Most incident response planning looks fine on paper. Roles are listed, steps outlined, maybe there’s a severity matrix. But when an incident hits, especially out of hours, most plans fall apart.
Incident response planning isn’t about having a document. It’s about whether people know what to do and whether your plan works under pressure.
This isn’t a basics guide. It’s a look at what’s missing from most playbooks and how to fix it.
Here are eight of the most common and costly gaps we see in real-world incident response plans.
TL;DR
1. No defined roles or escalation path
You’d be surprised how many incident response plans don’t actually tell people what to do.
They list the tools, reference the comms flow and maybe name a couple of senior contacts. But they skip the bit where someone takes ownership and makes the hard calls.
And when the alert hits, no one’s quite sure who’s running point, who needs to be looped in or what needs sign-off.
This isn’t just a documentation issue. It’s a governance gap. In financial services, it leads directly to delay, confusion, finger-pointing and regulator pain if something serious happens.
It’s also one of the most common weak spots in incident response planning.
Why this matters
Without clearly defined roles and escalation paths:
- Decision-making stalls under pressure
- Accountability is fuzzy so actions get delayed
- You risk missing internal SLAs, external obligations or regulator thresholds
This becomes even more serious during complex cross-team incidents like ransomware or insider fraud, where legal, compliance and comms need to be engaged in the right order with the right information.
How to fix it
The NCSC highlights clear roles and escalation paths as essential for effective cyber incident response, especially when incidents move fast and decision-making needs to be immediate.
Here’s how to improve the governance layer of your incident response planning:
1. Assign named roles, not just teams
List who’s responsible for each core function: triage lead, comms lead, legal or compliance contact and exec liaison. Don’t just say “IT Security” — say “Toby James, Head of SecOps”.
2. Define the chain of escalation
Make it clear who triggers each escalation step. For example: “If severity reaches level 3, notify the CISO and DPO immediately.” Map this out visually if needed.
3. Create a fallback structure
Assume someone’s off sick or on holiday. Every role should have an alternate with equal authority.
4. Walk through real scenarios
Don’t wait for a live incident to test governance. Run tabletop exercises and ask: “Who would make this call?” “How would they be reached?” “Who signs off on comms?”
5. Store the escalation matrix outside the IRP
Keep a one-pager version of your incident response planning handy and share it with everyone involved. It should live in your IR toolkit, not buried in a 60-page plan.
This is one of 16 controls we assess in our incident response planning scorecard. If you’re not sure where your gaps are or how bad they might be, [download the Cyber IRP scorecard here] to get a benchmark.
2. No out-of-hours contact structure or alternates
Most incidents don’t happen during working hours. Yet many IR plans assume a perfect 9 to 5 world, where everyone’s available, knows their role and can be reached instantly.
This is a common blind spot in incident response planning. The reality is different. Key people are off. Phones are off. That senior approver for public comms? On a plane to Singapore. And no one has the authority to act in their place.
Even when contacts are listed, the details are often out of date or buried in an internal SharePoint folder that no one can access during an incident.
According to the NCSC, organisations should maintain a live, accessible contact structure as part of their cyber incident response planning toolkit, especially for use during out-of-hours events or when primary contacts are unavailable.
Why this matters
Out-of-hours readiness is about more than just escalation. It’s about being able to act without delay, regardless of the time or day. When that breaks down:
- Incidents stall or worsen before action is taken
- Third parties or regulators may be notified too late
- Internal teams lose confidence in the response process
This is especially risky in environments where comms, legal and execs need to be brought in quickly for high-impact events.
How to fix it
1. Create a live IR contact list with names, numbers and roles
Include office and mobile numbers for each key contact. Use plain language to describe their role in the incident. For example: “Sarah Khan – decision maker for customer notifications”.
2. Nominate alternates for every primary contact
Make sure there’s always someone who can step in with the same authority in your incident response plannnig. Don’t rely on job titles alone. List names.
3. Make it accessible offline
Store the list in your incident response planning toolkit and back it up somewhere secure but accessible, like a dedicated Teams channel or protected PDF on a mobile device. Assume your normal systems are down.
4. Review and test it quarterly
Set a recurring check to verify names and numbers. Simulate an after-hours callout. See who answers and how long it takes to reach the right person.
