Incident Response Plan: Data Breach

Here are the key takeaways from this blog:

• Know the Regulatory Definitions and Deadlines — NCUA and FDIC have strict criteria and timelines (72 and 36 hours) for reporting breaches. Understanding these definitions is critical to ensure timely, compliant responses when an incident occurs.
  
  
• Prevention Starts with the Basics Most breaches exploit avoidable weaknesses—like misconfigurations, social engineering, or third-party access. Strong encryption, employee training, and vendor oversight are foundational defenses.
  
  
• A Structured IR Process Saves Time and Reputation — use a clear, repeatable response process (Detect → Analyze → Contain → Eradicate → Recover → Post-Incident) to reduce chaos during a breach. Tools like Rivial can help standardize and accelerate this process.
  
  
• Why folks choose Rivials Platform — our platform turns incident response from a chaotic scramble into a coordinated, strategic process. We support credit unions and banks in building IRPs tailored for PII breaches—aligning with GLBA, GDPR, and evolving state regulations.

Resilient Incident Response Plan

Download Rivial's Free Incident Response Template

The question isn’t if—it’s when.

In 2024, the average cost of a data breach in the financial sector hit $5.9 million (IBM Cost of a Data Breach Report). But beyond financial penalties, the true impact lies in fractured trust and disrupted operations—risks no institution can afford to ignore.

For IT, cybersecurity, and compliance leaders, preparedness is non-negotiable. A well-tested Incident Response Plan (IRP) is essential for defending against a PII data breach and responding decisively when—not if—a breach occurs.

This guide explains what a data breach is, explores common threat vectors, shares real-world lessons, and outlines critical Incident Response Steps to enhance your IRP.

What Constitutes a Breach According to NCUA and FDIC

Understanding regulatory definitions is essential for aligning your Incident Response Plan (IRP) with compliance obligations. Both the National Credit Union Administration (NCUA) and the Federal Deposit Insurance Corporation (FDIC) have specific criteria for what constitutes a reportable breach.

NCUA: Reportable Cyber Incidents

As of September 1, 2023, the NCUA mandates that federally insured credit unions report certain cyber incidents within 72 hours of forming a reasonable belief that such an incident has occurred. A reportable cyber incident is defined as one that results in:

• A substantial loss of confidentiality, integrity, or availability of a network or member information system due to unauthorized access or exposure of sensitive data.​
  
  
• Disruption of vital member services or business operations resulting from a cyberattack or exploitation of vulnerabilities.​
  
  
• Unauthorized access to sensitive data facilitated through, or caused by, a compromise of a credit union service organization, cloud service provider, or other third-party data hosting provider, including supply chain compromises.
  
  
• Examples include ransomware attacks impacting critical systems, unauthorized access to systems containing substantial member information, and data breaches exposing significant amounts of employee personally identifiable information (PII).​
  
  

FDIC: Computer-Security Incident Notification

Effective May 1, 2022, the FDIC, along with other federal banking agencies, requires banking organizations to notify their primary federal regulator within 36 hours of determining that a computer security incident has occurred. 

A "notification incident" is defined as a computer security incident that has materially disrupted or degraded, or is reasonably likely to materially disrupt or degrade:

• The banking organization's ability to carry out banking operations, activities, or processes, or deliver banking products and services to a material portion of its customer base.​
  
  
• Business lines, including associated operations, services, functions, and support, the failure of which would result in a material loss of revenue, profit, or franchise value.​
  
  
• Operations, including associated services, functions, and support, the failure or discontinuance of which would pose a threat to the financial stability of the United States.

How To Prevent PII Data Breaches:

• Data Minimization & Encryption: Store only what’s necessary and encrypt sensitive data both in transit and at rest. End-to-end encryption helps limit the impact of an exposure.
  
  
• Employee Awareness: Social engineering and phishing remain the top entry points. Regular training programs that simulate real-world attacks help staff recognize and report suspicious activity.
  
  
• Vendor Risk Management: Many breaches originate from third-party services. Continuously evaluate and audit vendors, and enforce least privilege principles on shared access.

Real-world Examples of Data Breaches:

First American Financial Data Leak 

A misconfigured web application led to the exposure of over 885 million records, including bank account numbers, mortgage records, and Social Security numbers – Krebs on Security

The incident highlighted how even non-malicious misconfigurations can have wide-reaching consequences for financial institutions.

Capital One Data Breach 

In 2019, a former employee of a cloud service provider accessed personal information of 106 million customers – The New York Times

The breach, caused by a firewall misconfiguration, exposed credit scores, balances, and transaction data, and led to regulatory scrutiny and lawsuits.

Desjardins Group Internal Breach 

A malicious insider at a Canadian credit union stole personal data of nearly 9.7 million individuals – CBC News

This case underscores the importance of strong internal controls and employee monitoring in financial institutions.

Incident Response Steps for Data Breach 

When a breach occurs, your ability to act quickly and in compliance hinges on a defined and practiced IRP. Below are essential Incident Response Steps, based on NIST SP 800-61:

1. Detect
   
   1. Alert Cybersecurity Incident Response Team (CSIRT)
   2. Trigger predefined data breach detection workflows
   3. Verify breach indicators using monitoring systems and data loss prevention tools
   4. Confirm the data type exposed and potential volume (especially PII)
2. Analyze
   1. Examine access logs, firewall alerts, and endpoint activity
   2. Identify entry points, compromised credentials, and lateral movement
   3. Assess regulatory implications (e.g., GLBA, GDPR, state laws)
   4. Work with legal to determine reporting thresholds and timelines
   5. Report to the appropriate regulatory authority (e.g., FDIC or NCUA) if required
3. Contain
   1. Isolate impacted systems or user accounts
   2. Suspend access for compromised credentials
   3. Implement network segmentation or temporary service shutdowns if needed
   4. Secure exposed data repositories
4. Eradicate
   1. Remove unauthorized users, malware, or rogue processes
   2. Patch vulnerabilities and misconfiguration
   3. Revoke and reissue credentials
   4. Validate systems are free of lingering threats
5. Recover
   1. Restore data and services from clean backups
   2. Re-enable systems in a staged manner
   3. Inform affected individuals and regulators where required
   4. Monitor systems for signs of re-entry or delayed malware triggers
6. Post-Incident
   1. Conduct a full root cause analysis
   2. Update your Incident Response Plan and employee training
   3. Adjust your security architecture and data governance strategies

Financial institutions must be prepared not only to respond quickly but to do so in a manner that aligns with regulatory and reputational considerations. Check out our other IR playbooks:

• Incident Response Playbook: Ransomeware
• Incident Response Playbook: Business Email Compromise (BEC)

Simplifying Incident Response with Rivial  

When a breach strikes, speed and precision are everything. Rivials' platform empowers financial institutions to respond faster and smarter by streamlining incident response with pre-built, compliance-ready workflows, ensuring seamless coordination across IT, security, and legal teams.

We support credit unions and banks in building IRPs tailored for PII breaches—aligning with GLBA, GDPR, and evolving state regulations.

Schedule a demo to see how you can turn incident response from a scramble into a structured, strategic process.

Resilient Incident Response Plan

Download Rivial's Free Incident Response Template