSCAL JSON

2. NIST SP 800-53 Rev. 5