5. Integrate it into your war room setup
Don’t treat the contact list as a side doc. Link it directly to your secure comms tools, war room checklists and escalation matrix.
This is one of 16 controls we assess in our incident response planning scorecard. To see how your plan holds up across governance, readiness, response and recovery, [download the Cyber IRP scorecard here].
3. No severity matrix or legal trigger points
When a potential incident lands, one of the first questions is: how serious is this?
If there’s no severity matrix or predefined thresholds, teams often fall back on instinct or past experience.
That works fine until someone downplays a breach, delays comms or misses a regulatory trigger. By the time legal is looped in, you’re already out of time.
This is a common blind spot in incident response planning. Technical teams move fast, but classification is inconsistent. Business risk gets missed. Regulators don’t get notified when they should. Or worse, they get notified too soon with half the facts.
Why this matters
The DORA Regulation (EU 2022/2554) will require financial firms to classify and report ICT incidents within tight deadlines, making this a core part of incident response planning.
If you don’t have clear, consistent classification:
- You waste time debating the impact instead of acting
- Legal and compliance teams are brought in too late or not at all
- You risk breaching GDPR, DORA or FCA time-bound obligations
In financial services and many other sectors, misjudging the severity of an incident can cost more than the incident itself.
How to fix it
1. Build a practical severity matrix
Define levels 1 to 4 with clear criteria: number of users impacted, data type involved, system criticality and reputational risk. Make sure it’s understandable at speed.
2. Include business and regulatory triggers
Don’t just use technical impact. Include thresholds that trigger legal or regulatory reporting. For example: “Any unauthorised access to customer data = severity 3 minimum”.
3. Align with legal and compliance early
Have your legal and compliance teams sign off on the severity matrix and agree when they should be notified. Put that in writing and in the plan.
4. Train your responders to use it
Classification is only useful if people actually apply it. Run live examples in exercises and incident reviews to build confidence in its use.
5. Integrate it into tooling if possible
If you use a SIEM or ticketing platform, add severity tags and trigger logic directly into your workflow. Automate where you can, but keep human override for edge cases.
Clear classification should be a core part of your incident response planning. If you’re unsure whether your current approach covers the right legal and regulatory triggers, our scorecard will help you benchmark it. [Download the Cyber IRP scorecard here].
4. No runbooks for top threat scenarios
You’ve got a response plan, but what about a ransomware playbook? Or one for phishing, insider activity or cloud account compromise?
This is where incident response planning often stops short. The main document covers the framework, but responders are left working out the details mid-incident.
Where’s the checklist? Who isolates what? Who confirms the backup is clean?
Without scenario-specific runbooks, teams either overreact or freeze. Either way, time is lost and decisions are slower.
Why this matters
Generic plans don’t work when things get specific. Without runbooks:
- Actions are missed or repeated
- Teams escalate before they’ve contained
- Legal and comms are notified too late
- Valuable time is wasted explaining systems and priorities
In a ransomware event, for example, the order of operations matters. Wait too long to isolate and it spreads. Restore too soon and you reintroduce the threat.
These mistakes don’t come from bad intent. They come from a lack of shared playbooks.
How to fix it
1. Identify your top five threat types
Use real data or expert judgement. Focus on likely, high-impact threats like ransomware, phishing, cloud misconfigurations, insider breach or DDoS.
2. Create simple, step-by-step runbooks
The NIST Incident Response Guide recommends developing playbooks or runbooks tailored to specific threat types to ensure consistent, repeatable actions during a response.
Keep them tight. Who leads? What’s the first response? What systems need to be checked, contained or isolated? Where’s the evidence stored?
3. Include system-specific notes
Add references to internal tools or platforms. For example, “Contain host in Defender portal” or “Disable user in Okta”.
4. Test them in exercises
Run a scenario every quarter. Don’t test the big plan. Test the ransomware playbook, the phishing flow, the backup restore checklist.
5. Link them to your main IR plan
Runbooks should be extensions, not replacements. Reference them from the incident response planning document and store them together in the same response toolkit.
Effective incident response planning isn’t just about having a policy. It’s about having the right playbook for the moment.
