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An incident response plan you can actually use at 2 a.m.

A section-by-section outline for a small-business incident response plan, a first-hour checklist and a simple way to test it before you need it.

Nine sections, plain language

First-hour checklist

Test it with a tabletop

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The short answer

A small-business incident response plan is a short written document that says who decides, who does what and who gets called when something goes wrong: ransomware, a hacked email account, a lost laptop or a payment fraud. A usable template has nine parts: purpose and scope, roles and contacts, what counts as an incident, severity levels, the first-hour checklist, containment and recovery steps by incident type, communication and notification, evidence and documentation, and review and testing.

Keep it to a few pages, print a copy and test it once a year with a one-hour tabletop exercise. Below is the outline with what to write in each section.

Why a short plan beats a long one

NIST’s updated incident response guidance, SP 800-61 Revision 3 (April 2025), ties incident response to the six functions of the NIST Cybersecurity Framework 2.0 rather than treating it as a standalone procedure. The practical takeaway for a small business is that the plan is part of everyday security, not a binder on a shelf. During an incident nobody reads 40 pages. They need names, phone numbers and the next three steps.

Some businesses are also required to have one. The FTC Safeguards Rule requires a written incident response plan for most covered financial businesses (very small ones are exempt from this part), such as tax preparers and mortgage brokers, and many cyber-insurance applications ask whether you have one. Regulated businesses should confirm their specific obligations with counsel.

The template, section by section

1. Purpose and scope

One paragraph. Which systems, locations and data the plan covers, and that it applies to employees and contractors. Note the date and who approved it.

2. Roles and contact sheet

The most important page. List an incident lead and a backup with authority to make decisions, such as shutting down systems or calling the insurer. Then list phone numbers, not just email, for:

  • Your IT provider or internal IT person
  • Your cyber-insurance carrier’s claims hotline and policy number
  • Breach counsel, if your policy assigns one
  • Your bank’s fraud department
  • Key software vendors: Microsoft 365 or Google Workspace admin, line-of-business software, website host
  • Local law enforcement and the FBI’s Internet Crime Complaint Center (IC3)

Store a printed copy and a copy outside your main systems. If email is down or encrypted, the plan cannot live only in email.

3. What counts as an incident

Give staff plain examples so they report early: a suspicious login alert, files that will not open, a ransom note, money sent to a changed bank account, a lost device, or a customer saying they got a strange invoice from you. State one way to report, such as calling a named person, and say that reporting a mistake will not get anyone in trouble.

4. Severity levels

Three levels are enough. Low: contained to one device or account, no sensitive data. Medium: several users, or possible exposure of customer data. High: business operations stopped, ransomware, or confirmed data theft. Each level says who must be told and how fast.

The first-hour checklist

This is section 5 of the plan, and it should fit on one page.

  1. Do not turn machines off. Disconnect affected computers from the network (unplug the cable or turn off Wi-Fi) so evidence is preserved.
  2. Call the incident lead and IT. Start a written log with times and actions.
  3. Call your insurer before hiring anyone. Many policies require you to use their approved responders, and early notice can matter for coverage.
  4. Reset compromised accounts. Change passwords and revoke sessions from a clean device, and confirm multi-factor authentication is on.
  5. Stop money movement. If payment fraud is involved, call your bank immediately; speed affects recovery.
  6. Do not pay or negotiate with an attacker without counsel and your insurer involved.
  7. Do not announce anything publicly until the incident lead approves the wording.

Want to know whether your recovery plan would hold up? Our free Technology Health Assessment takes about 30 minutes of data collection. The next day you get a plain-language report rating your IT operations, cybersecurity, backups and business continuity as controlled, needs attention, significant exposure or unknown, with a short list of next steps in order. It is yours to keep, with no obligation. Book your assessment.

Playbooks for the incidents you are most likely to face

Section 6 holds short playbooks, half a page each. Start with these four.

  • Compromised email account. Reset password, revoke sessions, check for forwarding rules and inbox rules the attacker created, review sent mail, warn contacts who received fraudulent messages.
  • Ransomware. Isolate affected devices, identify the last clean backup, confirm backups were not reached, restore by priority (the systems that let you invoice and serve customers first).
  • Lost or stolen device. Confirm encryption was on, wipe remotely, disable the user’s sessions, record what data was on it.
  • Payment or invoice fraud. Call the bank, file with IC3, verify all pending payment changes by phone using known numbers.

Recovery depends on backups you have actually restored before. Our guide to backup and disaster recovery covers how to set recovery targets.

Communication, notification and evidence

Section 7 lists who must be told: leadership, staff, customers, partners and, depending on your industry and state, regulators. Every U.S. state has a data breach notification law, and some industries have their own rules. HIPAA, the FTC Safeguards Rule and state laws each have their own timelines. Write in the plan that counsel decides on notifications, and keep pre-approved holding statements for staff and customers.

Section 8 covers evidence: keep logs, do not wipe affected machines until responders say so, and record every action with a time. Insurers and investigators will ask for this timeline.

Where small-business plans usually fail

  • Contacts are stale. The IT person left, the insurer changed, the phone numbers are old.
  • Nobody has authority. The plan does not say who can shut systems down or approve spending at night.
  • The plan lives in the system that is down. A plan stored only on the file server is useless during ransomware.
  • Admin access is unknown. No one can find the Microsoft 365 or domain registrar login when it matters.

How to test the plan

Section 9 sets the review cycle. Test once a year and after any major change, such as a new IT provider or office.

  1. Pick a scenario. CISA publishes free Tabletop Exercise Packages with ready-made scenarios, including ransomware, that small organizations can adapt.
  2. Gather the decision makers for one hour: owner, office manager, IT, finance.
  3. Walk through it. Read the scenario in stages and ask: who do we call, what do we shut off, what do we tell customers?
  4. Write down the gaps. Wrong phone numbers, unclear authority and untested backups are common.
  5. Fix and update. Assign each gap an owner and a date. Record that the test happened.

A test restore of a real system is the most useful companion exercise. A plan that says “restore from backup” means little if nobody has timed a restore. Our cybersecurity services include a written recovery plan, monitored backups and tested restores, and we can sit in on your tabletop.

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Questions we hear

What should a small business incident response plan include?

Purpose and scope, roles and a contact sheet, what counts as an incident, severity levels, a first-hour checklist, playbooks for common incidents, communication and notification steps, evidence handling and a schedule for review and testing.

How long should an incident response plan be?

Short enough to use under pressure. For a 25 to 100 person business, a few pages plus one-page playbooks for common incidents is usually enough.

Is a small business required to have an incident response plan?

Some are. The FTC Safeguards Rule requires one for most covered financial businesses, and insurers often ask about it. This is general information; confirm your obligations with counsel.

How often should you test an incident response plan?

At least once a year and after major changes. A one-hour tabletop exercise using a free CISA scenario is a practical starting point.

Who should call the cyber insurer during an incident?

The incident lead named in your plan, as early as possible and before hiring outside responders, because many policies require approved vendors.

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