Run a tabletop exercise each year and fold the findings into the plan

Incident Response policy, §9, §11

The Company tests this plan with a tabletop exercise at least once a year, on a scenario prepared in advance such as a payment outage, a customer data breach, or a vendor compromise. The response team walks through the response as the facilitator introduces new facts, the facilitator documents observations and improvement areas, and the findings are carried into the next plan update. The plan itself is reviewed at least annually and sooner on a material change to systems, vendors, requirements, or the threat landscape.

Annual

Once a year, with the plan update that follows; sooner on material change

Prepare the scenario, run the exercise with the response team, document the observations, update the plan, and distribute the approved version to staff and the sponsor bank.

• Tabletop exercise report

  Scenario, participants, date, observations, improvement areas

• Plan revision record

  Version, changes made, approver, date distributed

Compliance Officer

Leela can keep the annual exercise and plan-review dates and open each when it comes due, with last year’s findings attached.

Tell Leela about your company to see whether this applies.