Attachment K.docx

SCEO Privacy and Security Risk Assessment energy.gov/scep

IRA SECTION 50121: Home Efficiency Rebates

IRA SECTION 50121: Home Efficiency Rebates SCEO Privacy and Security Risk Assessment July 2025

Table of Contents

Tables

Introduction The Inflation Reduction Act (IRA) of 2022 authorizes the United States Department of Energy (DOE) to carry out two Home Energy Rebate programs – the Home Efficiency Rebates (HOMES) program and the Home Electrification and Appliance Rebates (HEAR) program. South Carolina has been granted a total of $137.2 million for these programs, with $68.7 million allocated for the HOMES program.

The South Carolina Energy Office (SCEO), a division of the South Carolina Office of Regulatory Staff, was directed by the IRA to carry out these programs. The SCEO’s serves as the principal energy planning entity for the state, and encourages energy efficiency, renewable energy, and clean transportation through a variety of initiatives. HOMES and HEAR align with this mission to promote energy efficiency and provide assistance to South Carolina residents to support energy-saving improvements.

In South Carolina, the combined impact of both HOMES and HEAR will leverage energy efficiency measures to help lower residential energy costs, reduce overall energy demand, and contribute to a more resilient energy grid. By reducing household energy expenditures, these programs will support sustainable energy practices while benefiting the state’s broader energy infrastructure.

The SCEO has established the following goals for the state’s HOMES and HEAR Programs:

(1) Provide Holistic Improvements to Residents’ Lives: Ensure education efforts, technology systems, contractor practices, program integrations, and rebate levels are designed to meet diverse needs while lowering household energy costs;

(2) Provide Statewide Program Accessibility: Encourage program participation across all regions of South Carolina through broad outreach, education, and targeted partnerships to support hard-to-reach populations;

(3) Distribute Funds Efficiently and Drive Tangible Impact: Promote program stewardship and drive impact by distributing funds efficiently, including by leveraging household and building-wide categorical eligibility; and

(4) Leverage Existing Infrastructure and Partnerships: Build upon existing energy efficiency and workforce development efforts, integrating them with utility and other statewide programs to maximize energy savings and support long-term reductions in energy costs for South Carolinians.

In alignment with the total proportion of low-income households across the state, South Carolina intends to allocate at least 39.9% of its rebate funds to the state’s low-income households (those with less than 80% of area median income (AMI)[footnoteRef:2]). Additionally, it will allocate at least 10% of the rebate funds to low-income multifamily buildings. [2: “Area median income” is the “value calculated by household size of the median income of the area in which the individual or family resides, as reported by the Department of Housing and Urban Development.” United States Department of Energy (published on October 13, 2023), Program Requirements & Application Instructions. Available at: https://www.energy.gov/sites/default/files/2023-10/home-energy-rebate-programs-requirements-and-application-instructions_10-13-2023.pdf.]

SCEO will launch its HOMES and HEAR Programs in early 2026, with a targeted soft launch followed by a full statewide launch.

Privacy and Security Risk Assessment Plan Overview Context and Purpose This document outlines the comprehensive approach to managing the privacy and security aspects of the HOMES program. The goal of this plan is to provide a structured framework for protecting the privacy and security of consumer data throughout the program. It aims to ensure that all data, such as personally identifiable information (PII), financial details, and energy usage data, is securely handled in compliance with state and federal privacy regulations.

To administer HOMES, South Carolina will work with a third-party implementer to establish both a Rebate Processing Platform and a Payment Processing Platform. The Rebate Processing Platform will securely manage consumer applications, while the Payment Processing Platform will disburse funds in accordance with program guidelines. Both platforms will operate under defined security protocols to protect sensitive data.

The policies in this document align with the standards established by the South Carolina Division of Information Security (SCDIS) and comply with guidelines provided by DOE. By adhering to these standards, South Carolina seeks to establish a security framework that safeguards consumer data, builds trust in the program, and supports the overall success of the HOMES program. As the program evolves in size and scope, these policies will be reviewed and updated regularly to reflect changes in regulatory requirements, technology, and program operations. Privacy and security procedures will remain a central operational component of the HOMES program.

Roles and Responsibilities SCEO will provide overall program oversight and governance for the HOMES program. The agency will manage the receipt of grant funds from DOE and will sponsor program implementation, ensuring that all activities comply with both state and federal requirements. In addition, SCDIS will define the program’s technology standards, including required security measures and approved infrastructure.

