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Template Reusable Incident response

AI Incident Response Policy Template

A practical response policy for identifying AI-related harm or control failures, getting the right people into the decision, containing the issue, reviewing notification obligations, and restoring service with evidence and follow-through.

Updated

Generic reusable template · Replace bracketed fields · Review notification obligations for each incident

Start here — Assign owners before an incident
  • One incident commander: Name a primary and backup who can coordinate work, set incident cadence, and record decisions.
  • Contain first, preserve evidence: Restrict the affected capability while preserving logs, prompts, outputs, configurations, and decision history.
  • Review each notification duty: Legal, privacy, and contract owners assess applicable laws, jurisdictions, data, and agreements; this template sets no universal deadline.
  • Restore through gates: Validate the fix, stage the return, define rollback criteria, and monitor more closely until the incident is closed.
01 · Purpose, scope, and records

Make response responsibilities usable before an incident

Use this policy for AI systems that [Organization] develops, operates, buys, or embeds in products and workflows. Adapt the scope, roles, severity criteria, and retention rules to the organization and the systems it uses.

Copy-paste policy section
Policy ownership and incident record
Policy owner: [Name / role] Effective date: [YYYY-MM-DD] Approving authority: [Committee / executive role] Review cadence: [At least annually and after a material incident] Incident intake channel: [Email / hotline / ticket queue] Incident record system: [Restricted system and record ID format] Record custodian: [Name / role] Purpose and scope [Organization] will identify, assess, contain, and learn from suspected or confirmed incidents involving AI systems. This policy covers systems used by [employees / contractors / business units], including [generative AI, prediction, ranking, decision support, autonomous actions, and vendor-embedded features]. It applies to safety, security, privacy, reliability, rights, compliance, and material operational events, including near misses. Every report must be logged promptly, even if facts are incomplete. The incident commander will maintain a time-stamped decision log, preserve relevant evidence, record the affected system and people or processes, and document severity changes, approvals, notifications, recovery gates, and corrective actions. Restrict records to authorized responders and apply [Organization]'s retention, legal hold, privacy, and access-control rules. Do not place unnecessary personal or sensitive data in the incident record.
02 · Classification and escalation triggers

Classify by impact and escalate when facts are uncertain

Use the highest credible severity while impact is being assessed. Severity may increase or decrease as evidence develops; record the rationale, time, and person approving each change.

SeverityIllustrative impactEscalation trigger and response
SEV 1 · CriticalCredible risk of death or serious injury; widespread or irreversible harm; major sensitive-data exposure; unauthorized consequential decisions; active compromise with broad reach.Immediately page the incident commander and executive sponsor; convene security, privacy, legal, system owner, and communications. Consider disabling the affected AI capability while scope is assessed.
SEV 2 · HighMaterial harm or customer impact; repeated unsafe outputs; significant data or access issue; impaired regulated or essential workflow; likely contractual or legal implications.Escalate promptly to the commander and relevant specialists. Restrict the affected use, assign an impact assessment, and set a frequent update cadence.
SEV 3 · ModerateLimited or contained impact; isolated inaccurate or policy-violating output; near miss; localized service or monitoring failure with a viable human check.Notify the system owner and designated security, privacy, or compliance contact as relevant. Track remediation and reassess if scope or recurrence changes.
SEV 4 · Low / observationNo confirmed harm or exposure; low-impact anomaly, blocked attempt, or control weakness detected before use.Log and route to the accountable owner for triage. Promote the incident if new facts indicate impact, repetition, or a control failure.

Escalate regardless of initial severity when there may be personal or sensitive data, a vulnerable or protected population, external customer impact, an unsafe autonomous action, a compromised credential, a vendor or subprocessor event, a legal hold, a regulator or media inquiry, or uncertainty about notification duties. Localize examples and thresholds with [Organization]'s risk owners.

03 · Roles and decision authority

Name primary and backup responders

Maintain an on-call directory with contact methods and alternates. One person may hold multiple functions in a small team, but record which decision they are making and when an independent review is required.

