Phase 1: Detection and Initial Assessment
Effective breach response begins with detection capabilities that identify incidents promptly. Many breaches remain undetected for extended periods, with studies indicating average discovery times exceeding 200 days for sophisticated attacks. This detection gap not only increases harm but complicates notification compliance under DPDPA.
Detection mechanisms should span technical and human elements. Security monitoring tools can identify anomalous network activity, unusual data access patterns, or system compromises. Employee reporting channels allow staff to flag suspicious activities or potential incidents. Customer complaints sometimes provide the first indication of data exposure. Vendor notifications may alert organisations to supply chain incidents affecting their data.
Initial assessment determines whether a detected event constitutes a personal data breach requiring further response. Not every security incident involves personal data, and not every personal data incident constitutes a notifiable breach. The initial assessment establishes facts necessary for these determinations: what data was involved, how many individuals affected, what circumstances caused the incident, and what immediate containment measures are needed.
Key Points
- Average breach detection time exceeds 200 days without proper monitoring
- Detection requires both technical monitoring and human reporting channels
- Initial assessment determines whether incident constitutes notifiable breach
Practical Note
Establish clear escalation criteria so that personnel who detect potential incidents know exactly when and to whom to report. Delayed internal escalation often causes more harm than the original incident.