Supporting functions: Enterprise Operations; Legal, Risk and Compliance; Office of Inspector General; Communications and Public Affairs
Effective date: July 21, 2026
Last reviewed: July 21, 2026
Next review due: July 21, 2026
Welcome to incident response
An incident rarely announces itself with perfect timing, complete information, and a neatly labeled folder. It may begin with a suspicious email, an unavailable system, an unfamiliar login, a missing device, an unexpected financial request, or the unsettling realization that information has been sent somewhere it should not have gone. This procedure establishes how Blevins Holdings identifies, reports, assesses, contains, investigates, resolves, and learns from security and operational incidents. The objective is simple:- Protect people.
- Limit damage.
- Preserve evidence.
- Restore operations safely.
- Meet legal, contractual, and regulatory obligations.
- Communicate accurately.
- Prevent recurrence.
Purpose
This SOP provides a consistent response process for events that may affect:- The confidentiality of company, employee, customer, client, or partner information.
- The integrity of systems, records, transactions, or data.
- The availability of critical technology, facilities, or business services.
- The safety of personnel.
- The security of company accounts, devices, networks, applications, or physical locations.
- The company’s legal, regulatory, contractual, financial, or reputational interests.
Scope
This SOP applies to:- Blevins Holdings employees, officers, managers, and contractors.
- Personnel of participating subsidiaries and affiliated entities.
- Company-owned and company-managed systems, applications, devices, networks, and facilities.
- Personally owned devices used to access company information or systems.
- Cloud platforms, hosted services, vendors, and other third-party systems used for company business.
- Security, privacy, operational, financial, physical, and technology events that may affect Blevins Holdings.
- At a company facility.
- At a remote-work location.
- During business travel.
- In a cloud or vendor environment.
- On a company or personal device.
- During or outside normal business hours.
What counts as an incident
An incident is any actual or suspected event that has harmed—or could reasonably harm—the confidentiality, integrity, availability, safety, legality, or reliability of company operations, information, systems, or facilities. Examples include:Cybersecurity incidents
- Suspected unauthorized access.
- Account compromise or credential theft.
- Malware, ransomware, spyware, or other malicious software.
- Phishing, impersonation, or social-engineering attacks.
- Suspicious logins or impossible-travel alerts.
- Unauthorized changes to systems or configurations.
- Denial-of-service attacks.
- Exploitation of a system vulnerability.
- Unapproved software or devices on company networks.
- Loss of administrative control over a system or account.
- Suspected insider misuse.
Privacy and data incidents
- Accidental disclosure of personal or confidential information.
- Information sent to the wrong recipient.
- Public exposure of restricted files or folders.
- Loss or theft of records, devices, or storage media.
- Unauthorized downloading, copying, or transfer of data.
- Improper disposal of records.
- Data accessed beyond a person’s authorized role.
- Suspected data exfiltration.
- Use of company information in an unauthorized artificial-intelligence or external service.
Technology and availability incidents
- Extended system or application outages.
- Failure of critical infrastructure.
- Loss of network, communications, or cloud services.
- Corruption or deletion of important records.
- Backup failure affecting recovery capability.
- Significant performance degradation.
- Failed software deployment with material operational impact.
- Loss of access to critical vendor systems.
- Repeated system instability suggesting a broader failure.
Physical and operational incidents
- Unauthorized entry to a company facility.
- Theft or loss of equipment.
- Tampering with physical security controls.
- Fire, flood, utility failure, or environmental damage affecting operations.
- Workplace threats or violence affecting business continuity.
- Loss of access to a critical facility.
- Disruption of essential operational processes.
- Vendor failure affecting a critical service.
- Fraudulent payment instructions or suspected financial manipulation.
Legal and compliance incidents
- Suspected violation of a legal, regulatory, contractual, or licensing requirement.
- Failure to meet a mandatory reporting or retention obligation.
- Loss or destruction of records subject to preservation.
- Unauthorized disclosure of legally privileged information.
- Government, law-enforcement, or regulatory contact relating to a suspected incident.