RolePrimary / backupResponsibilities and decision authority
Incident commander[Name / role] · Backup: [Name / role]Owns severity, response priorities, cadence, assignments, and decision log. May direct temporary containment under this policy and escalate unresolved risk to the executive sponsor.
AI / system owner[Name / role] · Backup: [Name / role]Identifies system behavior, versions, integrations, affected use cases, and safe rollback or fallback. Executes approved operational changes and validates technical recovery.
Security lead[Name / role] · Backup: [Name / role]Leads compromise investigation, access and token controls, forensics, and security containment; advises on evidence integrity and threat status.
Privacy lead[Name / role] · Backup: [Name / role]Assesses personal-data exposure, affected people, data flows, minimization, and privacy obligations; recommends protective steps and notification analysis.
Legal counsel[Name / role] · Backup: [Name / role]Reviews legal holds, privilege where appropriate, contracts, jurisdiction-specific duties, regulatory engagement, and proposed external statements.
Communications lead[Name / role] · Backup: [Name / role]Prepares consistent internal and external updates with subject-matter owners; releases communications only through the designated approval path.
Executive sponsor[Name / role] · Backup: [Name / role]Accepts or rejects material residual risk, approves exceptional business tradeoffs and resource priorities, and resolves disputes that exceed the commander's delegated authority.
Response setup
Decision and escalation rules
Incident commander may: [Pause feature / restrict users / invoke fallback / convene response team] System owner may: [Execute approved containment and rollback steps] Security lead may: [Revoke credentials / isolate affected infrastructure under emergency procedure] Executive approval required for: [Residual risk acceptance / broad restart / external position] If a primary responder is unavailable: Contact the listed backup; if both are unavailable, escalate to [role / on-call channel]. If authority is disputed or harm may continue: Maintain or expand the safest reversible containment and escalate to [executive role].
04 · Containment and evidence

Limit further impact while preserving what responders need

Choose proportionate, reversible controls where practical. The incident commander records what was changed, by whom, when, the reason, and how the change can be verified or reversed.

WorkstreamResponse stepsOwner / evidence
Preserve evidenceCapture relevant prompts, inputs, outputs, model and system versions, configuration, retrieval sources, logs, user reports, timestamps, and decision history. Preserve originals and record collection method, access, time zone, and chain of custody where needed.[Forensic owner] · Evidence location and references: [Links / IDs]
Limit AI behaviorDisable or pause the affected AI feature, tool call, model route, or workflow; roll back to a known-good version if safe; block the affected use case or population; add human review for consequential outputs.[System owner] · Change and validation record: [Ticket / timestamp]
Secure accessRevoke or rotate exposed credentials, API keys, tokens, and service accounts; restrict privileged access; review recent authentication and data access; preserve logs before changing short-lived evidence.[Security lead] · Access actions: [Record]
Protect people and operationsStop affected automated decisions or actions; identify impacted users, customers, records, and downstream processes; provide a manual fallback with an accountable reviewer and instructions.[Business owner] · Population and fallback: [Record]
Coordinate suppliersContact the vendor through the agreed incident channel, request preservation and relevant facts, and coordinate isolation or rollback without surrendering control of the incident record.[Vendor owner] · Contact and response: [Record]

Do not delete or overwrite data needed to understand the event. Apply legal hold and retention guidance from counsel, and use approved secure channels for sensitive evidence. Record containment gaps and interim safeguards when an immediate control cannot be applied.

05 · Notification and decision record

Assess audiences and duties for the facts of this incident

There is no single notification deadline for every AI incident. Legal and privacy owners must assess applicable laws, affected jurisdictions and people, data types, contracts, customer commitments, and regulator requirements. Record the analysis and the source of each deadline before communicating where practicable.

AudienceWhen to assessOwner and approval
Internal leadership and response teamsEscalate according to severity and trigger criteria; share verified facts, uncertainty, containment, and next update time.Incident commander; executive sponsor for material risk or resource decisions.
Employees and affected business unitsWhen users need to stop a workflow, use a manual fallback, preserve records, or answer questions consistently.Communications lead with system and business owners; legal review as needed.
Customers, users, or impacted individualsAssess potential harm, data exposure, contractual commitments, applicable law, and useful protective steps for affected people.Privacy and legal leads with the accountable customer or business owner.
Vendors, customers, and other counterpartiesReview incident clauses, service terms, data-processing agreements, security addenda, and cooperation requirements.Vendor / contract owner with legal and security review.
Regulators, law enforcement, or public channelsDetermine whether a law, regulator request, safety concern, or approved communications plan requires or supports engagement.Legal counsel leads regulator or law-enforcement contact; communications lead coordinates public statements.
Required decision record
Notification assessment for [Incident ID]
Incident facts and current uncertainty: [Summary / evidence links] Affected systems, data, people, and jurisdictions: [Details] Applicable law / contract / policy sources reviewed: [References] Potential audiences and required or voluntary notices: [List] Deadline or trigger identified and source: [Date, time zone, rule, and calculation] Decision: [Notify / no notice / defer pending facts / seek specialist advice] Decision rationale and approvers: [Names / roles / timestamp] Message owner, reviewer, channel, and delivery evidence: [Details] Next reassessment trigger: [New evidence / legal review / time]

When a deadline may apply, escalate immediately to counsel and the privacy lead so they can calculate and track the relevant clock. This template does not establish a legal deadline or replace jurisdiction-specific or contract-specific advice.

