What Regulators Look for in an Incident Response Plan

A data breach is no longer a question of if—it’s when. And when it happens, regulators will ask one question first: Did you follow your incident response plan?

Policy Alone Isn’t Enough
Having a document labeled “Incident Response Plan” isn’t the same as having a functional one. Regulators and auditors want to see evidence that the plan is current, realistic, and actively used. That includes clearly defined roles for key personnel, steps for detecting and containing threats, communication protocols for notifying stakeholders, legal and regulatory reporting guidelines, and procedures for documenting post-incident lessons learned. These elements aren’t optional—they’re expected. And if they aren’t present, organizations risk penalties, reputational damage, and insurance complications.

Common Points of Failure
In many businesses, response plans are incomplete, untested, or unknown to employees. The most common weaknesses include relying on outdated contact information, omitting third-party roles, overlooking internal communication strategies, and failing to document recovery actions. These oversights lead to confusion when speed and clarity matter most.

Planning Is Prevention
An incident response plan isn’t just a checkbox—it’s the operational playbook when systems go offline, data is compromised, or ransomware locks down a network. A strong plan reflects the actual structure of the business, considers the full lifecycle of an event, and is reviewed regularly—not just after something goes wrong.

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Want to make sure your response plan stands up to scrutiny? Schedule a free consultation with our Compliance+ team.

2025-05-29T18:19:53-05:00May 29, 2025|

Why Written Security Policies Matter More Than Ever

For many companies, cybersecurity policies exist in name only—buried in a shared drive, drafted years ago, and forgotten. But regulators, insurers, and legal teams now treat written policies as evidence of an organization’s intent, preparation, and governance. In short, you can no longer operate in confidence without a written security policy.

What Regulators Expect to See
A written policy doesn’t guarantee security, but it establishes expectations—and creates accountability. When businesses lack formal documentation, investigators often assume the controls don’t exist. During audits or after a breach, regulators typically request copies of core documents like an information security policy, acceptable use policy, data retention schedule, vendor risk protocol, and an incident response plan. Without them, businesses may be considered out of compliance even if protective measures are in place.

Policy Gaps Lead to Broader Risk
The most common issue is not the absence of security itself, but the inability to prove it. Many organizations have good technical defenses, but fail to document how decisions are made, how risks are evaluated, and how staff are expected to respond. These gaps weaken positions during legal reviews, complicate insurance claims, and increase the likelihood of regulatory penalties.

Good Policy Is Practical, Not Aspirational
Effective policies are realistic, concise, and enforced. They reflect how the business actually operates—not an idealized version of it. This includes identifying who is responsible for updates, setting review timelines, training staff on the contents, and aligning language with existing procedures and controls. A strong security posture isn’t just built on tools—it’s supported by policies that can be shown, explained, and defended.

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Want help evaluating your existing security policies? Schedule a free consultation with our Compliance+ team.

2025-06-03T18:44:45-05:00May 29, 2025|

Cyber Insurance Is Changing—and Compliance Is Now Part of the Underwriting

Carriers are no longer just asking about firewalls and backups. Today, they want proof of policies, enforcement, and governance– what’s more, cyber insurers now factor compliance into coverage decisions. Poor documentation can lead to higher premiums or denied claims.

The Shift from Technical Controls to Compliance Readiness
A few years ago, cyber insurance applications focused mostly on technical safeguards—do you have endpoint protection, MFA, offsite backups? Those questions still matter. But increasingly, insurers want to know how well you manage compliance.

Underwriters now review whether your business conducts risk assessments, trains employees, documents vendor relationships, and follows written policies. A strong cybersecurity program without formal compliance to back it up is often no longer enough.

Premiums, Coverage, and Denials Are Tied to Documentation
Insurers are tightening requirements and using compliance posture to set premiums, define coverage limits, or deny claims. Businesses with incomplete documentation or poor governance are seeing higher premiums, reduced payouts after an incident, claims denied for missing controls, and in some cases, mandatory remediation steps before a policy can be issued or renewed.

Insurers are trying to limit losses—and a company’s ability to demonstrate a managed risk environment is now seen as a critical factor.

Where Businesses Fall Short
Many organizations—especially mid-sized and smaller firms—lack the documentation to support what they say on insurance applications. Common weak spots include the absence of written incident response plans, vendor risk oversight, employee training records, and audit trails for user access or system changes. These are precisely the areas that come under scrutiny after a breach. If the policyholder can’t show what was in place and when, coverage disputes follow.

Compliance as an Insurance Strategy
The message from insurers is clear: compliance isn’t optional, and it’s not just a regulatory issue. It’s a business requirement tied to financial protection.