- Material violation of company security, privacy, or acceptable-use policy.
What is not ordinarily an incident
The following may be handled through normal support channels unless additional risk is present:- A routine password reset.
- A single user unable to access a noncritical application.
- A known and scheduled service interruption.
- A minor device issue with no security or operational impact.
- A user question about system behavior.
- A previously approved and documented configuration change.
- Suspicious activity.
- Repeated failures.
- Sensitive information.
- Privileged access.
- Multiple users or systems.
- A critical business service.
- Fraud, impersonation, or manipulation.
- Possible policy or legal violations.
Immediate priorities
The response team will generally prioritize the following objectives in order:- Protect life, health, and physical safety.
- Stop or limit active harm.
- Protect critical operations and information.
- Preserve evidence.
- Determine scope and severity.
- Meet legal, regulatory, contractual, and insurance obligations.
- Restore services safely.
- Communicate accurately and appropriately.
- Document decisions and actions.
- Identify corrective and preventive measures.
Reporting an incident
Anyone who becomes aware of an actual or suspected incident must report it immediately.Primary reporting channels
- IT Security: security@blevinsholdings.com
- Emergency IT telephone: [Emergency number]
- Service desk: [Service desk channel]
- After-hours escalation: [After-hours instructions]
- Physical emergency: Call local emergency services first, then notify the appropriate company contact.
- Suspected misconduct or internal wrongdoing: [Office of Inspector General or ethics reporting channel]
Information to include
Provide as much of the following as is reasonably available:- Your name and contact information.
- Date and time the issue was discovered.
- How the issue was discovered.
- Systems, accounts, devices, locations, or people involved.
- What was observed.
- Whether the activity appears to be continuing.
- Whether sensitive information may be involved.
- Whether anyone may be in immediate danger.
- Screenshots, error messages, filenames, sender addresses, or other relevant details.
- Actions already taken.
- Anyone else who has been notified.
- Whether a customer, client, vendor, regulator, or member of the public is aware of the matter.
What the person reporting should do
Unless immediate safety requires otherwise:- Stop the activity that revealed the issue.
- Preserve relevant messages, files, screenshots, and records.
- Record the time and circumstances.
- Follow instructions from IT Security or the incident commander.
- Remain available for follow-up questions.
- Keep the matter confidential.
- Avoid changing, deleting, forwarding, or modifying potential evidence.
- Avoid discussing the incident with unauthorized parties.
What the person reporting should not do
Do not:- Conduct an unauthorized investigation.
- Search another person’s account or device.
- Delete suspicious files or messages.
- run antivirus, cleanup, or forensic tools unless instructed.
- Reimage, reset, wipe, or replace the affected device.
- Power off a device unless directed or necessary for immediate safety.
- Contact the suspected attacker.
- Respond to ransom or extortion demands.
- Pay money or authorize payment.
- Notify customers, clients, regulators, insurers, law enforcement, or the media independently.
- Post about the incident on social media.
- Share screenshots or details in broad chat channels.
- Assume the incident is resolved because visible symptoms stop.
Lost or stolen devices
When a company device or a personal device containing company information is lost or stolen:- Report it immediately.
- Provide the device type, owner, telephone number, serial number, and last known location if available.
- State whether the device was encrypted and whether it was logged in.
- State whether company accounts, email, files, or applications were accessible.
- Do not attempt a personal recovery that could create a safety risk.
- Follow instructions regarding remote lock, account reset, device tracking, or remote wipe.
- File a police report when directed or reasonably required.
Suspected phishing or account compromise
When a suspicious message or account event is identified:- Do not click additional links or open attachments.
- Do not reply to the sender.
- Report the message through the approved phishing-reporting process.
- Tell IT Security whether credentials were entered.
- State whether an attachment was opened or software was installed.
- State whether an authentication request was approved.
- Follow instructions for password reset and session termination.
- Do not reuse the compromised password elsewhere.