The third-party implementer will manage the vendors responsible for the Rebate Processing Platform and Payment Processing Platform. This includes oversight of system development and maintenance, application portals, rebate processing, and disbursement activities. The implementer will be responsible for ensuring compliance with all privacy and security requirements across both platforms.

SCEO will also engage an independent third-party auditor to conduct a formal security policy review as outlined by DOE guidance. Vendors operating the rebate and payment platforms will store PII as necessary for program operations. The state will not alter any PII collected.

Selected Rebate Processing Platform – Rebate Processing Application Development and Maintenance Responsibilities:

· Develop the application and the security protocols that handle all portal interactions and rebate processing, ensuring it meets the required security standards.

· Create and maintain an incident response plan, including procedures for detecting, reporting, and responding to security incidents.

· Conduct regular drills to test the incident response plan and update it based on lessons learned and evolving threats.

· Ensure that all security incidents are documented and addressed promptly, with measures taken to prevent future occurrences.

Selected Payment Processing Platform – Integrated Financial Solutions Provider Responsibilities:

· Provide SCEO with a fully integrated solution and security protocols for disbursement, including integrated banking, enhanced checking solutions, comprehensive exception handling, increased security features, and auto-reconciliation.

· Develop and maintain an incident response plan, including procedures for detecting, reporting, and responding to security incidents.

· Conduct regular drills to test the incident response plan and update it based on lessons learned and evolving threats.

· Ensure that all security incidents are documented and addressed promptly, with measures taken to prevent future occurrences.

Depending on the outcome of the procurement process, the same vendor may be selected to serve as both the Rebate Processing Platform provider and the Payment Processing Platform provider. If a single vendor is awarded both roles, that vendor will be responsible for maintaining the operations, security, and incident response protocols across both systems, ensuring alignment with the outlined responsibilities and with SCDIS and DOE standards and requirements.

Data Non-Sale Assurance No entity involved in administering the HOMES program will sell participant data. All data collected will be used exclusively for rebate processing, program operations, or related energy efficiency initiatives. Data will be protected using encryption, access controls, and regular audits. Any sharing of data will be limited to operational needs and will follow all applicable privacy and security standards.

Guide to The Privacy and Security Blueprint Plan This document provides a structured blueprint for managing the privacy and security aspects of the Home Energy Rebate Programs. The following sections outline the plan's key components, aligned with applicable federal and state standards to support secure and compliant program implementation:

(1) Rationale for Categorizing the System: Explains how information systems are categorized based on confidentiality, integrity, and availability, using guidance from NIST SP 800-53. It also clarifies that no PII gathered from the program will be sold to third parties, in alignment with SCEO's privacy and security standards.

(2) Methodology for Determining Risk: Describes the risk assessment process, including data type identification, risk source evaluation, impact and likelihood assessments, and mitigation strategies. This section outlines a thorough approach aligned with NIST Special Publications.

(3) Risks Associated with Data Sharing: Identifies potential risks related to internal and external data sharing, including breaches, integrity failures, and availability concerns. It also details the controls used to mitigate these risks, such as encryption, access controls, and audit logging.

(4) Compliance with SCDIS Privacy and Security Standards: Details the program’s alignment with SCDIS policies through staff training, adherence to approved standards, and regular policy reviews to stay current with evolving threats.

(5) Audit Readiness and Third-Party Audits: Confirms that the HOMES program maintains documentation and is prepared for audit requirements, including those from DOE. While DOE does not require a third-party audit prior to the program going live, it does require a third-party audit be conducted at least once every three years.

(6) Continuous Monitoring and Incident Response: Outlines the tools and procedures used for continuous monitoring, outlines the incident response plan, and emphasizes the importance of regular drills and plan updates to ensure readiness.

Rationale for Categorizing the System In alignment with South Carolina’s adoption of NIST Special Publication 800-53, the information systems supporting the HOMES programs are categorized based on potential impacts to organizational operations, assets, and individuals in the event of a security incident. FIPS Publication 199 provides the definitions for categorizing impact levels for confidentiality, integrity, and availability.

SCDIS defines statewide technology standards and oversees agency compliance. Following FIPS 199 Section 3, SCDIS assigns impact levels—low, moderate, or high—to each of the three security objectives based on potential adverse effects. This categorization informs the level of security controls to apply to each system.

