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Crisis Management and Communications Plan Template (ISO 22361)

Crisis team and deputies, activation criteria, decision log and battle rhythm, stakeholder communication matrix, notification clocks, holding statements, ransomware scenario, exercises

ISMS & ISO/IEC 27001FullISO 22361:2022 (cited only); ISO/IEC 27001:2022 + Amd 1:2024 A.5.5, A.5.24 to A.5.29; ISO 22301:2019 + Amd 1:2024crisismanagementcommunicationsplan

How to use: Use it when you need a strategic layer above incident response and business continuity that takes decisions and owns external communication. Fill the crisis team with deputies, the activation criteria and the stakeholder matrix first. The main pitfall is a crisis team that tries to run the technical response instead of deciding and communicating.

Preview

Crisis Management and Communications Plan: [Organization name]

Plan for leading the organization through a crisis: a situation that threatens its people, customers, reputation, finances or ability to operate, and that ordinary incident and continuity processes cannot resolve on their own. It defines the crisis management team, activation criteria, decision-making, stakeholder communications (staff, customers, regulators, media, suppliers, investors), holding statements, a cyber crisis scenario and the interfaces with incident response and business continuity. It draws on the guidance of ISO 22361:2022 (crisis management, cited) and supports ISO/IEC 27001:2022

  • Amd 1:2024 controls A.5.24 to A.5.29 and A.5.5 (contact with authorities). Replace every [bracketed] value and every row marked Example. This is a documentation format, not legal advice.

Document control

FieldValue
Document ID[DOC-ISMS-078]
Version[1.0]
Status[Draft / In review / Approved / Superseded]
Owner[@coo] (crisis management lead)
Approvers/reviewers[@ceo], [@ciso], [@general-counsel], [@head-of-communications], [@business-continuity-lead]
Last updatedYYYY-MM-DD
Classification[Confidential; contact annex Restricted]
Standard and editionISO 22361:2022 (cited); ISO/IEC 27001:2022 + Amd 1:2024 (A.5.5, A.5.24 to A.5.29); ISO 22301:2019 + Amd 1:2024
Next scheduled reviewYYYY-MM-DD (at least annually and after every activation or major exercise)
Last exercised[Exercise ID, YYYY-MM-DD]
Contact annex reference[CMT-CONTACTS, last verified YYYY-MM-DD]
Incident response plan reference[DOC-ISMS-020]
Business continuity plan reference[DOC-ISMS-121]
Offline copy location[Printed copies with each team member, encrypted copy outside the corporate environment]

Approvals

RoleNameDecisionDate
Crisis management lead[@coo][Prepared]YYYY-MM-DD
General counsel[@general-counsel][Reviewed]YYYY-MM-DD
CISO[@ciso][Reviewed]YYYY-MM-DD
Chief executive[@ceo][Approved]YYYY-MM-DD

Revision history

VersionDateAuthorChange
1.0 (Example)YYYY-MM-DD[@coo]First approved plan
1.1 (Example)YYYY-MM-DD[@coo]Holding statements updated after the ransomware tabletop (EX-2027-02)

Contents

  1. Purpose, scope and definitions
  2. Interfaces with incident response and business continuity
  3. Crisis management team
  4. Activation and escalation
  5. Decision-making and battle rhythm
  6. Communication principles and approval
  7. Stakeholder map and communication matrix
  8. Regulators, authorities and notification duties
  9. Holding statements and message templates
  10. Cyber crisis scenario: ransomware with data theft
  11. Stand-down, recovery and review
  12. Training and exercises
  13. Size tiers
  14. Records and evidence
  15. References

1. Purpose, scope and definitions

This plan sets out how [Organization name] recognizes a crisis, brings together the people who can lead it, takes and records strategic decisions, and communicates with everyone affected, so that harm to people, customers, operations, reputation and legal standing is kept as low as possible and trust is rebuilt afterwards.

TermMeaning in this plan
EventSomething that happens and may need attention. Most events are handled by normal operations.
IncidentAn event that disrupts or threatens normal operations or information security, handled under the incident response plan (DOC-ISMS-020) or the operational incident process.
DisruptionAn incident that stops or degrades prioritized activities, handled under the business continuity plan (DOC-ISMS-121) and the ICT readiness plan (DOC-ISMS-047).
CrisisA situation with high uncertainty and potentially severe impact on the organization as a whole, needing strategic decisions and coordinated communication beyond what the plans above can deliver.

Scope: [all legal entities, sites, products and services of the organization]. The plan covers crises of any cause, including cyber attacks, major data breaches, prolonged service outages, supplier failure, product safety issues, serious misconduct allegations, natural hazards and events that affect staff safety. Life-safety emergencies are first handled by the site emergency procedures; the crisis team takes over the strategic response once people are safe.

