Cyber Incident Governance

In the aftermath or threat of a cyber incident, an organization must rapidly adopt disciplined governance, clear roles, consistent processes, and continuous improvement to respond effectively, contain damage, restore operations, and prevent recurrence.

Milliarium’s approach emphasizes strong Governance & Oversight as the backbone of incident response maturity. Our goal is to embed a sustainable, auditable, and scalable incident governance structure that aligns with industry best practices (NIST, ISO 27035, COSO, CMMC) and integrates with the client’s broader risk and enterprise control frameworks.

Key objectives include:

• Define a governance structure with decision rights, escalation paths, and accountability across IT, legal, business operations, and executive leadership

• Institutionalize frameworks and policies that meet regulatory and contractual expectations (e.g. CMMC’s IR domain)

• Enable real-time oversight and strategic decision-making during an incident

• Accelerate response timelines (MTTD / MTTR)

• Drive a culture of after-action learning and continuous improvement

Governance Architecture & Reference Mappings

Here we map how Milliarium’s governance layer ties into standards and frameworks:

Governance Component	Milliarium’s Design Approach	Mapping to Standards / Frameworks
Incident Response Policy & Charter	We deliver a formal charter authored jointly with the client’s CISO/Board that states scope, authority, escalation thresholds, external reporting triggers, and high-level principles.	Maps to ISO/IEC 27035 PP.1 (“Incident Management Policy”) requirement for documented approach.
Roles, Responsibilities & Organizational Structure	Define a layered governance: Executive Steering, Incident Oversight Committee, Incident Commander, Tactical Response Team, Forensic & Legal, Communications, and Remediation units.	Aligns with ISO 27035 PP.3 (“Defining Roles & Responsibilities”) RiskCognizance.com+1 and NIST’s guidance on establishing incident response teams (SP 800-61). NIST Computer Security Resource Center+1
Escalation & Decision Matrix	Predefine triggers (e.g. data exfiltration, ransomware, regulatory breach) mapped to severity tiers and required executive/legal notification.	Consistent with NIST’s severity classification in SP 800-61 and the modernization in SP 800-61 Rev 3. NIST Publications+4NIST Computer Security Resource Center+4NIST Publications+4
Integration with Enterprise Risk & Controls (COSO alignment)	We embed incident governance into the client’s risk management and internal control (COSO) framework — treating cyber incidents as operational and risk events, with oversight by the audit/ERM function.	Using a COSO lens ensures alignment between IT / security controls and enterprise-level risk/oversight. (Though COSO itself is not prescriptive for cybersecurity, it provides structural alignment.)
Regulatory / Contractual Reporting & Notification	We pre-map the thresholds for notifying regulators, customers, and stakeholders, especially for defense contracts (CMMC / DFARS) or privacy laws.	CMMC’s IR requirements demand defined response capability, reporting timelines (e.g. 72 hours) and tests of the IR plan. Kiteworks | Your Private Data Network+1
Governance Review & Audit Trail	All incidents pass through the oversight committee. We embed dashboards, logs, decision logs, and retrospectives to ensure auditability and continuous review.	Supports continuous improvement and audit obligations under ISO/IEC 27035 and NIST. Rapid7+2NIST Computer Security Resource Center+2

Thus, Milliarium’s governance layer is not merely a documentation exercise, but a living, decision-oriented structure that ensures discipline, transparency, and escalation control during high-stakes cyber events.

How Governance Supports Each Incident Phase

Incident Phase	Governance & Oversight Role	Key Deliverables / Controls
Preparation	Governance ensures funding, resourcing, authority, roles, and executive buy-in. The policy charter is approved and the oversight committee is formed.	Incident governance policy, committee charter, roles & escalation matrices, integration with risk management
Detection & Analysis	Governance defines thresholds for when to trigger escalation to senior leadership, legal, PR, customers. Oversees analytics & triage.	Triage policies, dashboard alerts, decision logs when incidents cross thresholds
Containment	Governance may authorize broad actions (e.g. network segmentation, disabling accounts, shutting down systems) especially when tradeoffs exist with business operations.	Executive decision memos, segmented escalation calls, oversight on containment paths
Eradication & Recovery	Governance monitors remediation prioritization, approves exceptions or waivers, ensures forensic integrity and that recovery aligns with business continuity priorities.	Change waivers, exception logs, remediation tracking, recovery approvals
Post-Incident / Lessons Learned	Governance oversees root-cause review, approves policy or procedural changes, ensures the cycle closes with resource allocation to prevent recurrence.	Lessons Learned reports, dashboard metrics, control enhancements, audit reviews

By weaving governance into every stage, Milliarium ensures the client does not devolve into tactical chaos, but instead operates under disciplined decision control — even when under attack.

Project Plan: High-Level Phases & Timeline

Below is a sample 5-phase project engagement (approx. 16–20 weeks) that a seasoned Senior Management Consultant would lead for a client adopting Milliarium’s Cyber Incident Governance solution following or anticipating a cyber incident.

Phase	Duration	Major Activities / Deliverables	Narrative Focus
Phase 0 – Incident Stabilization (if case ongoing)	1–2 weeks	Rapid triage, immediate containment support, war room setup	If a live incident is unfolding, the consultant leads crisis support to stabilize, while preparing the governance/structure work.
Phase 1 – Assessment & Baseline (2–3 wk)	2–3 weeks	Stakeholder interviews, current-state IR capability maturity assessment, gap analysis vs NIST, ISO, CMMC, COSO, control mapping	The consultant diagnoses governance gaps, risk tolerances, thresholds, and stakeholder information flows.
Phase 2 – Design & Governance Model (3–4 wk)	3–4 weeks	Design governance structure, draft policy & charter, define roles/escalation, integrate with ERM, draft decision matrices	The consultant facilitates working sessions with CISO, legal, business leads to build consensus on the governance design.
Phase 3 – Process & Tooling Implementation (4–5 wk)	4–5 weeks	Build playbooks, decision templates, dashboards, decision logs, integrate with SIEM / ticketing / reporting tools	The consultant oversees creation of artifacts (e.g. severity matrix, decision flowcharts), configures dashboards, and integrates governance controls into workflows.
Phase 4 – Testing, Training & Pilot (2–3 wk)	2–3 weeks	Tabletop exercises, mock incidents, role-play, training to Governance Committee and response team	The consultant leads simulation of major scenarios to validate decision paths, adjust thresholds, and strengthen readiness.
Phase 5 – Transition, Go-Live & Continuous Improvement (2–3 wk + ongoing)	2–3 weeks plus ongoing	Transition oversight to client’s teams, embed KPI monitoring, set up quarterly review cadence	The consultant ensures that the governance model becomes self-sustaining, hands off, and that feedback loops are embedded.

Milliarium engagements are designed to assist our clients in defining and implementing solutions that they own, thereby achieving the organization's goals. It's not a one-size-fits-all approach.

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