Suspected ransomware or active malware
If ransomware, unusual encryption, or rapidly spreading malware is suspected:- Disconnect the affected device from wired and wireless networks when it can be done safely.
- Do not power the device off unless instructed.
- Do not connect storage devices or backups.
- Do not attempt to decrypt or remove the malware.
- Contact IT Security immediately by telephone or another approved out-of-band method.
- Record visible messages, filenames, times, and affected systems without interacting further.
- Preserve any ransom message or communication.
- Await instructions.
Incident severity levels
Severity is determined by the incident commander in consultation with relevant response functions. Classification may change as new information becomes available.Severity considerations
The response team should consider:- Threat to life or safety.
- Whether the event is active.
- Sensitivity and volume of information involved.
- Number and type of affected systems or users.
- Criticality of the affected business service.
- Presence of privileged, executive, financial, or administrative accounts.
- Evidence of persistence, lateral movement, or exfiltration.
- Customer, client, employee, or public impact.
- Legal, regulatory, contractual, or insurance obligations.
- Financial loss or fraud exposure.
- Likelihood of media or public attention.
- Involvement of a regulated or government customer.
- Ability to contain the event.
- Availability of reliable backups and recovery methods.
- Whether the event involves a vendor or subsidiary.
- Possibility of insider activity.
Incident-response roles
Incident commander
The incident commander directs the response and is responsible for:- Confirming or assigning severity.
- Establishing response priorities.
- Assigning roles and workstreams.
- Approving containment and recovery actions.
- Coordinating response functions.
- Maintaining an operational timeline.
- Scheduling response meetings.
- Escalating decisions requiring executive authority.
- Confirming closure criteria.
IT Security
IT Security is responsible for:- Technical triage and investigation.
- Threat analysis.
- Account and system containment.
- Evidence preservation.
- Log collection and review.
- Coordination with forensic specialists.
- Security remediation.
- Validation of technical recovery.
- Security monitoring after restoration.
Information Systems and Technology
IST is responsible for:- Infrastructure and application support.
- Service restoration.
- Backup and recovery operations.
- Vendor coordination.
- Configuration changes.
- System validation.
- Operational documentation.
Legal, Risk and Compliance
Legal, Risk and Compliance is responsible for:- Preserving legal privilege when appropriate.
- Advising on legal and regulatory obligations.
- Determining notification requirements.
- Coordinating with law enforcement or regulators.
- Reviewing contracts and reporting deadlines.
- Advising on evidence preservation.
- Coordinating insurance notification when required.
- Reviewing external communications.
- Assessing legal and compliance risk.
General Counsel
The General Counsel advises on legal exposure, privilege, notification, regulatory contact, law-enforcement engagement, litigation risk, and external legal support.Office of Inspector General
The Office of Inspector General may:- Review suspected misconduct, fraud, abuse, retaliation, or control failures.
- Conduct or coordinate independent investigations.
- Preserve investigative independence.
- Recommend corrective or disciplinary action.
- Coordinate with Legal, Human Resources, Finance, or other oversight functions.
Global Human Resources
Global Human Resources supports incidents involving:- Employee conduct.
- Workplace safety.
- Personnel actions.
- Employee communications.
- Insider risk.
- Harassment, retaliation, or policy violations.
- Employee assistance and support.
Communications and Public Affairs
Communications and Public Affairs is responsible for:- Preparing approved internal and external communications.
- Coordinating media responses.
- Maintaining consistent messaging.
- Monitoring public reporting and reputational impact.
- Supporting executive and stakeholder communications.
Finance
Finance supports:- Fraud containment.
- Payment holds.
- Banking notifications.
- Financial-impact assessment.
- Insurance and loss documentation.
- Vendor-payment verification.
- Recovery of improperly transferred funds.
Business and subsidiary leaders
Affected leaders are responsible for:- Identifying operational impact.
- Prioritizing critical services.
- Providing knowledgeable personnel.
- Supporting business-continuity decisions.
- Communicating with affected teams as authorized.
- Verifying restoration of business processes.
Incident-response procedure
Report and acknowledge
- Record the date and time.
