Incident Reporting, Communication and Mitigation

All courses / AI Red Team / Module 6 / Chapter 21

Learning objectives

After the lesson the participant can:

• Compare the trigger that starts the clock under NIS 2 Article 23, DORA Article 19, AI Act Article 73 and GDPR Article 33, as the chapter reports them.
• Apply the three design rules for reporting clocks driven by the incident record.
• Identify the three ways AI drafting goes wrong and the controls that make sign-off more than a formality.
• Draft a containment catalogue with levels, exclusions, budgets, reversals and a stop path.

Key concepts

Four regimes, four triggers

NIS 2 runs from awareness of a significant incident, with an early warning within 24 hours and a notification within 72; DORA from classification as major; the AI Act from a causal link or its reasonable likelihood, not later than 15 days after awareness; the GDPR within 72 hours of awareness where feasible.

The record as single source

The incident record carries the classification facts, and recording a fact starts the clocks that depend on it. A clock starts on the earliest plausible trigger, each time limit names its source article or standard, and every report is attached to the record version it was based on.

Draft from the record, sign by a person

The drafter works from structured, analyst-confirmed facts; raw artefacts reach it only as quoted, labelled evidence. The tool shows each statement beside its source fact and marks unsourced ones, and a named signatory approves, edits or rejects.

Containment catalogue

A short, reviewed list of containment actions, each with autonomy level, scope limits, reversal and evidence. Irreversible actions, actions on tier-0 assets and changes to the agent's own permissions are never catalogued, and Level 4 Autonomous is not used for containment.

Rebuild rather than clean

Eradication redeploys compromised components from known-good definitions. For AI systems that means restoring model artefacts, prompts, guardrail policies and retrieval indexes at a version that predates the compromise and re-running the evaluation suite. It is complete when verified, not when executed.

Interactive exercises

Do them here and get feedback at once. Choose a card and then where it belongs, or drag it.

Teaching plan

Discussion

1. In a regulatory report an invented detail is worse than a gap. How should a drafting tool and a signatory handle what is not yet known?
2. An unconfirmed isolation is lifted after a fixed time in Hansa Mutual's catalogue. For which asset classes would you keep the isolation instead, and who should decide?
3. Why is an incomplete eradication dangerous in a way an incomplete containment is not?

Written exercise

Self-test

Choose an answer to see whether it is right, or open the answer below each question.

1. From which event does the DORA reporting clock for a major ICT-related incident start, as the chapter describes it?

   1. From classification of the incident as major
   2. From the first alert reaching the SOC queue
   3. From the final report under NIS 2 being filed
   4. From confirmation that personal data has left the entity
   Show the answer

   A. From classification of the incident as major
   The chapter states that the DORA clock starts from classification as major, so classification must be fast and recorded, while the NIS 2 clock starts from awareness.

2. What does the flag hold_before_altering_system in Hansa Mutual's configuration reflect?

   1. A works-council agreement that monitoring of the underwriting team is paused while an incident is open
   2. A DORA requirement to freeze all changes to ICT systems supporting critical functions while a major incident is being classified
   3. AI Act Article 73(6): no alteration that may affect later evaluation of the causes before the authorities are informed
   4. A GDPR requirement to keep breached personal data unchanged until the 72-hour notification has been made
   Show the answer

   C. AI Act Article 73(6): no alteration that may affect later evaluation of the causes before the authorities are informed
   The flag reflects Article 73(6) of the AI Act. For the same reason, suspending a compromised AI system preserves the model version, configuration and data.

3. What happens when HM-SEC-001 exhausts its action budget during an incident?

   1. The agent is stopped and its workload identity deleted
   2. The budget doubles automatically for the next hour
   3. Remaining actions are executed at Level 4 Autonomous
   4. Further actions fall back to Level 2 Supervised
   Show the answer

   D. Further actions fall back to Level 2 Supervised
   The catalogue caps actions per incident and per hour, and on exhaustion actions fall back to Level 2 Supervised, where a person approves each one.