Per SCDIS policy, data owners must maintain a system inventory and complete impact-based system categorizations consistent with NIST 800-53. This process ensures the efficient use of resources and helps prevent under-protection of sensitive data and critical functions.

Confidentiality Confidentiality refers to ensuring that information is not disclosed to unauthorized individuals, systems, or processes. Under FIPS 199, a loss of confidentiality may result in adverse effects ranging from limited to catastrophic, depending on the nature of the information involved.

In the context of the Home Energy Rebate Programs, protecting PII is essential. Unauthorized disclosure of participant data could lead to privacy violations, identity theft, and reputational harm to the program. In accordance with SCDIS policy, PII collected through the program will not be shared with unapproved third parties or sold for financial gain. Based on the nature of the data involved and the consequences of unauthorized disclosure, the confidentiality impact level is assessed as moderate to high.

Integrity Integrity involves protecting information from unauthorized modification or destruction and ensuring its accuracy and reliability. FIPS 199 defines a loss of integrity as the unauthorized alteration or deletion of information, which may negatively affect operations, assets, or individuals.

For the Home Energy Rebate Programs, maintaining data integrity is critical for accurate rebate processing and financial management. Any compromise to the integrity of the system could result in miscalculated payments, loss of funds, or operational disruption. As such, the integrity impact level is categorized as moderate to high.

Availability Availability refers to the timely and reliable access to and use of information and systems. FIPS 199 defines a loss of availability as a disruption in access to or use of systems that could adversely affect performance or outcomes.

The Home Energy Rebate Programs rely on the continuous availability of information systems to manage applications, issue rebates, and communicate with participants. Interruptions in system availability could cause delays, reduce program effectiveness, and frustrate participants. Given the critical nature of system uptime, the availability impact level is considered high.

Overall System Categorization Based on the assessments of confidentiality, integrity, and availability, the overall categorization of the information systems supporting the Home Energy Rebate Programs is determined to be moderate to high. This reflects the moderate to high impact levels for confidentiality and integrity, along with the high impact level for availability. This categorization ensures that appropriate and robust security measures are applied to manage the program’s risk profile. The final determination will be informed by the initial risk assessment.

The Implementer, in collaboration with the selected Rebate Processing Platform vendor, will apply this categorization to guide security planning and ensure that the system used for portal interactions and rebate processing is developed and maintained in compliance with the requirements of SCDIS and the DOE.

This structured and standards-aligned approach to system categorization is critical for protecting sensitive data, maintaining public trust, and supporting the successful implementation and operation of the Home Energy Rebate Programs.

In accordance with DOE guidance, SCEO will submit the program’s security policy along with the finalized system categorization and detailed assessment documentation included as an appendix.

Table 1 summarizes the potential impact definitions based on NIST800-53 and FIPS 199 for each security objective: confidentiality, integrity, and availability.

Potential Impact

Confidentiality Preserving authorized restrictions on information access and disclosure, including means for protecting personal privacy and proprietary information.

[44 U.S.C., SEC. 3542]

The unauthorized disclosure of information could be expected to have a limited adverse effect on organizational operations, organizational assets, or individuals The unauthorized disclosure of information could be expected to have a serious adverse effect on organizational operations, organizational assets, or individuals.

The unauthorized disclosure of information could be expected to have a severe or catastrophic adverse effect on organizational operations, organizational assets, or individuals.

Integrity Guarding against improper information modification or destruction, and includes ensuring information non-repudiation and authenticity.

[44 U.S.C., SEC. 3542]

The unauthorized modification or destruction of information could be expected to have a limited adverse effect on organizational operations, organizational assets, or individuals.

The unauthorized modification or destruction of information could be expected to have a serious adverse effect on organizational operations, organizational assets, or individuals.

The unauthorized modification or destruction of information could be expected to have a severe or catastrophic adverse effect on organizational operations, organizational assets, or individuals.

Availability Ensuring timely and reliable access to and use of information.

[44 U.S.C., SEC. 3542]

The disruption of access to or use of information or an information system could be expected to have a limited adverse effect on organizational operations, organizational assets, or individuals.

The disruption of access to or use of information or an information system could be expected to have a serious adverse effect on organizational operations, organizational assets, or individuals.

The disruption of access to or use of information or an information system could be expected to have a severe or catastrophic adverse effect on organizational operations, organizational assets, or individuals.

