IR-4(6): Insider Threats

IR-4(6) requires you to run incident handling specifically for insider-threat incidents, not just generic security incidents. Operationalize it by defining insider-threat incident types, adding insider-specific triage and investigation steps, assigning cross-functional roles (HR, Legal, Security), and retaining repeatable evidence that the process runs in real cases. ¹

Key takeaways:

• IR-4(6) is an incident-handling enhancement focused on insiders, including employees, contractors, and other trusted users. ¹
• You need an insider-threat playbook, clear decision rights, and a forensically sound workflow that coordinates Security, HR, and Legal.
• Evidence matters as much as the process: tickets, timelines, approvals, chain-of-custody, and post-incident lessons learned must be retained and reviewable.

The ir-4(6): insider threats requirement is narrow on purpose: your incident response program must explicitly cover incidents where the threat actor is “inside” your trust boundary. That includes employees, privileged admins, contractors, and sometimes third parties with persistent access (for example, managed service providers). Generic IR plans often assume an external attacker and break down on insider cases because access is legitimate, motives vary (malice, coercion, negligence), and investigations carry employment and legal consequences.

For a Compliance Officer, CCO, or GRC lead, the fastest way to implement IR-4(6) is to treat it as a specialization of IR-4 (Incident Handling): build a distinct insider-threat incident category, define triggers and triage paths, and establish a cross-functional operating model that can act quickly without contaminating evidence or creating HR/legal exposure. The control text is short, but assessors typically look for concrete, repeatable execution: documented procedures, clearly assigned ownership, and artifacts showing the procedures were used.

This page gives requirement-level guidance you can implement immediately: who owns what, what to document, what to retain, what auditors ask, and how to avoid common failures.

Regulatory text

Requirement (excerpt): “Implement an incident handling capability for incidents involving insider threats.” ¹

Operator interpretation: Your incident handling program must include defined procedures, roles, and evidence-retention practices that work for insider-driven incidents. “Capability” means more than a statement in a policy. It means you can detect/receive an allegation, triage it, investigate it, contain it, coordinate sensitive actions (account suspension, device seizure, interviews), document what happened, and close the incident with lessons learned. ¹

Plain-English interpretation (what IR-4(6) is really asking)

You must be able to respond to insider-threat incidents with the same rigor as external incidents, plus insider-specific handling steps:

• Insider context changes the workflow. The subject may have legitimate access, knowledge of controls, and relationships with staff.
• HR and Legal coordination is part of incident handling. Many insider actions trigger employment actions, litigation holds, or regulatory reporting decisions.
• Evidence handling must be tight. You may need device handling, log preservation, and chain-of-custody practices that survive scrutiny.

A workable standard: if an employee is suspected of data theft, sabotage, fraud, or policy circumvention, your team should already know (1) who approves access changes, (2) how evidence is preserved, (3) how HR/Legal are engaged, and (4) where the full timeline is recorded.

Who it applies to (entity and operational context)

IR-4(6) commonly applies to:

• Federal information systems and programs assessed against NIST SP 800-53. ²
• Contractor systems handling federal data where NIST 800-53 controls are contractually required or inherited through an authorization boundary. ²

Operationally, it applies anywhere you have:

• Workforce accounts (employees, temps, interns)
• Privileged users (admins, DevOps, DBAs)
• Long-lived access for third parties (MSPs, support vendors, integrators)
• Sensitive data stores and logging that can support an investigation

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

Use the steps below as an implementation checklist. Your goal is a repeatable, auditable insider-threat incident path inside your broader incident response lifecycle. ¹

1) Define “insider threat incident” categories and entry criteria

Create a small taxonomy that drives consistent routing and evidence collection. Keep it operational, not theoretical.

Recommended incident types (examples):

• Data exfiltration or attempted exfiltration by a trusted user
• Privilege misuse (unauthorized access to systems/data)
• Sabotage (intentional system or data destruction)
• Fraud or unauthorized transactions (where applicable)
• Policy-bypass with security impact (shadow admin accounts, disabling logging)

Define triggers: DLP alerts, anomalous access patterns, hotline reports, manager escalations, SOC detections, code repo anomalies, physical security reports.

Deliverable: “Insider Threat Incident Definition & Triage Triggers” section inside your IR procedures.

