AI INCIDENT RESPONSE PLAN
[ORGANIZATION NAME]
DOCUMENT CONTROL
| Field | Information |
|---|---|
| Plan Owner | [NAME, TITLE] |
| Approved By | [NAME, TITLE] |
| Effective Date | [DATE] |
| Version | [VERSION] |
| Last Tested | [DATE] |
| Next Review | [DATE] |
1. INTRODUCTION
1.1 Purpose
This AI Incident Response Plan establishes procedures for detecting, responding to, and recovering from incidents involving artificial intelligence systems.
1.2 Scope
This Plan covers:
- All AI systems operated by [ORGANIZATION NAME]
- AI-specific incidents as defined in Section 2
- Integration with general incident response
1.3 Objectives
- Minimize harm from AI incidents
- Ensure rapid and effective response
- Meet regulatory notification requirements
- Learn and improve from incidents
- Maintain stakeholder trust
2. AI INCIDENT DEFINITION
2.1 What Constitutes an AI Incident
An AI incident is an event involving AI systems that:
☐ Causes harm to individuals or groups
- Physical, psychological, or financial harm
- Discrimination or unfair treatment
- Privacy violations
☐ Involves significant system failures
- Major accuracy degradation
- Widespread incorrect outputs
- System unavailability affecting operations
☐ Indicates security compromise
- Adversarial attacks
- Data poisoning
- Model theft or extraction
☐ Violates laws or policies
- Regulatory non-compliance
- Policy violations
- Ethical breaches
☐ Threatens organizational reputation
- Public incidents
- Media attention
- Stakeholder complaints
2.2 AI Incident Categories
| Category | Examples |
|---|---|
| Bias/Fairness | Discriminatory outcomes discovered, disparate impact, unfair treatment |
| Accuracy/Performance | Model failures, incorrect predictions, hallucinations causing harm |
| Safety | Harmful outputs, dangerous recommendations, physical safety risks |
| Security | Adversarial attacks, prompt injection, data breaches, model theft |
| Privacy | Unauthorized data exposure, re-identification, consent violations |
| Compliance | Regulatory violations, documentation failures, transparency failures |
| Ethical | Manipulation, autonomy violations, value alignment failures |
2.3 Severity Levels
| Level | Definition | Examples | Response Time |
|---|---|---|---|
| Critical | Ongoing significant harm; regulatory reporting required | Widespread discrimination, data breach, safety incident | Immediate |
| High | Potential for significant harm; urgent attention needed | Bias discovered, major system failure | 4 hours |
| Medium | Moderate impact; requires prompt attention | Performance degradation, isolated complaints | 24 hours |
| Low | Minor impact; routine handling | Minor accuracy issues, documentation gaps | 72 hours |
3. INCIDENT RESPONSE TEAM
3.1 AI Incident Response Team (AI-IRT)
| Role | Primary | Alternate | Contact |
|---|---|---|---|
| Incident Commander | [NAME] | [NAME] | [CONTACT] |
| AI Technical Lead | [NAME] | [NAME] | [CONTACT] |
| Legal/Compliance | [NAME] | [NAME] | [CONTACT] |
| Communications | [NAME] | [NAME] | [CONTACT] |
| Privacy Officer | [NAME] | [NAME] | [CONTACT] |
| Business Representative | [NAME] | [NAME] | [CONTACT] |
| Security Lead | [NAME] | [NAME] | [CONTACT] |
3.2 Roles and Responsibilities
Incident Commander:
- Overall incident management
- Resource coordination
- Decision authority
- External communication approval
AI Technical Lead:
- Technical investigation
- Root cause analysis
- Remediation implementation
- Technical recommendations
Legal/Compliance:
- Regulatory assessment
- Notification requirements
- Legal risk evaluation
- Documentation review
Communications:
- Internal communications
- External communications (with approval)
- Media management
- Stakeholder updates
Privacy Officer:
- Privacy impact assessment
- Data breach determination
- Privacy notifications
- Data subject rights
Business Representative:
- Business impact assessment
- Customer considerations
- Operational decisions
- Business continuity
Security Lead:
- Security incident aspects
- Forensics coordination
- Security controls
3.3 Escalation Matrix
| Severity | Notified Immediately | Notified Within 1 Hour | Notified Within 24 Hours |
|---|---|---|---|
| Critical | Incident Commander, AI Lead, Legal, Executive | Full AI-IRT, CISO, CEO | Board (if required) |
| High | Incident Commander, AI Lead | Legal, Privacy, Business | Executive |
| Medium | AI Lead | Business, Compliance | Incident Commander |
| Low | System Owner | AI Lead | As needed |
4. INCIDENT RESPONSE PHASES
4.1 Phase 1: Detection and Identification
Objectives:
- Identify potential incidents quickly
- Determine if AI-specific response needed
- Initial severity assessment
Detection Sources:
☐ Automated monitoring alerts
☐ User/customer reports
☐ Employee reports
☐ Third-party notifications
☐ Regulatory inquiries
☐ Media/social media
☐ Audit findings
☐ Periodic reviews
Initial Assessment Checklist:
☐ Is this an AI-related incident?
