Häiriöiden hallinta ja menettelyt ongelmatilanteissa

All security incidents are addressed in a consistent manner to improve security based on what has happened.

In the incident treatment process:

• the reported incident is confirmed (or found unnecessary to record)
• the type and cause of incident is documented
• the risks associated with the incident are documented
• the risks are re-evaluated and treated if that is necessary after the incident
• risk mitigation measures or a decision their acceptance is documented
• people who need to be informed of the results of the incident treatment are identified (including external ones)
• possible need for a post-incident analysis is determined

The organization shall ensure that clear persons are assigned to incident management responsibilities, e.g. handling the first response for incidents.

Incident management personnel need to be instructed and trained to understand the organization's priorities in dealing with security incidents.

A process for reporting incidents is maintained to help staff report incidents efficiently and consistently.

Things to report as an incident include e.g.:

• unauthorized access to data / premises
• action against security guidelines
• suspected security issue (e.g. phishing, malware infection)
• data system outage
• accidental or intentional destruction / alteration of data
• lost or stolen device
• compromised password
• lost physical identifier (e.g. keychain, smart card, smart sticker)
• suspected security weakness (e.g. on utilized data system or other procedures)

The personnel guidelines emphasize the obligation to report security incidents as soon as possible in accordance with the agreed process. The instructions also describe other operations in the event of an incident (e.g. recording seen error messages and other details).

The organization must document all personal data breaches and their consequences and the corrective actions taken, regardless of the action ultimately resulting from the breach.

Failure to comply with the documentation obligation or notification is contrary to GDPR and may lead to sanctions defined on the regulation.

A personal data breach must be reported to the supervisory authority if the breach may pose a risk to data subjects rights and freedoms. Data subjects, on the other hand, must be informed if the breach is likely to pose a high risk to their rights and freedoms. For example, registrants may take steps to reduce the adverse effect (e.g. by closing their credit card).

The notification must include the following information:

• a clear description of the personal data breach
• the name and contact details of the data protection officer or other contact point from which further information can be obtained
• the likely consequences of the personal data breach
• the measures proposed or already taken by the controller; where appropriate, measures to mitigate possible adverse effects.

Organisaation on Asiakastietolain 41 §:n mukaisesti ilmoitettava tietojärjestelmän tuottajalle, mikäli järjestelmässä ilmenee poikkeama järjestelmien olennaisista vaatimuksista. Poikkeamia on kuvattu THL:n määräyksen 5/2021 luvussa 10.4

Tietojärjestelmien merkittävistä poikkeamista on ilmoitettava Valviralle, erityisesti tilanteissa, joissa poikkeama voi aiheuttaa merkittävän riskin asiakas- tai potilasturvallisuudelle tai tietoturvalle. Merkittävien poikkeamien korjaamiseksi on ryhdyttävä korjaaviin toimenpiteisiin.

Organization must create processes that identify, collect and store relevant evidence information related to information security incidents. The evidence may need to have been collected in a way that can be accepted in relevant courts or other similar disciplinary bodies.

Regarding the evidence material, it should be possible to demonstrate e.g.:

• the records are complete and not altered in any way
• copies of electronic evidence are likely to be identical to the originals
• the data system from which the evidence was collected was functioning properly at the time of collection

Certification or other assurances of the competency of related personnel and tools may additionally be considered to establish more evidentiary value.

The organization shall establish a incident response plan for security incidents to critical information systems. Response plans should also be tested by the necessary organizational elements. The plan should take into account at least:

• The purpose of the information system and the precautions to be taken in the event of its disruption
• Recovery plans, targets, and priorities for the order of recovery of assets
• The role of implementing the response plans and the contact details of the persons assigned to the roles
•  Continuation of normal operations regardless of the state of the information systems.
• Distribution, approval and review of response plans

In addition, the plan should at least:

• Establish a roadmap for developing disruption management capacity
• Describe the structure and organization of incident management capability
• Provides metrics to measure incident management capability

The organization has defined a process and the team involved in responding promptly to security incidents and deciding on the appropriate actions.

The first level response process includes at least:

• effectively seeking to confirm the identified incident
• deciding on the need for immediate response

If it is difficult to identify the source of a security incident based on the primary treatment, a separate follow-up analysis is performed for the incident, in which the root cause is sought to be identified.

The knowledge gained from analyzing and resolving security incidents should be used to reduce the likelihood of future incidents and their impact.

The organization regularly analyzes incidents as a whole. This process examines the type, amount and cost of incidents with the aim of identifying recurrent and significant incidents that need more action.

If recurrent incidents requiring response are identified, based on them:

• new management tasks are created or current ones expanded
• security guidelines in this area are refined or extended
• a case example of the incident is created that is used to train staff to respond to or avoid similar incidents