Incident Response Testing: An Australian Perspective

In today's rapidly evolving digital landscape, organizations must be prepared for the inevitable occurrence of cybersecurity incidents. Incident response testing is a critical component of a robust cybersecurity strategy, ensuring an organization can swiftly and effectively respond to incidents when they occur.

This article highlights the importance of incident response testing, outlining its key components, who should be involved, the benefits to organizations, and the complex regulatory landscape in Australia.

Like many nations, Australia has a myriad of federal, state, and local laws that may impact an organization's requirement for maintaining and testing an incident response plan. While some organizations may have a legal responsibility, others may have a compliance requirement for incident response exercises. We will address this landscape in more detail further down in this article, but first, let’s take a look at why testing incident response is important for any organization.

The Importance of Incident Response Testing

Incident response exercises, focus on testing an organization's response to simulated cybersecurity incidents. These exercises involve key personnel discussing and walking through their roles and decisions during a hypothetical scenario, aiming to evaluate and improve the organization's incident response plans and communication strategies. In contrast, penetration testing involves ethical hackers attempting to exploit vulnerabilities within the organization's systems, networks, or applications to identify and remediate security weaknesses before malicious actors can exploit them. While tabletop exercises are more about preparedness and process evaluation, penetration testing directly assesses the technical security posture of an organization.

Assessing the Effectiveness of the Incident Response Plan

One method for testing the effectiveness of your incident response plan is using tabletop exercises. These are a great way to prepare your team to respond swiftly and effectively to cyber incidents. By simulating different attack vectors and scenarios, staff can identify gaps in your response plan and improve coordination among different departments. This preparedness is crucial to minimize the impact of actual cyber incidents, helping your organization maintain critical services, protect sensitive data, and swiftly recover.

Tabletop exercises can uncover important response issues that include:

• Updating procedures: Reflecting changes in the organizational structure, technology, or regulatory requirements.
• Training staff: Ensuring all team members are familiar with the plan and their specific roles.
• Incorporating lessons learned: Applying insights from past incidents and exercises to improve the plan.

Evaluate the Response Capabilities of the Incident Response Team

Simply conducting an incident response test is not sufficient. To ensure an incident response team is fully prepared, you should evaluate the results:

• Role Clarity: Confirm that every team member understands their specific roles and responsibilities and the steps they need to take during an incident.
• Plan Execution: Assess the team's ability to follow the incident response plan accurately and efficiently, ensuring all protocols are followed.
• Performance Under Stress: Put the team under simulated pressure to gauge their performance and identify weaknesses in decision-making or execution.
• Self-Evaluation and Feedback: Collect feedback from team members to understand their challenges and refine the response plan based on their experiences.

Identify Gaps in Resources and Training

Incident response testing reveals areas where your organization may lack the necessary tools or knowledge. Regular testing helps identify:

• Resource Shortfalls: Identify if there are any missing tools, software, or hardware that hinder the incident response process.
• Skill Gaps: Determine if team members require additional training or certifications to handle incidents more effectively.
• Process Inefficiencies: Uncover any procedural inefficiencies that could slow down the response, such as unclear protocols or outdated technologies.
• Training Programs: Develop targeted training programs to address identified gaps, ensuring the team is better prepared for future incidents.

Enhance Communication and Coordination

Effective incident response relies on seamless communication and coordination across the organization. Testing helps with functions like interdepartmental coordination. Testing ensures different departments, such as IT, legal, and public relations, can work together smoothly during an incident. External communication is also improved through testing, and it’s important to include communication protocols with external parties, including customers, partners, and regulatory bodies, to ensure clarity and timeliness.

Incident response testing helps refine internal crisis communication strategies to keep all employees informed and reduce panic or misinformation during an incident.

Finally, testing will validate the organization’s chain of command is respected and the decision-making processes are clear and efficient, minimizing delays in response actions. Similarly, escalation and communication decision points can be assessed and tested.

Who Should Be Involved

It's a widespread misunderstanding that incident response is the sole responsibility of IT and security teams. In reality, effective incident response testing necessitates the participation of a diverse range of stakeholders across the organization, including:

• Executive leadership: To ensure top-level support and decision-making.
• IT and cybersecurity teams: To manage the technical aspects of the response.
• Privacy Representatives: To manage compliance with privacy laws and regulations and to facilitate accurate and timely reporting of data breaches.
• Legal and compliance teams: To navigate legal obligations and reporting requirements.
• Public relations and communications: To handle internal and external communications.
• HR and employee representatives: To address any personnel-related issues.

Tailoring Scenarios to Organizational Processes and Infrastructure

Organizations should tailor scenarios used in incident response testing its unique processes and infrastructure. This approach ensures that the testing is realistic and relevant, addressing the organization's specific threats and vulnerabilities. Custom scenarios help to:

• Identify unique risks: Highlighting specific threats that the organization is most likely to encounter.
• Test real-world response: Ensuring the team can effectively handle incidents that could realistically occur.
• Enhance readiness: Preparing the organization for actual incidents, leading to more effective and confident responses.

Why Incident Response Testing is Necessary: The Regulatory and Compliance Landscape in Australia

Australia has a robust regulatory framework that can require certain types of organizations to conduct incident response training or to report data breaches.

Key regulations, controls, standards, and recommendations relating to incident response include:

• The Privacy Act (Cth) 1988: Requires some organizations to protect personal information and report data breaches that are likely to result in serious harm.
• The Federal Notifiable Data Breaches (NDB) scheme: Part of the Privacy Act, mandates that some organizations must notify affected individuals and the Office of the Australian Information Commissioner (OAIC) in the event of an eligible data breach.
• Security of Critical Infrastructure Act 2018 (SOCI Act): Regulated entities under the SOCI Act may be required to report cyber incidents to the Australian Cyber Security Centre (ACSC). For assets declared as Systems of National Significance (SoNS), there are Enhanced Cyber Security Obligations (ECSO) that are relevant to incident response. These additional obligations that may apply to a SoNS include obligations to:
  - Develop Cyber Security Incident Response Plans: Develop and maintain a cyber security incident response plan for potential cyber security incidents.
  - Undertake Cyber Security Exercises: Conduct regular cyber security exercises to build and enhance preparedness for cyber incidents. These exercises help identify weaknesses and improve the overall effectiveness of the incident response plans.