IR-4(15): Public Relations and Reputation Repair

IR-4(15) is a practical requirement disguised as a short sentence: “manage public relations associated with an incident.” In audits and customer diligence, this is where otherwise strong incident response programs fail, because they can show containment and forensics but cannot show disciplined external communications. Your technical response and your public narrative must match. If they diverge, you create regulatory, contractual, and litigation risk even if the underlying incident is handled well.

This requirement applies most directly to federal information systems and contractor systems handling federal data, but it is equally relevant in any environment where customers, regulators, employees, and third parties expect timely, accurate incident updates. The goal is not “good PR.” The goal is controlled, factual, role-based communication that protects investigations, preserves privilege where applicable, and avoids inconsistent statements across channels.

The fastest path to implementation is to convert this requirement into a control you can run: assign an owner (often Comms with Security and Legal), define triggers (what kinds of incidents activate the PR process), define approval and release steps, and define the evidence bundle you will retain each time the workflow is invoked.

Regulatory text

Requirement (excerpt): “Manage public relations associated with an incident; and” ¹

Operator meaning: You need a documented and repeatable method to control external communications related to incidents. “Manage” implies:

• Someone is accountable for incident-related public messaging (not just internal updates).
• Messaging is coordinated with incident response leadership (to avoid contradicting facts).
• Communications are approved before release and tracked after release.
• The organization can prove what it did, even if the incident is confidential.

This is an enhancement to incident handling (IR-4) in NIST SP 800-53 Rev. 5 ². In practice, examiners expect to see integration between your incident response plan and your communications function, plus evidence from at least one test (tabletop) or real event.

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

You satisfy ir-4(15): public relations and reputation repair requirement when you can answer, quickly and consistently:

1. Who speaks for the organization during an incident (and who is explicitly not authorized).
2. What gets communicated (and what is withheld) at each stage of an incident.
3. How facts are validated before publication (single source of truth).
4. How approvals work across Security, Legal, Privacy, and Executive leadership.
5. How you coordinate across channels (press, customer notices, status page, social media, employee comms, call center scripts, third-party comms).
6. What evidence you retain to show the process operated as designed.

Who it applies to

Entity scope (from the control’s applicability context):

• Federal information systems
• Contractor systems handling federal data ¹

Operational context (where this becomes real):

• You operate a customer-facing service where incidents may require external notification.
• You depend on third parties (cloud, MSP, SaaS, forensics, call centers) who may influence or publish incident facts.
• You have contractual notice obligations (customer contracts, DPAs) that intersect with public statements.
• You have a brand or mission where misinformation or silence creates operational harm (support overload, churn, employee confusion).

If you’re a CCO or GRC lead, your role is to make the communication workflow auditable: defined triggers, defined authorities, retained artifacts, and tested execution.

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

1) Create a control card (turn the sentence into an executable control)

Build a one-page “control card” that includes:

• Objective: Controlled external communications for incidents.
• Owner: Head of Communications (or equivalent) with Security IR lead as co-owner.
• Triggers: Severity thresholds, confirmed data exposure, ransomware/extortion, major outage with security implications, law enforcement involvement.
• Inputs: Incident timeline, known facts, impacted services, legal/privacy assessment, customer contract notice requirements.
• Steps: Draft, validate, approve, release, monitor, correct, closeout.
• Exceptions: Who can approve urgent statements, what to do if Legal is unavailable, what to do if facts are incomplete.
  This aligns with the recommended practice to “create a requirement control card with objective, owner, trigger events, execution steps, and exception rules.” ¹

2) Define your incident communications governance (RACI + approvals)

Create a RACI that covers:

• Spokesperson authority: named roles, alternates, and prohibited roles.
• Approval chain: Security IR lead validates technical facts; Legal reviews risk language; Privacy reviews personal data statements; Comms owns tone/channel; Exec sponsor approves high-impact releases.
• Single source of truth: one canonical incident summary used to generate all external artifacts (press statement, customer notice, FAQ, status page update).

Operational tip: if you can’t get Legal response quickly during an active event, pre-approve a limited “holding statement” template (see below) with clear constraints.

3) Pre-build message templates and channel playbooks

Maintain templates that can be filled from your incident summary:

• Holding statement (acknowledge investigation, commit to updates, avoid root-cause speculation)
• Customer advisory (what happened, what you’re doing, what customers should do now, how to get help)
• Status page language (service impact vs. security impact)
• Employee communication (what staff can and cannot say externally; where to route inquiries)
• Call center/support scripts
• Third-party coordination note (for key third parties that may receive inbound media questions)

The goal is speed without improvisation. Templates also reduce the risk of inconsistent claims across channels.

4) Integrate comms into the incident response workflow

Update your IR plan/runbooks so that:

• A communications lead is added to the incident bridge for qualifying incidents.
• A communications workstream is created in the incident ticket with tasks for drafting, approvals, publishing, and monitoring.
• Media/social monitoring and correction actions are tracked like other incident tasks.

This is where many programs fail: comms exists, but it is not wired into the operational muscle memory of IR.