- Acknowledge receipt.
- Obtain immediate safety and impact information.
- Create an incident record.
- Provide initial instructions to the reporter.
- Escalate urgent matters immediately.
Triage
- What occurred or may have occurred.
- Whether the event is active.
- What systems, people, information, or facilities may be affected.
- Whether immediate containment is required.
- Whether sensitive data may be involved.
- Whether the matter may involve fraud, misconduct, safety, or legal risk.
- Which teams must be engaged.
Assign severity and leadership
- A response team.
- A secure communication channel.
- A meeting cadence.
- An incident timeline.
- Decision and approval authority.
- Technical, legal, operational, and communications workstreams.
Protect safety and critical operations
- Contacting emergency services.
- Evacuating or securing a location.
- Activating business-continuity procedures.
- Switching to alternate systems.
- Suspending hazardous operations.
- Restricting facility or system access.
Preserve evidence
- System and application logs.
- Security alerts.
- Email messages and headers.
- Chat records.
- Access records.
- Device images.
- Cloud audit records.
- Network captures.
- Photographs or video.
- Physical access logs.
- Transaction records.
- Vendor communications.
- Witness accounts.
Contain
- Isolating devices, networks, applications, or cloud resources.
- Suspending compromised accounts.
- Revoking tokens, sessions, or credentials.
- Blocking malicious domains, addresses, files, or traffic.
- Disabling integrations.
- Restricting administrative access.
- Placing payment or transaction holds.
- Removing public access to exposed information.
- Temporarily shutting down an affected service.
- Restricting physical access.
Investigate and assess scope
- Initial access or root cause.
- Systems and accounts affected.
- Information accessed, altered, disclosed, or removed.
- Duration of exposure.
- Attacker or actor activity.
- Persistence mechanisms.
- Lateral movement.
- Financial and operational impact.
- Whether the event remains active.
- Whether third parties are involved.
- Whether notification obligations may apply.
Engage required stakeholders
- Executive leadership.
- General Counsel.
- Legal, Risk and Compliance.
- Office of Inspector General.
- Global Human Resources.
- Finance.
- Communications and Public Affairs.
- Affected subsidiary leadership.
- Insurance providers.
- External forensic or legal specialists.
- Critical vendors.
- Law enforcement or regulators.
Eradicate the cause
- Removing malicious software.
- Closing vulnerabilities.
- Resetting credentials.
- Rebuilding affected systems.
- Revoking unauthorized access.
- Removing persistence mechanisms.
- Correcting misconfigurations.
- Updating software.
- Replacing compromised devices.
- Terminating malicious integrations.
- Correcting failed procedures or controls.
Recover operations
- Validation of backups.
- Security testing.
- Integrity checks.
- Controlled restoration.
- Business-owner acceptance.
- Enhanced monitoring.
- Confirmation that the original cause has been addressed.
- Documentation of temporary workarounds.
- Prioritization of critical services.
Communicate status
- What is known.
- What remains under investigation.
- Current operational impact.
- Actions employees or users must take.
- Where questions should be directed.
- When the next update is expected.
Validate containment and recovery
- The active threat has been removed or controlled.
- Affected systems are operating reliably.
- Credentials and access have been secured.
- Required monitoring is in place.
- Business owners accept restored services.
- Required notifications have been completed or scheduled.
- Residual risks are documented and approved.
Close the incident
- Final severity.
- Resolution date and time.
- Affected services and data.
- Confirmed or probable root cause.
- Outstanding corrective actions.
- Responsible owners.
- Post-incident review requirements.
Conduct the post-incident review
Evidence preservation
Evidence must be preserved in a manner appropriate to the incident. Personnel must not:- Delete suspicious messages.
- Clear logs.
- Wipe or reimage devices.
- Alter timestamps.
- Modify relevant records.
- Destroy physical evidence.
- Remove data from company custody without authorization.
- Conduct forensic analysis using unapproved tools.
- Share evidence with unauthorized parties.
- What was collected.
- Who collected it.