Our incident response planning scorecard helps you see which scenarios you’re actually prepared for and which ones need work. [Download the Cyber IRP scorecard here] to benchmark your coverage.
5. Backups exist but haven’t been tested under pressure
Most teams are confident they have backups. Fewer are confident they can actually restore from them, quickly, reliably and under pressure.
This is one of the most dangerous gaps in incident response planning.
In ransomware scenarios, recovery depends on your ability to restore fast. But backups are often untested or taken for granted. Some are incomplete. Some restore the wrong version. Some restore just fine, but only over a weekend.
And that’s assuming someone even knows where to find the last clean backup.
Why this matters
- If you can’t restore, you can’t recover.
- You might contain the threat and clear the systems, but without working data, you’re still offline.
- If you’re in financial services, that’s not just a business risk. It’s a regulatory one too.
We’ve seen cases where backups were assumed to work, only to fail in the middle of a recovery effort. Hours were wasted. Trust was lost. The regulator wasn’t impressed. That was all done to poor incident response planning.
The IBM Cost of a Data Breach Report also consistently finds that delayed response and recovery, often due to failed or untested backups, adds significantly to breach costs.
How to fix it
1. Define your critical systems and recovery points
Know which systems must be restored first. Set target recovery times and recovery points. Make sure these are realistic and aligned with business expectations.
2. Test backup restores regularly
Don’t wait for a real event. Schedule restore tests every quarter. Include cloud platforms, SaaS tools and anything holding customer data.
3. Document the restore process step by step
List exactly how to restore from each platform or tool. Who runs the restore? What credentials are needed? Where are the backups stored?
4. Build clean recovery zones
In ransomware scenarios, restoring to an infected environment just repeats the problem. Prepare a known clean zone or sandbox for validation.
5. Make this part of your wider incident response planning
Restoration is not just an IT function. It’s a key phase in your response. Document it, assign owners and include it in tabletop exercises.
Backup validation is one of the quickest wins in incident response planning, but also one of the most overlooked.
Our scorecard helps you assess not just whether backups exist, but whether they’re ready for the real thing. [Download the Cyber IRP scorecard here] to test your recovery readiness.
6. No clear data flow for high-risk systems
When an incident hits, one of the first questions is: what data is affected? But many teams can’t answer that without digging through outdated diagrams or asking around.
Data flow clarity is often treated as an architecture issue, not an incident response priority.
But if you don’t know how sensitive data moves through your systems, you can’t contain the breach or assess the impact. You end up guessing, over-disclosing or under-reporting.
This is a major weakness in incident response planning, especially in financial services where customer data, payment flows and regulatory scope all carry weight.
Why this matters
Without up-to-date data flow visibility:
- You can’t quickly scope the blast radius of an incident
- You risk underestimating exposure to PII, transactions or regulated records
- You delay legal and regulatory assessments
A compromised cloud account, for example, might seem low risk until you realise it’s piped into a production billing system. By then, the window to act has closed.
How to fix it
1. Identify your high-risk systems and data types
Start with customer data, payment systems and regulated workflows. Include anything that triggers legal reporting or business continuity plans.
2. Map flows end to end
Use diagrams to show how data enters, moves through and exits each system. Include third parties, cloud integrations and internal transfers.
3. Tag each data type
The NIST Cybersecurity Framework places strong emphasis on identifying and mapping system dependencies and data flows as a core part of response preparation.
Mark what is considered PII, payment data, financial records or internal only. Add a risk level if helpful.
4. Review and update quarterly
Treat your data flow map as a live document. Review it alongside system changes, vendor shifts or new regulatory requirements.
5. Link to your incident response planning toolkit
This isn’t just for the architects. Your IR team needs access to this during triage and classification. Store it where responders can find and use it fast.
Clear data flow mapping is an essential part of effective incident response planning. If you’re not sure whether your current map is accurate or even available, our scorecard can help you assess the gap. [Download the Cyber IRP scorecard here] to get started.
7. Unclear or untested reporting procedures
When something serious happens, you usually don’t have long before you’re expected to inform someone. That could be your regulator, your board, your insurer or all three.
But many teams don’t have a clear process for this.
Some scramble for a template. Others waste hours chasing legal or compliance to draft a statement. And sometimes, the trigger to notify never gets pulled. Not because of bad intent but because no one was sure who owned it.