Table 1: Potential Impact Definitions for Security Objectives Using Table 1 to guide the definitions of security objectives, the program will also complete the SCDIS-approved Security Categorization table specific to the energy rebate program. Table 2 below is essential to the security categorization process in documenting research, key decisions, approvals, and supporting rationale driving the information system security categorization. This information is key to supporting the security life cycle and will be included in the information system’s security plan.

Table 2 provides formatting for documenting the security categorization process systems that require privacy and security measures as outlined in FIPS 199.

Information System Name:

Business and Mission Supported:

Information Types

Step 3b – Impact Adjustment Justification

L/H

L/H

Overall Information System Impact:

Table 2: FIPS 199 Security Risk Assessment Template SCEO References For the purpose of this section, SCEO’s approach is based on SCDIS-200 Information Security and Privacy Standards, which references the following federal standards for information security.

· NIST SP 800-53: Provides the full catalog of security and privacy controls for federal information systems. The control descriptions begin in Chapter 3 (starting on page 15) and span through the remainder of the publication. This framework references impact level definitions established in FIPS Publication 199 for system categorization.

· FIPS 199: Defines the security objectives of confidentiality, integrity, and availability and their associated impact levels (Section 3, pp. 1–4). Establishes standards for security categorization of federal information and systems.

Methodology for Determining Risk South Carolina’s risk assessment methodology, as established by the SCDIS-200 Information Security and Privacy Standards, is grounded in applicable state and federal laws and incorporates nationally recognized frameworks. This approach aligns with NIST SP 800-53, particularly control RA-2 (Security Categorization), which guides how systems are evaluated based on the potential impact of a loss of confidentiality, integrity, or availability. Impact levels used in this process follow the definitions outlined in FIPS Publication 199. In addition, NIST SP 800-30 serves as a foundational guide for identifying sources of risk, assessing threat likelihood and impact, and determining appropriate mitigation strategies.

The assessment framework defines roles and responsibilities at multiple levels, including system owners, data stewards, and vendor partners. System owners are accountable for identifying risks and ensuring that appropriate mitigation measures are implemented. SCDIS provides oversight and statewide standards to ensure consistency and compliance across agencies.

The sections below illustrate how this methodology is applied, using unauthorized access to PII as an example risk.

Identifying Data Types and Sensitivity The first step in the risk assessment process is identifying the types of data involved and classifying them based on their sensitivity. For example, the Home Energy Rebate Programs handle various categories of data, including PII, financial details, and energy consumption records.

· Example Risk: Unauthorized access to PII of program participants.

· Data Sensitivity: PII such as names, addresses, Social Security numbers, and financial data is classified as highly sensitive due to the potential harm if improperly accessed or disclosed.

Evaluating Sources of Risk Potential risk sources and threat events are then evaluated. This includes identifying system vulnerabilities and the threats that could exploit them, whether internal or external, intentional or accidental.

· Example Risk: Unauthorized access to PII of program participants.

· Potential Sources of Risk:

· Vulnerabilities: Weak access controls, outdated software, unpatched systems.

· Threats: Malicious insiders, external hackers, phishing attacks.

Assessing Impact and Likelihood Each risk is assessed for potential impact and likelihood of occurrence using qualitative and quantitative methods, including historical data and threat intelligence.

· Example Risk: Unauthorized access to PII.

· Impact: May include reputational damage, identity theft, and regulatory noncompliance.

· Likelihood: Assessed based on system configuration, existing controls, and known threat activity.

Mitigation Strategies Once risks are identified and assessed, mitigation strategies are developed and implemented. These strategies are implemented based on SCDIS-200 standards and the controls outlined in NIST SP 800-53 and NIST SP 800-30. Each vendor is responsible for tailoring risk mitigation measures based on the specific data types and threats relevant to their systems.

· Example Risk: Unauthorized access to PII.

· Mitigation Strategies:

· Encryption: Encrypting data at rest and in transit to prevent unauthorized access.

· Access Controls: Enforcing multi-factor authentication and role-based access permissions.

· Security Audits: Conducting regular security audits to detect and address vulnerabilities.

· Incident Response Planning: Maintaining a documented plan for responding to security incidents.

Related to the Home Energy Rebate Program For the Home Energy Rebate Programs, applying a structured and standards-based risk assessment methodology is critical to protecting participant data and ensuring program integrity. By identifying data sensitivity, evaluating threat sources, assessing impact and likelihood, and implementing mitigation strategies, the program maintains a strong security posture.

