Regulatory Notification Deadline Approaching
A regulatory reporting deadline (GDPR 72-hour, SEC 4-day, state breach notification, HIPAA) is imminent and the investigation has not yet determined the full scope of data exposure. The team must balance thorough investigation against mandatory disclosure timelines.
Signals
- •Legal or compliance has flagged that the notification clock started upon discovery and the deadline is within 24-48 hours
- •The incident involves PII, PHI, or financial data subject to mandatory breach notification
- •Executive leadership is requesting a scope assessment for the notification filing
- •External counsel has been engaged to draft the notification language
Pivot Actions
- 1.Prioritize data-exposure scoping: identify which data stores were accessed and what data categories are affected
- 2.Prepare a preliminary notification that meets minimum regulatory requirements while preserving the ability to supplement later
- 3.Coordinate with legal to determine if a "good faith" preliminary filing buys additional investigation time
- 4.Assign a dedicated analyst to regulatory-evidence collection (access logs for sensitive data stores) separate from the broader IR workstream
- 5.Document all investigative steps and timelines meticulously to demonstrate due diligence to regulators
Alternate Evidence Sources
- •Database access and query logs showing which tables/records were accessed
- •DLP logs identifying sensitive data in exfiltration channels
- •Data classification inventories mapping which systems hold regulated data