This is a critical weakness in incident response planning, especially in financial services where reporting deadlines are short and the expectations are high.
Why this matters
Without a clear and tested reporting procedure:
- You risk missing a regulatory window and triggering enforcement
- Your external messaging is inconsistent or inaccurate
- Legal and compliance get brought in too late to help shape the response
Even when you manage to notify, the content is often rushed, misaligned or overly cautious. That creates more questions than answers. Not a good look with your regulator.
How to fix it
The ICO sets out specific expectations for reporting timelines and content following a notifiable security incident. A vague or delayed response puts you at risk of non-compliance.
Here’s the steps you should follow in your incident response planning:
1. Define your regulatory reporting triggers
Document what types of incidents need to be reported and under which laws or frameworks. Include GDPR, FCA, DORA or anything else that applies to your firm.
2. Assign ownership for drafting and approval
Make it clear who prepares the notification and who signs it off. Avoid sending anything generic or rushed without legal review.
3. Create a reporting template or checklist
Include the key points most regulators expect: what happened, when it was discovered, who is affected, what actions have been taken and what’s next.
4. Test the procedure in exercises
Run a tabletop where the trigger threshold is crossed. Time how long it takes to produce a statement and get it approved.
5. Include this step in your wider incident response planning
Reporting is not an afterthought. It’s a core part of the plan. Treat it with the same urgency and structure as containment and recovery.
From our experience, this is one of the areas most often overlooked in incident response planning.
If you’re not sure whether your reporting process stands up under pressure, the incident response planning scorecard will help you find out. [Download the Cyber IRP scorecard here] to check your coverage.
8. No structured lessons learned process
You get through the incident. Things go quiet. Then everyone moves on.
It’s one of the most common failure points in incident response planning. The team manages containment and recovery, maybe even does a quick write-up. But the opportunity to learn, and improve, gets missed.
There’s no structured debrief, no action tracking and no changes made to the actual response plan.
The next time something similar happens, you’re back where you started. Same delays, same gaps, same scramble.
Why this matters
If you don’t learn from each incident:
- You repeat the same mistakes
- Your plan never improves
- Small issues become systemic weaknesses
Regulators expect formalised learning. Internally, so do your stakeholders.
Lessons learned isn’t a nice-to-have. It’s the engine that makes your incident response planning better over time.
How to fix it
1. Run a structured debrief within five working days
Set time aside with key responders while the event is still fresh. Use a simple format: what went well, what didn’t and what needs fixing.
2. Track actions with owners and deadlines
Make sure every issue raised is logged, prioritised and assigned. Don’t let them sit in meeting notes.
3. Feed actions back into the IR plan
Update roles, contacts, playbooks or tooling based on what happened. Show that the plan evolves after real incidents.
4. Share insights across teams
Publish short summaries or key learnings. Help other teams benefit from what was discovered, especially if the root cause is systemic.
5. Make this step a non-negotiable part of your incident response planning
Lessons learned should not rely on memory or culture. It should be formal, documented and tracked.
Lessons learned is one of the most powerful parts of incident response planning. But only if it’s built into the process.
Our incident response planning scorecard helps you assess how well you close the loop after each incident. [Download the Cyber IRP scorecard here] to benchmark your maturity.
Final thoughts on incident response planning
Most organisations have some form of incident response planning in place. But having a document doesn’t mean you’re ready.
As we’ve seen, it’s often the missing details. The out-of-hours gaps, the lack of playbooks, the untested backups.
These cause the biggest problems when it really counts. These aren’t edge cases. They’re the basics, and they’re where many plans fall short.
If you’re responsible for incident response planning in your organisation, now is the time to pressure test what you’ve got. Not just for your own peace of mind, but for your customers, your regulator and your team.
Cyber Incident Response Planning Scorecard
We’ve created a free, editable scorecard that helps you assess your maturity across 16 critical controls. It’s practical, quick to use and designed specifically for IT and InfoSec teams in financial services.
[Download the Cyber IRP scorecard here] and see where you stand.
CloudGuard Incident Response Workshops
Sound like too much work or not enough time? CloudGuard’s Incident Response Workshops can help you create, review and test effective incident response plans that hold up under pressure.