☐ What AI system(s) are involved?
☐ What is the apparent impact?
☐ Is harm ongoing?
☐ What is the initial severity?
☐ Who needs to be notified?
Actions:
1. Log incident in tracking system
2. Assign initial severity
3. Notify appropriate personnel
4. Preserve evidence
5. Begin documentation
4.2 Phase 2: Containment
Objectives:
- Stop ongoing harm
- Prevent incident expansion
- Preserve evidence
Containment Actions by Category:
| Category | Immediate Actions |
|---|---|
| Bias/Fairness | Flag affected decisions for review; consider pausing system; notify affected teams |
| Accuracy | Enable human review; reduce automation; alert users |
| Safety | Disable harmful functionality; implement warnings; escalate to safety team |
| Security | Isolate system; revoke compromised access; engage security team |
| Privacy | Stop further exposure; secure affected data; preserve logs |
| Compliance | Document current state; preserve evidence; engage legal |
Containment Decision Matrix:
| Severity | System Suspension | Communication | Leadership |
|---|---|---|---|
| Critical | Immediate | Immediate prep | Immediate |
| High | Consider | Prepare | Within hours |
| Medium | Usually no | As needed | Routine |
| Low | No | Minimal | Routine |
Documentation Requirements:
- Time of containment actions
- Actions taken and by whom
- Decision rationale
- Impact of containment
4.3 Phase 3: Investigation
Objectives:
- Determine root cause
- Assess full impact
- Identify affected parties
- Gather evidence
Investigation Activities:
☐ Technical Investigation
- Analyze system logs
- Review model behavior
- Examine data inputs
- Test hypotheses
- Identify failure points
☐ Impact Assessment
- Determine affected individuals/groups
- Quantify harm
- Assess scope (time, volume)
- Evaluate ongoing risks
☐ Root Cause Analysis
- What happened?
- Why did it happen?
- What controls failed?
- Was this foreseeable?
AI-Specific Investigation Considerations:
| Incident Type | Investigation Focus |
|---|---|
| Bias | Training data analysis; fairness metric review; affected group identification |
| Accuracy | Model drift analysis; input data review; edge case identification |
| Security | Attack vector analysis; compromised components; adversarial input analysis |
| Privacy | Data flow analysis; exposure scope; re-identification risk |
Evidence Preservation:
☐ System logs
☐ Model versions
☐ Training data snapshots
☐ Input/output samples
☐ Configuration records
☐ User reports
☐ Timeline documentation
4.4 Phase 4: Notification
Internal Notifications:
| Severity | Notify |
|---|---|
| Critical | Executive team, Board (if warranted), all AI-IRT |
| High | Senior management, all AI-IRT |
| Medium | Relevant managers, core AI-IRT |
| Low | System owner, AI Lead |
External Notification Requirements:
| Trigger | Notification Required | Timeframe | To Whom |
|---|---|---|---|
| Personal data breach (GDPR) | Yes | 72 hours | Supervisory Authority |
| Personal data breach (US State) | Per state law | Per law | AG/Affected |
| Serious AI incident (EU AI Act) | Yes | Per regulation | Authority |
| Sector-specific | Per regulation | Per regulation | Regulator |
| Contractual | Per contract | Per contract | Customer |
Notification Content:
☐ Nature of incident
☐ Systems/data involved
☐ Approximate impact
☐ Actions taken
☐ Next steps
☐ Contact information
Communication Guidelines:
- Facts only, no speculation
- Approved messaging
- Consistent across channels
- Appropriate level of detail
- Legal review for external
4.5 Phase 5: Remediation
Objectives:
- Fix the root cause
- Restore normal operations
- Prevent recurrence
Remediation Actions by Category:
| Category | Typical Remediation |
|---|---|
| Bias | Model retraining; data correction; fairness improvements; review affected decisions |
| Accuracy | Model update; threshold adjustment; additional testing; monitoring enhancement |
| Security | Patch vulnerabilities; strengthen defenses; implement detection |