This methodology demonstrates alignment with industry best practices and regulatory expectations. By following guidance from NIST SP 800-53, NIST SP 800-30, and FIPS 199, SCEO ensures accountability across stakeholders and establishes a clear foundation for decision-making and risk management.

SCEO References

· NIST SP 800-53: Provides a comprehensive catalog of controls to manage security and privacy risks. Control RA-2 outlines the security categorization process, which informs control selection.

· FIPS 199: Defines the impact levels (low, moderate, high) for confidentiality, integrity, and availability used in the system categorization process.

· NIST SP 800-30: Offers guidance on identifying risk sources and threat events (Section 3.2, p. 10) and on assessing risk likelihood and impact (Section 3.3, p. 12).

Risks Associated with Data Sharing Data sharing introduces a range of risks that must be actively managed to protect the confidentiality, integrity, and availability of sensitive information handled by the Home Energy Rebate Programs. These risks include potential data breaches, unauthorized data modification, and disruptions in data availability. SCEO mitigates these risks by applying the security and privacy control framework outlined in NIST 800-53.

As SCDIS’s primary standard for information security, NIST SP 800-53 provides the foundational controls used to manage data sharing risks. This framework incorporates supporting guidance from other federal publications, including FIPS 199 for impact level definitions, NIST SP 800-30 for risk assessment processes, and NIST SP 800-60 for mapping data types to security categories. These referenced documents are integral to implementing NIST SP 800-53 controls effectively and consistently.

Data Breach One of the most significant risks associated with data sharing is unauthorized access to sensitive information during transmission or storage. This is particularly critical for the Home Energy Rebate Programs, which involve PII and financial data.

Control RA-2 in NIST SP 800-53 directs agencies to categorize information systems based on the potential impact of a breach, using definitions established in FIPS 199. NIST SP 800-30, which is referenced in several risk-related controls, reinforces the importance of identifying vulnerabilities and implementing preventive measures such as encryption and access control. In the event of a data breach, agencies must coordinate with the SCDIS for investigation and remediation guidance.

Mitigation Strategy: Encryption To prevent unauthorized access, all data transmitted between systems or shared with third parties will be encrypted using approved cryptographic standards. Data will not be transferred to or accessed by vendors or third parties located outside the United States. This ensures that, even if intercepted, sensitive information remains secure and unreadable to unauthorized actors.

Data Integrity Issues Maintaining the accuracy and trustworthiness of data during sharing is essential. If data is modified inappropriately during transmission or by unauthorized parties, it can undermine rebate calculations and financial reconciliation processes.

NIST SP 800-53 includes integrity-focused controls such as SI-7 (Software and Information Integrity) and SC-12 (Cryptographic Key Establishment), which help preserve data authenticity. These controls build on the categorization methods established in FIPS 199 and are supported by mapping guidance in NIST SP 800-60, which helps determine the required level of protection based on the type of data being shared.

Mitigation Strategy: Access Controls Strict access management protocols ensure that only authorized individuals are permitted to modify or transmit program data. Role-based access control (RBAC), combined with multi-factor authentication, reduces the risk of unauthorized changes and strengthens overall data integrity.

Data Availability Ensuring that data is available and accessible when needed is vital for the efficient and timely operation of the rebate programs. Interruptions in system availability or data access can lead to delayed rebate processing and participant frustration.

NIST SP 800-53 addresses availability through controls such as CP-2 (Contingency Planning), SI-13 (Predictable Failure Prevention), and AU-9 (Protection of Audit Information). These controls are informed by the impact levels defined in FIPS 199, which recognize the operational disruption that could result from data unavailability.

Mitigation Strategy: Audit Logs Maintaining comprehensive audit logs of all data sharing activity supports accountability and traceability. Logs help detect potential threats to data availability, allow for rapid incident investigation, and confirm that access to data remains uninterrupted and limited to authorized boundaries.

Related to the Home Energy Rebate Programs The Home Energy Rebate Programs rely on secure and compliant data sharing practices to function effectively. Given the volume and sensitivity of participant data involved, managing risks associated with data exchange is a foundational requirement for program success. By aligning with NIST SP 800-53, and leveraging its references to FIPS 199, NIST SP 800-30, and NIST SP 800-60, the program applies a well-established, federally recognized approach to data security.

Key strategies such as encryption, role-based access control, and audit logging help the program maintain data confidentiality, integrity, and availability. These efforts are essential for protecting participant information, sustaining public trust, and ensuring the efficient delivery of rebates.