- When and where it was collected.
- How it was transferred.
- Where it is stored.
- Who accessed it.
- Any changes made during analysis.
Communication rules
Incident communications must be accurate, controlled, and appropriate to the risk.Approved communication methods
The incident commander will designate approved channels, which may include:- A restricted incident-management platform.
- A secure conference bridge.
- A limited-access chat channel.
- An out-of-band telephone or messaging channel.
- An approved email distribution list.
- In-person meetings.
Internal communications
Internal updates should:- Be limited to people with a legitimate need to know.
- Use the incident identifier where practical.
- Distinguish confirmed facts from assumptions.
- Avoid unnecessary personal information.
- State required actions clearly.
- Include the time of the next update.
- Be preserved as part of the incident record.
External communications
No employee may independently communicate incident details to:- Customers or clients.
- Vendors or business partners.
- Regulators.
- Law enforcement.
- Insurance carriers.
- News media.
- Investors.
- Members of the public.
Customer, client, and regulatory notification
Legal, Risk and Compliance will determine whether notification is required under:- Applicable law or regulation.
- Customer or client contracts.
- Insurance policies.
- Government agreements.
- Industry requirements.
- Court orders.
- Licensing obligations.
- Other binding commitments.
- The type of information involved.
- The affected individuals or organizations.
- The likelihood of harm.
- The date of discovery.
- Statutory or contractual deadlines.
- Required content and delivery methods.
- Coordination across jurisdictions.
- Whether law enforcement has requested a delay.
Third-party and vendor incidents
When a vendor or service provider reports an incident that may affect Blevins Holdings:- Open an internal incident record.
- Obtain the vendor’s incident identifier and primary contact.
- Determine affected services, systems, and information.
- Request available timelines and indicators.
- Review contractual notification and cooperation requirements.
- Identify internal dependencies.
- Consider temporary suspension or isolation of the vendor connection.
- Coordinate Legal, security, privacy, and business review.
- Track vendor remediation and evidence.
- Confirm restoration before returning to normal operations.
Business-continuity coordination
When an incident disrupts critical services, the incident commander should coordinate with Enterprise Operations and affected business leaders to:- Identify essential functions.
- Establish restoration priorities.
- Activate manual or alternate processes.
- Reassign personnel or resources.
- Communicate operational limitations.
- Protect service commitments.
- Document temporary controls.
- Determine whether continuity or disaster-recovery plans should be activated.
Law-enforcement contact
Contact with law enforcement should be coordinated through General Counsel, Legal, Risk and Compliance, or another expressly authorized executive. Emergency situations involving immediate danger may be reported directly to emergency services. The response team should preserve:- Contact names.
- Agency information.
- Case or report numbers.
- Requests for evidence.
- Preservation instructions.
- Disclosure approvals.
- Dates and times of communication.
Cyber-insurance notification
When an incident may be covered by insurance, Legal, Risk and Compliance or another designated owner should review notification requirements promptly. Certain policies may require:- Notice before engaging outside specialists.
- Use of approved forensic, legal, or communications vendors.
- Insurer approval before incurring specified costs.
- Preservation of expense and loss records.
- Cooperation with insurer-appointed specialists.
Status updates
For significant incidents, the incident commander should establish a regular update cadence. A status update should generally include:Post-incident review
A post-incident review should determine what occurred, why it occurred, how the response performed, and what must change. The review should cover:Incident summary
- Date and time of discovery.
- Detection source.
- Final severity.
- Duration.
- Affected systems, information, operations, and stakeholders.
- Business and financial impact.
- Notification obligations.
- Final status.
Timeline
The timeline should document:- Initial event.
- Detection.
- Reporting.
- Escalation.
- Containment.
- Investigation milestones.
- Major decisions.
- Notifications.
- Restoration.
- Closure.
Root cause
The review should identify:- Immediate technical or operational cause.
- Contributing conditions.
- Failed or missing controls.
- Human, process, vendor, technology, and governance factors.
- Why the event was not prevented or detected sooner.
