Cmmc Incident Response Plan Template

STANDARD OPERATING PROCEDURE: CMMC Incident Response Plan (IRP) Execution & Template Registry Implementation

1. Document Control Block

• Document ID: SOP-ENG-CMMC-IRP-042
• Effective Date: October 24, 2023
• Version: 3.4.0
• Classification: Controlled Unclassified Information (CUI) / ITAR-Restricted
• Review Cadence: Annual (or immediately following any high-severity security incident)
• Owner: Julian Vance, Chief Architect, Template Registry

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2. Executive Summary & Purpose

This Standard Operating Procedure (SOP) defines the operational mandates, workflows, and artifact standards for executing, maintaining, and testing the Cybersecurity Maturity Model Certification (CMMC) Incident Response Plan (IRP) at Template Registry.

The purpose of this document is to ensure 100% compliance with CMMC Level 2 / NIST SP 800-171 Rev 2 controls (specifically families IR: Incident Response and PE: Physical and Environmental Protection). This SOP dictates how security anomalies are detected, contained, eradicated, and reported to relevant regulatory bodies (e.g., DoD DCISE, FedRAMP/CMMC PMO) within mandated contractual timeframes (e.g., 72-hour reporting for CUI compromise).

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3. Scope & Prerequisites

Scope

• Applicability: All physical infrastructure, cloud environments (AWS GovCloud/Commercial Enclaves), endpoints, source code repositories, and CI/CD pipelines managed by Template Registry.
• Data Classifications: Controlled Unclassified Information (CUI), Federal Contract Information (FCI), and proprietary corporate intellectual property.

Prerequisites & Required Tools

• SIEM / Log Aggregation: Splunk Enterprise Security / AWS CloudWatch / GuardDuty.
• EDR (Endpoint Detection & Response): CrowdStrike Falcon Insight.
• Forensic Tooling: Volatility Framework, FTK Imager, Wireshark.
• Ticketing & Incident Management: Jira Service Management (FedRAMP Authorized instance) with PagerDuty integration.
• Secure Collaboration: Signal / Wickr Enterprise (out-of-band communication).
• Reference Artifact: Template Registry CMMC System Security Plan (SSP) v5.2.

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4. Roles & Responsibilities (RACI Matrix)

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5. Step-by-Step Procedure

Phase 1: Preparation & Continuous Monitoring (IR.L2-3.6.1)

• Verify that automated alerting rules in SIEM and EDR are active and polling critical assets continuously.
• Confirm that out-of-band communication channels (Wickr Enterprise) are tested and operational for the Incident Response Team (IRT).
• Ensure forensic capture mechanisms and Read-Only media drives are staged within the primary server racks.

Phase 2: Detection & Analysis (IR.L2-3.6.2)

• Triage Alert: Acknowledge security anomalies flagged by SIEM/EDR within 15 minutes of generation.
• Validate Indicator: Determine whether the alert represents a true positive or false positive using threat intelligence feeds and baseline deviation analysis.
• Classify Severity: Assign an incident severity level (Sev-1: Active CUI Exfiltration; Sev-2: Localized Malware; Sev-3: Policy Violation).
• Open Ticket: Generate an encrypted ticket in the Jira Service Management incident registry, logging all initial artifacts, timestamps, and indicators of compromise (IoCs).

Phase 3: Containment, Eradication, & Recovery (IR.L2-3.6.3, IR.L2-3.6.4)

• Execute Containment: If Sev-1 or Sev-2, isolate compromised endpoints from the network using EDR isolation commands while preserving memory states for forensics.
• Network Segmentation: Revoke compromised AWS IAM roles, rotate API keys, and terminate compromised security groups.
• Acquire Evidence: Perform bit-stream forensic imaging of compromised physical/virtual assets using NIST-compliant tools (FTK Imager/dd).
• Eradicate Threat: Remove malware payloads, close exploited vectors, patch vulnerabilities, and purge unauthorized persistence mechanisms (cron jobs, registry keys).
• System Recovery: Restore systems from known-good, immutable golden images or verified clean backups.
• Integrity Verification: Run system integrity checks (tripwire/AIDE) and vulnerability scans to validate cleanliness prior to network re-introduction.

Phase 4: Post-Incident Activity & Reporting (IR.L2-3.6.5)

• Mandatory Reporting: If CUI exposure is confirmed, initiate formal notification protocols to the DoD DCISE (within 72 hours via dibnet.dod.mil) and affected contracting officers.
• Conduct Post-Mortem: Convene an After-Action Report (AAR) meeting with the IRT within 5 business days of incident closure.
• Update Artifacts: Revise the Template Registry CMMC Incident Response Plan template and associated playbooks based on lessons learned.

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6. Quality Assurance & Pro-Tips

Best Practices (Pro-Tips)

• Preserve Chain of Custody: Never power down a live system suspected of containing volatile memory before memory capture is complete; pulling the plug destroys crucial forensic evidence.
• Isolate, Don't Delete: When dealing with compromised cloud instances, snapshot the volume and isolate the security group rather than terminating the instance immediately, ensuring root-cause analysis viability.

Common Pitfalls to Avoid

• Internal Communication Leaks: Do not use corporate email or Slack for incident discussions regarding active breaches; use designated out-of-band encrypted channels to prevent tipping off threat actors.
• Delayed Reporting: Avoid waiting for complete forensic conclusions before notifying compliance officers; adherence to the 72-hour DoD reporting window supersedes complete root-cause certainty.

Metric Thresholds

• Mean Time to Detect (MTTD): $< 15$ minutes for high-severity anomalies.
• Mean Time to Contain (MTTC): $< 60$ minutes for confirmed CUI exposure incidents.
• Tabletop Exercise Frequency: Minimum biannual execution of simulated CMMC incident scenarios.

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7. Frequently Asked Questions (FAQ)

Q1: What triggers the mandatory 72-hour DoD reporting requirement under CMMC/NIST SP 800-171?
A: The 72-hour clock begins the exact moment Template Registry reasonably suspects or confirms that Controlled Unclassified Information (CUI) has been accessed, exfiltrated, or compromised by an unauthorized actor. Do not wait for a full forensic report to submit the initial DIBNet notification.

Q2: How should forensic artifacts be stored to maintain CMMC compliance?
A: All forensic images, memory dumps, and ticket logs must be stored in encrypted, access-controlled repositories (AES-256 at rest) with strict Role-Based Access Control (RBAC) limited exclusively to the Incident Response Commander and authorized legal counsel. Retain artifacts for a minimum of 3 years or per contract specifications.