5) Define the minimum evidence bundle (so you can pass an audit)

Write down, in your control card, the evidence you will retain per incident or exercise. This aligns with the recommended practice to “define the minimum evidence bundle for each execution cycle (inputs, approvals, output artifacts, and retention location).” ¹

Minimum evidence bundle (practical baseline):

• Incident communications log (timestamps, channel, audience, link to content)
• Drafts and final versions of public statements
• Approval records (email/thread screenshots, ticket approvals, e-sign approvals)
• The canonical “known facts” incident summary used for messaging
• Copies of status page updates and customer notices
• Evidence of monitoring and corrections (errata, follow-up statements, updated FAQs)
• Post-incident review notes specific to communications (what worked, what failed, action items)

6) Test it and track remediation to closure

Run a tabletop exercise that includes a realistic press/customer scenario and forces approvals under time pressure. Then track improvements to validated closure. This maps to the recommended practice to “run recurring control health checks and track remediation items to validated closure with due dates.” ¹

If you already run incident tabletops, add a comms inject: a reporter email, a customer escalation, a social media rumor, or a third party posting inaccurate details.

Required evidence and artifacts to retain

Keep these artifacts in a dedicated, access-controlled location with retention aligned to your incident response recordkeeping:

• Incident PR runbook and templates (version-controlled)
• Communications RACI and spokesperson authorization list
• Approval matrix and escalation rules (including after-hours)
• Completed evidence bundle per event/exercise (listed above)
• Training records for designated spokespersons and alternates
• Tabletop/exercise materials and after-action reports (comms section included)

Practical point: auditors ask for “the last one.” If you only have policy documents and no executed example, expect a finding.

Common exam/audit questions and hangups

Expect questions like:

• “Who is authorized to speak publicly about incidents, and where is that documented?”
• “Show me the workflow for approving a customer-facing statement.”
• “How do you ensure your status page does not contradict your incident report?”
• “Provide evidence from a recent incident or exercise: drafts, approvals, final release.”
• “How do you coordinate communications when a third party is involved (cloud/MSP/SaaS)?”
• “How do you correct inaccurate public information after release?”

Hangups that trigger findings:

• PR process exists only in people’s heads.
• No retained drafts/approvals (only final statements).
• No linkage to the incident ticket/timeline.
• Conflicting messages across channels with no documented correction.

Frequent implementation mistakes (and how to avoid them)

1. Mistake: Treating PR as a brand exercise instead of an incident control.
   Fix: Put comms tasks in the incident ticketing workflow, with approvals and timestamps.

2. Mistake: No “single source of truth” for facts.
   Fix: Require that every external statement references the same approved incident summary.

3. Mistake: Legal review becomes a bottleneck, so teams bypass it.
   Fix: Pre-approve holding statements and define escalation rules for urgent releases.

4. Mistake: Ignoring employee communications.
   Fix: Add an internal memo template that tells employees where to route inquiries and what not to say.

5. Mistake: No evidence bundle discipline.
   Fix: Define the evidence bundle up front and make it a closure requirement in the incident runbook.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not cite specific actions or outcomes. The risk is still operationally concrete: inconsistent or inaccurate public statements can drive contractual disputes, regulator scrutiny, litigation exposure, and loss of customer trust. Treat communications as a controlled activity in the same way you treat containment and recovery ².

Practical execution plan (30/60/90-day)

You asked for speed. Use this as a deployment cadence, then roll into steady-state operations.

First 30 days (stand up the control)

• Assign an executive sponsor and a named control owner (Comms) plus IR co-owner (Security).
• Publish the incident communications control card (objective, triggers, steps, exceptions).
• Create the RACI and approval matrix (include after-hours coverage).
• Draft minimum viable templates: holding statement, customer advisory, employee memo, status page update, support script.
• Define the evidence bundle and where it will be stored.

Days 31–60 (wire it into operations)

• Update IR runbooks so comms is automatically pulled in for trigger events.
• Add an “External Communications” workstream to your incident ticket template.
• Train spokespersons and alternates; rehearse the approval workflow.
• Align with third-party management: document how you coordinate statements when a third party is involved.

Days 61–90 (prove it works and close gaps)

• Run a tabletop that forces public messaging under pressure.
• Produce an after-action report with corrective actions.
• Track corrective actions to closure and update templates/runbooks.
• Prepare an audit-ready package: last tabletop evidence + current runbook + RACI + templates.

How Daydream fits (practical, not theoretical)

Teams struggle to show ownership, cadence, and evidence for this requirement ¹. Daydream helps by turning IR-4(15) into an operator-ready control record: a control card, an evidence checklist per incident/exercise, and a lightweight health-check workflow so you can produce audit-ready artifacts without rebuilding them during an exam.

Frequently Asked Questions

Do we need to publish a press release for every incident to satisfy IR-4(15)?

No. The requirement is to manage public relations associated with an incident, which often means having a controlled process even when you decide not to publish. You should document the decision, who approved it, and what channels (if any) were used. ¹

Who should own this control: Security or Communications?

Communications should typically own external messaging execution, while Security owns technical fact validation and incident classification. Document co-ownership and the approval workflow so audits don’t find a gap between teams. ²

What if Legal cannot review in time during an active incident?

Pre-approve a constrained holding statement and define escalation rules for urgent releases. Keep evidence of when Legal review occurred and what changes were made after initial publication.

How do we handle incidents caused by a third party (cloud, MSP, SaaS)?

Add a third-party coordination step: who contacts the third party, how you reconcile facts, and who controls your outbound statements. Retain the third party’s written inputs as part of the evidence bundle.

What evidence do auditors usually ask for first?

They usually start with the most recent real incident or tabletop: drafts, approvals, the final statement, and a timeline that shows you controlled updates across channels. If you can’t show an executed example, expect deeper sampling.

Can our status page updates satisfy the requirement by themselves?

Sometimes status updates are part of the evidence, but they rarely cover media inquiries, customer escalations, or employee guidance. Treat the status page as one channel within a broader incident communications workflow.

Footnotes

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

2. NIST SP 800-53 Rev. 5