Theme comparison · incident-response
Incident response across frameworks
Compare incident response requirements across SOC 2, ISO 27001, GDPR, and HIPAA, including control IDs, notification clocks, evidence, and SaaS playbooks.
Frameworks covered: SOC 2, ISO/IEC 27001, GDPR, HIPAA
Key differences
| Dimension | Approach A | Approach B |
|---|---|---|
| SOC 2 | CC7.3–CC7.5 address event evaluation, response, recovery, root cause, and communication consistent with commitments. | CPA testing focuses on design and, for Type II, sampled operation during the report period; law-based notification is outside SOC 2 itself. |
| ISO 27001 | A.5.24–A.5.28 cover preparation, event assessment, response, lessons learned, and collection of evidence. | The ISMS links incidents to roles, risk treatment, corrective action, competence, and continual improvement. |
| GDPR | Articles 33–34 govern personal-data breaches, records, authority notification, and affected-person communication based on risk. | Controllers face a 72-hour authority deadline where required; processors notify controllers without undue delay. |
| HIPAA | §164.308(a)(6) requires security-incident procedures, while the Breach Notification Rule governs compromise analysis and notices. | Notification is without unreasonable delay and no later than 60 days, with HHS, individual, and sometimes media channels. |
| Incident threshold | SOC 2 and ISO processes normally capture a broad universe of security events and incidents. | GDPR and HIPAA add legal definitions and harm or compromise tests; not every security alert is a reportable breach. |
| Evidence | Tickets, SIEM alerts, timelines, containment actions, approvals, postmortems, exercises, and corrective actions support assurance. | Regulatory files also need affected-data facts, legal threshold analysis, notification decisions, recipients, timing, and delay reasons. |
| Third-party handling | Vendor and cloud incidents enter shared triage through SOC 2 CC9.2 and ISO supplier controls. | Processor, subprocessor, and business-associate contracts need fast escalation so controllers and covered entities can meet their clocks. |
Control overlap
Use one incident-management backbone and branch only where frameworks require different decisions. Detection and triage records support SOC 2 CC7.2–CC7.3, ISO A.5.25–A.5.26, GDPR Article 33, and /controls/hipaa/164-308-a-6. Containment, recovery, evidence preservation, and postmortems support CC7.4–CC7.5 and ISO A.5.27–A.5.28. Keep a common timeline, severity, affected systems, data classification, indicators, actions, and owners. Add legal fields for controller/processor or covered-entity/business-associate role, discovery time, affected people, likely risk, compromise factors, authority/customer notices, and reasons for delay. A tabletop report can be reused, but notification tests must reflect each legal regime.
Sequencing advice
For SaaS, define a 24/7 reporting path and an initial legal escalation target shorter than every external deadline—often hours, not days. Integrate cloud, SIEM, support, and vendor alerts into one queue; create severity criteria and playbooks for credential theft, data exfiltration, ransomware, and subprocessor incidents. Put GDPR’s 72-hour assessment and HIPAA’s discovery rules into decision checklists, while contractual customer notices may be faster. Exercise engineering, privacy, legal, support, and executives together, including unavailable evidence and incomplete facts. After each event or tabletop, track corrective actions through closure and retain the packet for SOC 2 samples, ISO improvement, and regulatory accountability.