| Privacy | Data deletion; consent refresh; privacy control enhancement |
| Compliance | Documentation update; process correction; control implementation |
Remediation Process:
- Develop remediation plan
- Prioritize actions
- Obtain approvals
- Implement fixes
- Test thoroughly
- Deploy with monitoring
- Verify effectiveness
Remediation for Affected Parties:
☐ Identify affected individuals
☐ Determine appropriate remedy
☐ Communicate with affected parties
☐ Implement remedies
☐ Document remediation
4.6 Phase 6: Recovery
Objectives:
- Return to normal operations
- Restore stakeholder confidence
- Verify remediation effectiveness
Recovery Checklist:
☐ Root cause addressed
☐ Remediation verified effective
☐ Monitoring enhanced
☐ Systems returned to full operation
☐ Stakeholders informed
☐ Documentation complete
Recovery Criteria:
| Criteria | Verified |
|---|---|
| Incident contained | ☐ Yes |
| Root cause fixed | ☐ Yes |
| Testing completed | ☐ Yes |
| Monitoring in place | ☐ Yes |
| Stakeholder communication complete | ☐ Yes |
| Documentation complete | ☐ Yes |
4.7 Phase 7: Post-Incident Review
Objectives:
- Learn from incident
- Improve processes
- Prevent recurrence
Post-Incident Review Meeting:
- Timing: Within [X] days of incident closure
- Participants: AI-IRT, relevant stakeholders
- Duration: [X] hours
Review Agenda:
- Incident timeline review
- What worked well
- What could be improved
- Root cause discussion
- Lessons learned
- Action items
Post-Incident Report Contents:
☐ Executive summary
☐ Incident description
☐ Timeline
☐ Impact assessment
☐ Root cause analysis
☐ Response evaluation
☐ Lessons learned
☐ Recommendations
☐ Action items
Action Item Tracking:
| Action | Owner | Deadline | Status |
|---|---|---|---|
| [ACTION] | [OWNER] | [DATE] | [STATUS] |
5. COMMUNICATION TEMPLATES
5.1 Internal Alert Template
Subject: AI Incident Alert - [SEVERITY] - [SYSTEM NAME]
Incident ID: [ID]
Severity: [LEVEL]
Reported: [DATE/TIME]
System: [SYSTEM NAME]
Summary:
[Brief description]
Current Status:
[Status]
Actions Taken:
[Actions]
Next Steps:
[Steps]
Contact:
[Incident Commander contact]
5.2 External Notification Template
[Use with Legal approval]
Subject: Notice Regarding [DESCRIPTION]
Dear [RECIPIENT],
We are writing to inform you of an incident involving [DESCRIPTION].
What Happened:
[Description]
What Information Was Involved:
[Information types]
What We Are Doing:
[Actions]
What You Can Do:
[Recommendations]
For More Information:
[Contact]
We sincerely regret any concern this may cause.
[Signature]
6. REGULATORY NOTIFICATION REQUIREMENTS
6.1 EU AI Act
Serious Incident Definition: Per Article 73
Notification Required: Yes, for serious incidents
Timeframe: Per regulation
Notify: Market surveillance authority
6.2 Data Protection
GDPR: 72 hours to supervisory authority
US State Laws: Per state requirements
Documentation: Record all breaches
6.3 Sector-Specific
[ADD SECTOR-SPECIFIC REQUIREMENTS]
7. PLAN MAINTENANCE
7.1 Testing
| Test Type | Frequency | Last Test | Next Test |
|---|---|---|---|
| Tabletop exercise | Annual | [DATE] | [DATE] |
| Functional test | Annual | [DATE] | [DATE] |
| Full simulation | Biennial | [DATE] | [DATE] |
7.2 Review and Update
This Plan is reviewed:
- Annually
- After significant incidents
- After regulatory changes
- After organizational changes
7.3 Training
| Audience | Training | Frequency |
|---|---|---|
| AI-IRT members | Full plan training | Annual |
| System owners | Incident reporting | Annual |
| All employees | Awareness | Annual |
APPENDICES
Appendix A: Contact List
[COMPLETE CONTACT INFORMATION]
Appendix B: Incident Log Template
[INCIDENT LOGGING TEMPLATE]
Appendix C: Checklist Summary
[QUICK REFERENCE CHECKLISTS]
APPROVAL
| Role | Name | Signature | Date |
|---|---|---|---|
| Plan Owner | |||
| Legal | |||
| Executive Sponsor |
This AI Incident Response Plan is a living document. All personnel should be familiar with their roles and responsibilities.
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