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Compliance Compared SMB1001 Cyber Security Framework

Written by Nick Kropp | Aug 21, 2025

In an era where cyber threats are rampant, having a robust Incident Response Plan is non-negotiable for financial services firms. Learn how to build a plan that ensures swift detection, containment, and recovery from cyber incidents.

Why Every Financial Services Firm Needs an Incident Response Plan

In the financial services sector, the stakes are incredibly high when it comes to cybersecurity. Without a well-structured Incident Response Plan (IRP), firms are exposed to severe risks including operational disruption, reputational damage, and financial losses. A robust IRP ensures that your team can act quickly to contain threats, protect client data, and comply with regulatory requirements.

The absence of an IRP can lead to chaos during a cyber incident, resulting in delayed responses, increased damage, and a loss of client trust. Regulatory bodies such as ASIC, APRA, and OAIC expect financial services firms to be incident-ready, and failing to meet these expectations can result in severe penalties.

Key Components of an Effective Incident Response Plan

An effective Incident Response Plan should include several key components to ensure that your business can swiftly and efficiently handle cyber threats. These components include:

1. **Preparation**: This involves creating and training an incident response team, establishing communication protocols, and setting up detection mechanisms.

2. **Identification**: The ability to detect and correctly identify a cyber incident is crucial. This includes monitoring systems and recognising signs of a breach.

3. **Containment**: Once an incident is identified, it must be contained to prevent further damage. This involves isolating affected systems and implementing short-term fixes.

4. **Eradication**: This step involves removing the threat from your systems. It may include deleting malicious files, shutting down compromised accounts, and patching vulnerabilities.

5. **Recovery**: Bringing affected systems back online in a controlled manner is essential to resume normal operations. This includes restoring data from backups and ensuring that systems are secure.

6. **Lessons Learned**: Conducting a post-incident review to understand what went wrong and how to improve your response plan for future incidents.

Regulatory Compliance and Incident Response

Financial services firms operate under stringent regulatory frameworks that mandate specific cybersecurity measures. Regulatory bodies such as ASIC, APRA, and OAIC require firms to have an Incident Response Plan in place. This ensures that businesses can quickly respond to and recover from cyber incidents, thereby protecting client data and maintaining trust.

Compliance with regulations like ISO 27001 and Essential 8 is not just about avoiding penalties; it’s also about demonstrating due diligence and commitment to cybersecurity. An effective IRP helps meet these compliance requirements by providing clear protocols for incident detection, containment, and recovery, as well as documenting actions for audits and investigations.

Steps to Develop and Implement Your Incident Response Plan

Developing and implementing an Incident Response Plan involves several critical steps:

1. **Assess Risks**: Identify potential threats and vulnerabilities specific to your business and industry. This includes understanding the types of data you hold and the systems you use.

2. **Define Roles and Responsibilities**: Clearly outline the roles and responsibilities of your incident response team. Ensure that everyone understands their tasks and has the necessary authority to act swiftly.

3. **Create Incident Response Procedures**: Develop step-by-step procedures for detecting, containing, eradicating, and recovering from incidents. These should be documented and easily accessible to everyone involved.

4. **Train Your Team**: Regularly train your incident response team and conduct drills to ensure they are prepared to handle real incidents. This includes practicing communication protocols and running through hypothetical scenarios.

5. **Test and Update the Plan**: Regularly test your IRP through simulated incidents to identify any weaknesses or gaps. Update the plan as necessary to reflect changes in your business environment or emerging threats.

Continuous Improvement: Keeping Your Incident Response Plan Relevant

Cyber threats are constantly evolving, and so should your Incident Response Plan. Continuous improvement is essential to keep your IRP relevant and effective. This involves regularly reviewing and updating the plan based on new threats, changes in your business operations, and lessons learned from past incidents.

Conducting post-incident reviews is a key part of this process. After each incident, analyse what happened, how it was handled, and what could be improved. Use this information to update your IRP, ensuring that your team is better prepared for future incidents. Additionally, stay informed about industry trends and regulatory changes to ensure your plan remains compliant and effective.