Treating compliance as part of your cyber risk strategy—not an afterthought—can improve insurability, reduce premiums, and strengthen your position in the event of a claim.

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Need to understand how your compliance posture affects insurance? Schedule a free consultation with our Compliance+ team to identify gaps and reduce risk.

2025-05-29T17:58:32-05:00May 29, 2025|

Why Data Retention Policies Are Becoming a Regulatory Priority

Regulators are increasingly focused not just on what data companies collect—but how long they keep it.

Data Hoarding Carries Risk
Many organizations default to keeping everything: emails, customer records, internal files, and application logs. But retaining unnecessary or outdated data creates liability. It expands the scope of compliance obligations, increases the potential impact of a breach, and complicates legal discovery.

As cybersecurity threats evolve and regulations tighten, regulators are scrutinizing whether businesses have clear, defensible data retention policies in place—and whether they’re actually following them.

Growing Pressure Across Regulated Industries
Healthcare, finance, education, and legal services all face heightened expectations to enforce structured retention periods. HIPAA, GLBA, and state-level privacy laws increasingly require companies to dispose of personal information once it is no longer needed for the purpose it was collected.

Auditors and regulators are asking not just “What data do you have?” but “Why do you still have it?”

Elements of a Modern Data Retention Policy
An effective retention policy balances compliance, legal, and business needs. Core components typically include:

  • Defined retention periods for each category of data

  • Secure deletion protocols with audit trails

  • Clear roles and responsibilities for enforcement

  • Documentation of exceptions and review processes

These policies are not set-it-and-forget-it. They must evolve with changing laws, business operations, and technology platforms. Failure to maintain current policies—let alone follow them—can increase exposure during audits, investigations, or litigation.

A Compliance Priority, Not Just a Technical Task
Retention planning is often treated as an IT issue, but regulators view it as a compliance and governance obligation. The consequences of over-retention can be significant: higher discovery costs in legal disputes, larger breach notification lists, and more regulatory scrutiny.

Even small businesses are now expected to show that they are limiting data exposure through active retention management—not just good intentions.

Schedule Your Free Consultation Today
Want to make sure your retention policy stands up to regulatory expectations? Schedule a free consultation with our Compliance+ team.

2025-05-29T17:50:35-05:00May 29, 2025|

Why Compliance Starts Outside Your Organization

In today’s regulatory environment, your business is only as secure as the vendors you trust.

Regulatory Pressure Is Increasing—And So Are Third-Party Expectations
For many companies, compliance used to be an internal concern. But that’s no longer the case. Regulators now expect businesses to evaluate the cybersecurity posture, privacy practices, and operational resilience of every third-party vendor they work with—especially those with access to sensitive data or business-critical systems.

Whether it’s a cloud provider, software vendor, payment processor, or outsourced IT support team, the risks are real. According to the Ponemon Institute, 51% of data breaches in the last year involved a third party.

Federal and state regulations—from HIPAA and GLBA to the FTC Safeguards Rule—have updated requirements that make vendor risk management a formal part of compliance. It’s not enough to have a signed contract or a SOC 2 report on file. Companies must demonstrate they’ve done due diligence, implemented appropriate controls, and continue to monitor third-party performance over time.

Key Elements of a Vendor Risk Management Program
A mature vendor risk management (VRM) program includes several core components:

  • Initial Risk Assessments: Evaluating each vendor’s access, data handling practices, and security controls.

  • Contractual Protections: Ensuring contracts contain security obligations, breach notification timelines, and audit rights.

  • Ongoing Monitoring: Reviewing vendors annually, tracking compliance, and documenting any incidents.

  • Offboarding Procedures: Ensuring secure data return or destruction when a relationship ends.

Too often, businesses rely on outdated spreadsheets or informal processes that can’t scale—or survive an audit. And without a clear framework, even well-meaning companies can miss warning signs that a vendor poses a growing risk.

Compliance+ Helps You Build a Defensible Program
At Cost+, our Compliance+ service is designed to help you implement and maintain a vendor risk management program that meets regulatory expectations and reduces business exposure.

We assist with vendor classification, policy creation, risk assessments, and documentation—ensuring your program aligns with today’s compliance standards.

For companies without internal compliance teams, or those needing to modernize outdated processes, we provide the tools and expertise to close the gap and protect your business from third-party fallout.

Schedule Your Free Consultation Today
Learn how Cost+ can help you build a stronger vendor risk program—book your free consultation with our Compliance+ team today.

2025-05-29T17:44:00-05:00May 29, 2025|
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