Security Incident Response Plan (SIRP)

Table of Contents

1. Summary
2. Planning
3. Identification
4. Containment
5. Recovery
6. Remediation
7. Lessons Learned
8. Contact

1. Summary

This Security Incident Response Plan (“SIRP”) between Ethnio, Inc. (“Ethnio”, "us" or "we") and users of the Ethnio Services ("you") governs the provision of the Software Service by Ethnio to you pursuant to the Terms of Service (the "Terms"). All capitalized terms not defined herein shall have the meanings given to them in the Agreement.

2. Planning

This Security Incident Response Plan is documented to provide a well-defined, organized approach for handling any potential threat to computers and data, as well as taking appropriate action when the source of the intrusion or incident at a third party is traced back to the private network. This Security Incident Response Plan identifies and describes the roles and responsibilities of the Security Incident Response Team.

2.1 Security Incident Response Team (SIRT)

The Security Incident Response Team is comprised of key technical and support team members at Ethnio who have had training in providing a quick, effective and orderly response to threats such as hacker attempts and break-ins, system service interruptions, breach of personal information, and other events with serious information security implications.

The Security Incident Response Team’s mission is to prevent a serious loss of profits, client confidence or information assets by providing an immediate, effective and skillful response to any unexpected event involving computer information systems, networks or databases. The Security Incident Response Team is authorized to take appropriate steps deemed necessary to contain, mitigate or resolve a computer security incident.

The Security Incident Response Team is responsible for investigating suspected intrusion attempts or other security incidents in a timely, cost-effective manner and reporting findings to the appropriate authorities as necessary. These investigations will be coordinated across:

2.2 Types of Incidents

2.3 Definition of a Security Breach

A security breach is defined as unauthorized acquisition of data that compromises the security, confidentiality or integrity of personal information maintained by Customer. Good faith acquisition of personal information by an employee or agent of the Vendor for business purposes is not a breach, provided that the personal information is not used or subject to further unauthorized disclosure.

3. Identification

All reports of a potential incident shall be classified as a Severity 1/Severity 2/Severity 3 risk to facilitate the actions to take.

3.1 – Severity 1

Definition: Functionality of the Software Service is impaired or some users are unable to access or use some functionality. Example: Unauthorized system access.

Ethnio will respond to and our senior engineers and will commence efforts to fix these problems no later than two (2) hours after you report of such problem or we detection of such problem, whichever is earlier. Ethnio will use reasonable and continuous efforts to fix these problems during normal business hours, and if an acceptable work-around is provided, will provide a permanent fix no later than thirty (30) days after you report of such problem.

3.2 – Severity 2

Definition: Incidents that have the potential to have a monumental impact on the use or functionality of the Software Service. Example: Password cracking attempt.

Ethnio will respond to these problems within four (4) hours after you report of such problem or we detection of such problem, whichever is earlier, during you regular business hours (or on the next business day, if the problem is reported outside of you regular business hours).

3.3 – Severity 3

Definition: Low impact to users of the Software Service. Example: Firewall scanning.

Ethnio will respond to these problems within six (6) hours after you report of such problem or our detection of such problem, whichever is earlier, during regular business hours (or on the next business day, if the problem is reported outside of regular business hours).

4. Containment

4.1 Shut Down Note

In responding to a reported incident, it may be good prudence to shut down any or all systems for the stopping of an attack in real time and/or the preservation of any potential forensic evidence.

5. Recovery

The main purpose of this Security Incident Response Plan is to ensure an efficient recovery through the eradication of security vulnerabilities and the restoration of repaired systems. Recovery includes Ethnio ensuring the attacker’s point of penetration and any associated vulnerabilities have been eliminated and all system operations have been restored.

6. Remediation

Ethnio’s first priority after recovery, especially with a Severity 1 incident, is remediation to achieve full threat eradication. The Security Incident Response Team will focus on immediately eliminating any attacker presence, blocking access, and closing all attack vectors.

6.1 Updates & Repairs

Ethnio will update security controls, perform repairs, replacements, or augmentation to ensure the environment is secure while final remediation plans are developed.

6.2 Sustained Security

Using detailed incident reports and gap analyses that are developed during the initial response, Ethnio will develop updated security plans. Prior to the next phase of Lessons Learned, the quickest new processes and tools will be implemented to improve the security of vendor perimeter, internal network, internal hosts, applications, and data.

7. Lessons Learned

7.1 Prevention

The Security Incident Response Team will use investigative techniques, including reviewing of system logs, looking for gaps in logs, reviewing intrusion detection or firewall logs and interviewing internal and external stakeholders to determine how the incident was caused. The Security Incident Response Team will recommend changes to prevent the occurrence from happening again or spreading to other systems.

7.2 Periodic Testing

It is the responsibility of Ethnio to test and review the Security Incident Response Plan annually. When testing is done, each system should be scanned for the open vulnerability before remediation and then scanned again after the remediation to verify that the vulnerability has been eliminated. Annual testing of the Incident Response Plan will be done using walkthroughs and practical simulations of potential incident scenarios to identify process gaps and improvement areas.

8. Contact

Security Incident Response Team contact: Senior Engineer
Email: security_response@ethn.io