2) Assign control ownership and decision rights

IR-4(6) fails most often because “Security owns incident response” is written down, but HR/Legal actions happen ad hoc.

Create a RACI that answers:

• Who declares an insider-threat incident?
• Who can suspend accounts, revoke badges, or seize devices?
• Who approves employee interviews and communications?
• Who decides when to involve law enforcement or external counsel?

Minimum roles to name:

• Incident Commander (Security/IR lead)
• HR lead (employee relations)
• Legal lead (in-house counsel or outside counsel contact path)
• IT / IAM lead (access actions)
• Forensics lead (internal or retainer)
• Communications lead (internal comms; PR if needed)

Deliverable: Insider Threat Incident RACI + escalation contacts, embedded in your IR plan.
Best-practice control mapping: map IR-4(6) to a named owner, written procedure, and recurring evidence artifacts so it is assessable. ¹

3) Build an insider-threat incident playbook (a “gold path”)

Write a playbook that your SOC/IR team can execute without improvising. Include decision points and required documentation at each step.

Playbook sections to include:

• Intake: what data to capture in the initial ticket (reporter, allegation, systems, subject identity, time window)
• Triage: severity rubric; safety considerations; immediate containment options
• Evidence preservation: what logs to preserve first; how to snapshot accounts; legal hold triggers
• Containment: account restrictions, token revocation, device isolation, email forwarding restrictions, repo access changes
• Investigation: hypotheses, queries to run, systems to review, peer review of findings
• HR/Legal workflow: when HR contacts the manager; when Legal directs evidence collection; how to avoid tipping off the subject prematurely
• Eradication and recovery: remediation steps; credential resets; permissions cleanup; monitoring plan
• Closure: lessons learned; control gaps; disciplinary outcomes tracked by HR (with privacy controls)

Deliverable: Insider Threat Playbook v1.0 attached to your IR program documentation. ¹

4) Make evidence collection forensically defensible (practical version)

You do not need to turn your team into a full forensics lab, but you do need consistent handling:

• Centralize incidents in a system of record (IR platform or ticketing system).
• Require a timeline of actions (who did what, when, and why).
• Preserve key logs relevant to the allegation (identity, endpoint, cloud admin, data access).
• Track any device handling with a simple chain-of-custody form when equipment changes hands.
• Restrict access to insider-threat case files; document who has access.

Deliverables: evidence checklist + chain-of-custody template + access controls for case files.

5) Train the humans who will execute it

Insider incidents have higher interpersonal and legal risk than many external incidents.

Minimum training topics:

• How to route insider allegations (SOC vs HR vs Legal)
• Do’s and don’ts for managers (don’t investigate independently; don’t confront the subject)
• Evidence handling basics
• Confidentiality expectations

Deliverable: training record or attestation tied to the roles in the RACI.

6) Test the workflow and fix what breaks

Run a tabletop or a structured walkthrough using an insider scenario (data theft, sabotage, privilege misuse). Capture gaps and update the playbook.

Deliverables: tabletop agenda, participant list, after-action notes, and playbook revision history.

Required evidence and artifacts to retain

Assessors typically want to see that the capability exists and is used. Build an evidence package that is easy to export.

Policy/procedure artifacts

• Incident Response Plan with insider-threat coverage (IR-4(6) mapped) ¹
• Insider Threat Incident Playbook
• Insider Threat RACI and escalation matrix
• Evidence preservation and chain-of-custody procedure (lightweight is fine)
• Case file access control procedure (who can view insider cases)

Operational artifacts

• Example insider-threat incident tickets (sanitized) showing triage, actions, and closure
• Log preservation records (what was preserved, when, by whom)
• Access change approvals (IAM tickets, emergency changes)
• Forensics engagement records (if used)
• Lessons learned / after-action reports and tracked remediations

Governance artifacts

• Training completion/attestations for IR, HR, Legal, IT roles
• Periodic review record showing the playbook is updated as systems change

Common exam/audit questions and hangups

Use these to pre-brief control owners and reduce back-and-forth.

1. “Show me where insider threats are covered in incident handling.”
   Auditors want an explicit insider section or playbook, not a verbal claim. ¹

2. “Who can disable an employee account, and what approvals are required?”
   They will test decision rights and separation of duties.

3. “How do you preserve evidence if the suspect is an admin?”
   Expect questions about privileged access, log integrity, and limiting the subject’s ability to tamper.