SCEO References

· NIST SP 800-53, Revision 5: South Carolina’s primary information security framework. Includes controls for system categorization (RA-2), access control, audit logging, and integrity protection. Incorporates references to other federal guidance.

· FIPS Publication 199: Provides the definitions of low, moderate, and high impact levels for confidentiality, integrity, and availability used in system categorization.

· NIST SP 800-30, Revision 1: Referenced by NIST SP 800-53 for risk assessment methodology, including threat and vulnerability identification and risk evaluation.

· NIST SP 800-60, Volume I and II: Referenced by NIST SP 800-53 to assist in mapping information types to appropriate security categories.

Compliance with SCEO Privacy and Security Standards SCEO complies with SCDIS privacy and security standards through a structured, proactive approach. This includes adherence to state-approved policies, implementation of training and awareness programs, and routine reviews and audits. These components are fully integrated into the Home Energy Rebate Programs to support strong security governance and maintain program integrity.

Adherence to Established Policies Adherence to SCDIS-approved privacy and security policies and procedures is fundamental to ensuring compliance. These policies provide a framework for protecting sensitive data and managing security risks effectively. For the rebate programs, strict adherence to these policies ensures that all aspects of data handling, from collection to processing and storage, comply with state-approved standards.

As an additional safeguard, all individuals working on the Home Energy Rebates Program who may have access to PII are required to complete South Carolina privacy training available through SCEIS. This includes the following training modules:

· Information Privacy Basics for State Employees

· South Carolina Enterprise Office HIPPA Training Regular Reviews and Updates SCEO conducts periodic reviews of its privacy and security policies to ensure alignment with evolving threats, technologies, and regulatory requirements. These reviews include evaluating current practices, identifying any outdated processes, and implementing updates as needed to maintain effective safeguards.

For the Home Energy Rebate Programs, this includes engaging an independent third-party auditor at least once every three years. SCEO also maintains documented procedures to monitor, assess, and respond to privacy and security issues in a timely and consistent manner. These efforts help ensure the program remains responsive to emerging risks and maintains compliance with SCDIS standards.

Audit Implementation and Incident Readiness Implementing audit recommendations is a key aspect of continuous improvement. By addressing findings and integrating industry best practices, the programs can strengthen their security posture and improve defenses against emerging threats.

SCEO also conducts regular drills to test the incident response plan. These exercises ensure that the response team is prepared to manage real incidents, identify opportunities for improvement, and update the plan based on lessons learned. The incident response plan is reviewed and revised regularly to ensure it remains effective in a dynamic threat environment.

SCEO References

· NIST SP 800-53: Provides a comprehensive catalog of controls that align with SCDIS privacy and security policies (Sections 3 and 4, pp. 25-53).

· FIPS Publication 200: Defines the minimum security requirements for federal information and systems, supporting the implementation of NIST SP 800-53 controls.

Continuous Monitoring and Incident Response Continuous monitoring and incident response are critical components of the privacy and security framework for the Home Energy Rebate Programs. These capabilities enable the timely detection of potential security incidents and ensure an effective response to minimize operational, financial, and reputational impacts. Each vendor participating in the program is required to develop SCDIS-compliant monitoring and response procedures that align with their respective security plans.

Monitoring Systems Implementing tools and processes to continuously monitor systems for potential security incidents is essential. Continuous monitoring supports the early detection of threats, vulnerabilities, and anomalous activity that could indicate a security breach. By leveraging advanced monitoring technologies and practices, the programs can maintain a proactive security posture. Controls related to continuous monitoring and detection are addressed in NIST SP 800-53’s SI (System and Information Integrity) and AU (Audit and Accountability) families, which include provisions for automated alerts, logging mechanisms, and real-time analysis.

Incident Response Plan Developing and maintaining an incident response plan is essential for managing security incidents effectively. These plans must include detailed procedures for identifying, reporting, and responding to incidents. They must also define the roles and responsibilities of response personnel, establish communication protocols, and outline steps for containment, eradication, and recovery. Vendors are responsible for creating incident response plans tailored to the specific data they handle, ensuring alignment with SCDIS requirements and their approved security documentation. Relevant controls from NIST SP 800-53 include the IR (Incident Response) control family, which outlines requirements for planning, training, testing, and incident handling.

SCEO References

· NIST SP 800-53: Provides detailed controls for continuous monitoring and incident response, including audit logging, automated alerts, and structured incident handling procedures (Sections 3 and 4, pp. 25–53).

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