06 · Recovery and restoration

Restore only after the control owner can explain why it is safe

Recovery is a documented decision. The incident commander and system owner may propose restoration; any required security, privacy, legal, business, or executive approver confirms the gates appropriate to severity and impact.

GateEvidence required before proceedingOwner / approval
Containment stableImmediate threat, unsafe behavior, or uncontrolled exposure is stopped; access and affected workflows are understood; manual fallback remains available.[Incident commander] · [Approver]
Cause and fix understoodKnown cause or bounded hypothesis, corrective change, residual uncertainty, and remaining risks are documented. Vendor dependencies and affected outputs or decisions are addressed.[System owner / security lead] · [Approver]
Validation passedTests cover the triggering failure, relevant edge cases, security and privacy controls, expected model behavior, and human review. Record test data, results, limitations, and independent checks as required.[Test owner] · [Reviewer]
Staged restoration approvedStart with a limited scope, defined success and stop thresholds, named rollback authority, and a communication plan for affected users.[Business owner / commander] · [Approver]
Heightened monitoring activeAssign monitoring owner, frequency, signals, escalation channel, coverage window, and end condition for heightened observation.[Monitoring owner] · [Review date]
Recovery decision
Restart authorization for [System / feature]
Incident ID and severity: [ID / severity] Containment verified by: [Name / role / date] Fix and validation evidence: [Change / test references] Open risk and safeguards: [Details] Stage 1 scope and start: [Population / date] Success and stop thresholds: [Metrics / limits] Rollback authority and procedure: [Name / role / steps] Heightened monitoring owner and end condition: [Details] Approvers and decision time: [Names / roles / timestamp]
07 · Post-incident review

Turn the incident record into assigned improvements

Schedule a review after immediate response stabilizes. As an internal starting target, open a SEV 1 review within 5 business days of stabilization, a SEV 2 review within 10 business days, and review lower severity incidents at the next monthly governance meeting; adjust these targets for [Organization]. Conduct a separate safety or legal review when needed. Focus on how the system and response behaved rather than assigning blame.

Review areaQuestions and evidence
Timeline and impactWhen did the event begin, become detectable, get reported, get contained, and resolve? Which systems, decisions, data, people, and downstream workflows were affected? What remains uncertain?
Root cause and contributing factorsWhat technical, data, model, vendor, workflow, monitoring, access, or governance conditions contributed? Which assumptions or safeguards failed or were missing?
Response effectivenessDid classification and escalation happen at the right time? Were roles and backups reachable? Did evidence preservation, containment, manual fallback, notifications, and recovery gates work as intended?
Learning and preventionWhat should change in design, testing, monitoring, contracts, training, policy, or response exercises? What near misses indicate broader exposure?
Corrective actionOwnerDue dateCompletion evidence / approver
[Action, priority, and interim safeguard][Name / role][YYYY-MM-DD][Evidence location / reviewer]
[Action, priority, and interim safeguard][Name / role][YYYY-MM-DD][Evidence location / reviewer]
Closure record
Post-incident review for [Incident ID]
Review target based on severity: [SEV 1 within 5 business days / SEV 2 within 10 business days / lower severity at monthly review, or Organization's approved target] Review date and participants: [Date / roles] Incident timeline and impact summary: [Link / summary] Root cause and contributing factors: [Findings] Containment and recovery effectiveness: [Findings] Notification decisions and lessons: [Findings] Corrective actions, owners, and due dates: [Action tracker] Residual risk accepted by: [Name / role / date] Evidence custodian and retention rule: [Details] Closure approved by: [Incident commander / executive role / date] Policy, system, or training updates required: [Owner / due date]
FAQ

Questions teams ask before adopting the template

What should count as an AI incident?
Treat suspected events as incidents when an AI system may have contributed to harm, mishandled data, produced materially unsafe outputs, operated outside approved use, or suffered a security, availability, or control failure. Log near misses so patterns can be identified.
Does this policy specify a universal notification deadline?
No. Legal, privacy, and contract owners need to assess applicable laws, jurisdictions, affected people, data types, and agreements for each event. Record the source, calculation, decision, and any reassessment trigger.
Who decides whether to restore an AI feature?
The incident commander and system owner recommend restoration after the gates are met. Required security, privacy, legal, business, or executive approvers depend on severity and residual risk; record the decision and rollback authority.
Does this replace legal or security advice?
No. It is an operational starting point. Adapt it with qualified legal, privacy, security, safety, and compliance reviewers for the organization's systems, contracts, and jurisdictions.

Make incident response part of AI governance.

Assign responders, test the escalation path, and adapt this policy to the AI systems, contracts, and jurisdictions your organization actually uses.

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