- Whether similar risk exists elsewhere.
Response effectiveness
Evaluate:- Speed of detection.
- Speed of reporting.
- Accuracy of severity assignment.
- Effectiveness of containment.
- Evidence preservation.
- Coordination among teams.
- Quality of communications.
- Recovery performance.
- Vendor cooperation.
- Legal and compliance handling.
- Availability of documentation and contact information.
Corrective actions
Corrective actions should be:- Specific.
- Assigned to an owner.
- Given a due date.
- Prioritized by risk.
- Tracked to completion.
- Verified for effectiveness.
- Technical remediation.
- Policy or procedure changes.
- Additional monitoring.
- Training.
- Vendor changes.
- Access-control improvements.
- Backup improvements.
- System redesign.
- Contract amendments.
- Business-continuity enhancements.
- Disciplinary or administrative action.
- Additional testing or exercises.
Incident documentation
The official incident record should include, as applicable:- Incident identifier.
- Reporter information.
- Discovery date and time.
- Severity history.
- Incident commander.
- Response-team members.
- Affected assets and information.
- Timeline of events.
- Decisions and approvals.
- Evidence inventory.
- Communications.
- Legal and regulatory analysis.
- Containment and remediation actions.
- Recovery validation.
- Cost and impact estimates.
- Notification records.
- Post-incident review.
- Corrective-action plan.
- Closure approval.
Confidentiality
Incident information may contain:- Sensitive security details.
- Personal information.
- Legal advice.
- Privileged communications.
- Personnel information.
- Trade secrets.
- Customer or client information.
- Evidence of suspected wrongdoing.
- Information that could enable further attacks.
- Forward incident records to personal accounts.
- Download records to unapproved devices.
- discuss incident details casually.
- Share information with uninvolved colleagues.
- Use incident details for presentations or training without approval.
- Retain personal copies after the matter is closed.
Metrics and program improvement
IT Security should periodically review incident-response metrics, which may include:- Number of incidents by category and severity.
- Time to detect.
- Time to report.
- Time to contain.
- Time to recover.
- Repeated root causes.
- Number of affected systems or users.
- Corrective-action completion rates.
- Vendor-response performance.
- Backup and restoration effectiveness.
- Phishing-reporting rates.
- Regulatory or contractual notifications.
- Business interruption and financial impact.
Exercises and testing
Blevins Holdings should periodically test incident-response capability through:- Tabletop exercises.
- Phishing simulations.
- Backup-restoration tests.
- Technical response drills.
- Vendor-response exercises.
- Business-continuity exercises.
- Executive decision simulations.
- Communications exercises.
- Contact-list validation.
Escalation guide
Responsibilities of all personnel
Everyone covered by this SOP is expected to:- Report suspected incidents promptly.
- Provide truthful and complete information.
- Follow response-team instructions.
- Protect incident confidentiality.
- Preserve relevant evidence.
- Avoid unauthorized investigation or remediation.
- Cooperate with authorized reviews.
- Complete required training.
- Keep emergency contact information accessible.
- Report suspected retaliation or interference.
Non-retaliation
Retaliation against an individual who reports a suspected incident in good faith, preserves evidence, participates in an investigation, or follows this procedure is prohibited. Retaliation concerns should be reported to Global Human Resources, Legal, Risk and Compliance, or the Office of Inspector General.Exceptions
Exceptions to this SOP must be:- Legally permissible.
- Based on a documented operational need.
- Risk-assessed.
- Approved by the SOP owner and other required authorities.
- Limited in scope and duration.
- Supported by appropriate compensating controls.
Related documents
- Information Security Policy.
- Acceptable Use Policy.
- Data Privacy Policy.
- Business Continuity Plan.
- Disaster Recovery Plan.
- Records Management Policy.
- Investigation and Non-Retaliation Policy.
- Vendor Risk Management Policy.
- Crisis Communications Plan.
- Cyber-Insurance Response Guide.
- Physical Security Procedures.
- Evidence Handling Standard.
- Data Breach Notification Procedure.
