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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:

  1. Develop remediation plan
  2. Prioritize actions
  3. Obtain approvals
  4. Implement fixes
  5. Test thoroughly
  6. Deploy with monitoring
  7. 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:

  1. Incident timeline review
  2. What worked well
  3. What could be improved
  4. Root cause discussion
  5. Lessons learned
  6. 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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AI INCIDENT RESPONSE PLAN

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