4. “Provide an example case.”
   A sanitized incident record with a clear timeline is often the fastest way to demonstrate capability.

5. “How do HR and Legal participate?”
   Assessors look for defined touchpoints, not informal “we call Legal if needed.”

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails	What to do instead
Treating insider incidents as standard malware/phishing cases	Insider cases often require HR/Legal controls and different containment	Maintain a distinct insider playbook and escalation path 1
No decision rights for access suspension or device seizure	Delays containment; inconsistent actions across teams	Publish a RACI with named approvers and alternates
Evidence scattered across email and chat	Weak audit trail; hard to reconstruct timelines	Use a single system of record; attach artifacts and approvals
Managers “investigate” on their own	High legal/HR risk; evidence contamination	Train managers on routing and confidentiality
Over-collecting employee data	Privacy and labor risk; scope creep	Use an evidence checklist tied to the allegation; limit access to case files

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should treat enforcement context as indirect: IR-4(6) is assessed as part of your overall incident response capability under NIST-based audits and authorizations. The practical risk is operational: insider incidents can move fast, and poorly controlled investigations can create secondary risk (data loss, service disruption, HR claims, litigation holds, or spoliation allegations). ²

Practical 30/60/90-day execution plan

No source-backed durations were provided, so treat this as a pragmatic sequencing plan, not a promise of effort.

First 30 days (Immediate foundation)

• Name the control owner for IR-4(6) and confirm HR and Legal counterparts. ¹
• Add an “Insider Threat Incidents” section to your IR procedures with definitions and triggers.
• Draft the insider-threat RACI and get written approval for decision rights (account actions, device handling).
• Create templates: insider incident ticket fields, evidence checklist, chain-of-custody form.

Days 31–60 (Operationalize and integrate)

• Publish the insider-threat playbook and run a dry-run walkthrough with SOC/IR, HR, Legal, IT/IAM.
• Confirm log sources needed for insider cases (identity, endpoint, cloud audit logs) and document how to preserve them.
• Implement case file access controls and confidentiality labels for insider investigations.
• Train managers and the SOC on routing, do’s/don’ts, and confidentiality.

Days 61–90 (Prove it works and harden)

• Run a tabletop exercise using a realistic insider scenario; record outcomes and remediation actions.
• Validate you can execute containment steps quickly (token revocation, privileged access review, repo access removal).
• Build an assessor-ready evidence pack: current playbook, RACI, training records, tabletop artifacts, sanitized case sample.
• Set a recurring review cadence for the playbook tied to major system changes and org changes.

Where Daydream fits (without adding process overhead)

If your issue is repeatable evidence, Daydream can track IR-4(6) ownership, map it to your insider-threat playbook, and produce a consistent evidence request list (tickets, tabletop records, training attestations) so audits do not become a scavenger hunt. The operational work still happens in your IR and HR systems; Daydream keeps the compliance view clean and exportable. ¹

Frequently Asked Questions

Does IR-4(6) require a standalone “Insider Threat Program”?

IR-4(6) specifically requires incident handling capability for insider-threat incidents. You can meet it by adding insider-specific procedures and coordination paths inside your incident response program. ¹

Who counts as an “insider” for incident handling purposes?

Treat anyone with trusted access as in-scope: employees, contractors, and other users with credentials or persistent access paths. Define this in your insider incident criteria so triage is consistent. ¹

What’s the minimum evidence an auditor will expect for IR-4(6)?

A documented insider-threat incident procedure or playbook, named roles/decision rights, and at least one example (sanitized) showing the process executed with a clear timeline and approvals. ¹

How do we handle privacy and employee sensitivity while keeping evidence?

Restrict access to insider case files, document a need-to-know model, and retain only artifacts tied to the allegation and investigation steps. Keep HR outcome details in HR systems, and reference them at a high level in the incident record.

What if HR refuses to be “on the hook” as a control owner?

Keep Security as the control owner, but formalize HR as a required participant with defined actions and SLAs in the RACI. Auditors look for coordination and execution, not a particular department owning the control. ¹

Can we satisfy IR-4(6) if we’ve never had an insider incident?

Yes, if you can show a working capability: approved procedures, training, and a tested tabletop or simulation record. A test artifact often substitutes for a real case when none exists. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5