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Outage / resilienceIntermediateExecutive 1 h 30 min
At 07:15 on a Tuesday, your EU payment institution loses its core transaction database after a fault at the cloud provider that hosts it. Card authorisations are failing for about 40% of merchants across four member states. The provider's status page says 'degraded performance' and gives no estimate. By 09:00 your service desk has logged 2,300 merchant complaints. Your head of compliance asks the question nobody has answered yet: is this a major ICT-related incident under DORA, and if so, when did the clock start? The CEO wants to know what goes to the regulator, and when.
It is 07:40. Overnight your SOC confirmed that an intruder has had access to the customer database for at least nine days. Containment is under way but not finished. The chair has heard a rumour from another director and wants a call with the full board at 18:00 today. You do not yet know how many records were taken, whether the attacker is still inside, or whether a regulatory clock has started. You have ten hours to decide what the board needs to hear, who says it, and what you will refuse to guess at.
You signed the agreement to buy a regional medical-billing company three weeks ago. Closing is in five weeks, pending regulatory approval. This morning the target's CEO calls: ransomware hit them overnight and patient billing records may have been taken. Your security team wants to send people in to help. Your lawyers warn that you cannot run the target's business before close. The agreement has a material adverse effect clause, and your board meets in four days. What do you do, and what are you allowed to do?
A misconfigured analytics export at your online learning company exposed records for 640,000 students and staff in the EU, the UK, the United States, Canada and Australia. Fields include names, email addresses, dates of birth and, for 12,000 US users, partial payment data. You confirmed the exposure at 09:00 today. Each jurisdiction has different triggers, deadlines and regulators, and some of your customers are universities that are controllers in their own right. Counsel wants a single notification plan by end of day.
A security researcher posted on social media that your insurance comparison site had left a storage bucket of 80,000 quote applications open to the internet. You closed it within an hour and decided, after a quick assessment, that it did not need to be notified. Eleven days later a letter arrives from the data protection authority. It asks when you became aware, who accessed the data, why you did not notify, and for a copy of your breach register entry. Replies are due in 14 days. Your breach register entry is two lines long.