Compliance glossary
Definition

Incident Response Plan (IRP)

A documented set of procedures your firm follows when a data breach or security incident occurs.

What it means.

An Incident Response Plan (IRP) is a formal document that outlines how your firm detects, responds to, contains, and recovers from a cybersecurity incident such as a data breach, ransomware attack, phishing compromise, or unauthorized access to client data. A comprehensive IRP includes roles and responsibilities, communication procedures, containment steps, evidence preservation, notification requirements (both regulatory and client), and recovery procedures. Under the FTC Safeguards Rule, firms with 5,000 or more consumer records must maintain a written IRP.

Why it matters for CPA firms.

Without a documented IRP, firms typically take longer to respond to breaches, suffer greater data loss, and face higher penalties. State breach notification laws in all 50 states require specific actions within defined timeframes (often 30-72 hours). Having a pre-written IRP ensures your firm can respond quickly and correctly. Cyber insurers frequently require a documented IRP and may deny claims if the firm had no plan in place before the incident.

Relevant regulations.

  • FTC Safeguards Rule (16 CFR 314.4(h))
  • State Breach Notification Laws (all 50 states)
  • IRS Publication 4557

How Kompflow helps.

The Incident Response Plan Generator module handles this for your firm, personalized to your software, team size, and state requirements.

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