A breach workflow with a clock — not a Slack channel.
Detection, triage and notification under §8(6). A 72-hour clock, a Board notification template and a data-principal notification with evidence.
For CISOs, DPOs and incident response leads accountable when the clock starts.
A breach mishandled is worse than the breach itself.
Missed notification windows, unclear scope and inconsistent communications turn a technical incident into a public failure and a regulatory finding.
DPDP §8(6) requires the Data Fiduciary to intimate the Board and each affected data principal of a personal data breach in the form and manner prescribed.
Response cannot be improvised at 2am.
The clock starts on detection. The Board template must be ready. The data-principal notification must be ready. The scope must cite real inventory records.
- 72-hour clock on detection with escalation.
- Scope cites systems, applications and vendors from the inventory.
- Board notification template pre-approved by legal.
- Data-principal notification per affected cohort.
- Remediation tasks with named owners and closure evidence.
Detect, triage, notify, remediate, close.
One workflow across incident types, with the clock and templates pre-agreed.
- 01DetectIncident opened; clock starts; scope drafted against the inventory.
- 02TriageSeverity assigned; legal, DPO and IR lead notified.
- 03Notify BoardBoard notification issued under §8(6) with template pack.
- 04Notify PrincipalsData-principal notification per affected cohort with contact evidence.
- 05RemediateTasks assigned to owners with closure evidence.
- 06ClosePost-incident report with lessons and control changes.
A file the Board can review and the regulator can request.
Every step timestamped. Every notification with evidence. Every remediation task with closure.
- Incident timeline with clock
- Scope report citing inventory records
- Board notification (§8(6))
- Data-principal notification per cohort
- Remediation register with closure evidence
- Post-incident review report
The programme's worst day, handled to plan.
No improvisation. No missed windows. The response is the plan you rehearsed.
- Grounded in
- DPDP §8(6)
- Clock
- 72 hours
- Templates
- Board · Principal
