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Incident Response Plan for Security Breaches Affecting Your Software

While the Cyber Resilience Act (CRA) primarily focuses on the security of products with digital elements and the manufacturer's processes for vulnerability handling, a natural extension of this is being prepared for when things go wrong. If a security breach affects your app, game, or software, having an incident response plan is crucial.

Article 14, Paragraph 3, mandates that manufacturers notify any "severe incident having an impact on the security of the product with digital elements" to authorities. A "severe incident" is defined in Article 14, Paragraph 5, as one negatively affecting the product's ability to protect data/functions or leading to malicious code execution. Having a plan helps you manage such incidents effectively and meet these reporting obligations.

Why You Need a Plan for Your Software​

Even with the best security measures, breaches can happen. An incident response plan helps you:

  • React Quickly and Effectively: Minimize damage to your users and your software.
  • Contain the Breach: Stop the bleeding and prevent further unauthorized access or data loss.
  • Eradicate the Threat: Remove the attacker or malware from your systems.
  • Recover Operations: Get your app or game's services back online safely.
  • Learn and Improve: Analyze the incident to prevent future occurrences (lessons learned).
  • Meet Reporting Obligations: Systematically gather information needed for CRA notifications (Article 14) and potentially GDPR notifications if personal data is involved.

Core Elements of a Software-Focused Plan​

Your plan, even a simple one for a small app or game studio, might include:

  1. Preparation: Identify team roles, communication channels, and essential tools.
  2. Identification: How do you detect an incident affecting your software or its backend?
  3. Containment: Steps to isolate affected systems or parts of your app.
  4. Eradication: How to remove the cause of the incident.
  5. Recovery: Procedures to restore your software's services securely.
  6. Post-Incident Analysis: What happened, why, and how to prevent it next time. This feeds back into your risk assessment and security measures.

Key Takeway​

While not explicitly detailing an "incident response plan" document, the CRA's requirement to handle and report severe incidents (Article 14) makes having such a plan essential for any software manufacturer to react effectively to security breaches affecting their products.