2. Interfaces with incident response and business continuity

LevelTeamDecidesReports to
StrategicCrisis management teamPriorities, risk trade-offs, external communication, spending beyond limits, legal positions, ransom stanceBoard
TacticalIncident commander, business continuity lead, ICT recovery managerHow to carry out the strategic priorities, resource allocation within limitsCrisis management team
OperationalResponse, recovery and support teamsTechnical and process actionsTactical leads

Rules: the incident commander keeps authority over technical response; the crisis team does not give instructions to responders directly. All external messages about the event, including those to customers from account managers, go through the communications cell once the crisis team is active.

3. Crisis management team

RoleResponsibilitiesPrimaryDeputy
Crisis lead (chair)Convenes the team, sets priorities, takes final decisions, keeps the board informed[@coo][@cfo]
Chief executivePublic face of the organization, decisions with board-level impact[@ceo][@coo]
Legal leadLegal duties, notifications, privilege, contracts, law enforcement contact[@general-counsel][@legal-counsel]
Security leadSituation picture for cyber events, link to the incident commander[@ciso][@security-lead]
Operations and continuity leadStatus of prioritized activities, link to BCP and ICT readiness[@business-continuity-lead][@head-of-it-operations]
Communications leadRuns the communications cell, drafts and releases messages[@head-of-communications][@marketing-lead]
People leadStaff welfare, internal communication, HR issues[@head-of-people][@hr-partner]
Crisis coordinator (secretariat)Decision log, action tracker, meeting logistics, information board[@executive-assistant][@pmo-lead]

Advisers called in as needed: data protection officer, customer success lead, finance lead, insurer and breach counsel, external forensic provider, public relations adviser. Their contact details sit in the contact annex and in the authorities and special interest groups contact list (DOC-ISMS-069).

Crisis room: [primary meeting room], virtual bridge [out-of-band conference line not dependent on corporate identity], backup location [alternate site]. Out-of-band messaging group: [tool], tested every quarter.

4. Activation and escalation

4.1 Activation criteria

Any one of these is enough to alert the crisis lead:

CodeCriterionTypical source
C1Incident rated at the top severity level in the incident severity matrix (ops/incident-severity-matrix)Incident commander
C2Prioritized activity expected to exceed its maximum tolerable period of disruption (BIA)Business continuity lead
C3Confirmed or likely theft or exposure of personal data or customer confidential data at large scaleCISO, data protection officer
C4Threat of extortion, including ransom demandsCISO
C5Media, regulator or law enforcement interest, or social media spreading fastCommunications lead, legal lead
C6Risk of serious harm to people, or a fatalitySite emergency lead
C7Event likely to have a material financial impact or to require disclosure to investorsFinance lead
C8Any situation the chief executive or crisis lead considers a crisisAny member

4.2 Escalation steps

  1. The person who identifies a possible crisis calls the crisis lead or deputy at once, day or night, and gives a short summary: what happened, when, what is affected, what is known and unknown.
  2. The crisis lead decides within [30] minutes to activate, to put the team on standby, or to leave the event with the incident or continuity team.
  3. On activation, the crisis coordinator alerts all members through the out-of-band channel; members confirm within [15] minutes and join the first meeting within [60] minutes.
  4. The coordinator opens the decision log and the action tracker.

Activation is recorded with the time, the criteria met and who decided. Activating and standing down early is acceptable and is not counted as a failure.

5. Decision-making and battle rhythm

5.1 First meeting agenda

  1. Situation report from the security or operations lead: facts, assumptions and unknowns, kept separate.
  2. Impact on people, customers, operations, legal duties and reputation.
  3. Priorities for the next [4] hours, in order.
  4. Immediate decisions (for example taking systems offline, engaging forensic or legal support, informing the insurer).
  5. Notification clocks that may have started (section 8).
  6. First communications: staff, customers, holding statement readiness.
  7. Next meeting time and owner of each action.

5.2 Decision principles

  • Protect people first, then customers, then the organization's ability to recover, then reputation and finances.
  • Separate facts from assumptions in every briefing, and say how confident the team is.
  • Prefer reversible decisions when uncertainty is high; record the trigger for revisiting them.
  • Record each decision with the options considered, the reasons and the owner, even when the decision is to wait.
  • Seek legal advice before any statement that admits cause or liability, but do not let legal review delay safety or regulatory notices.

5.3 Decision log

Decision IDTime (UTC)DecisionOptions consideredReasonsDecided byOwnerReview trigger
CD-001 (Example)2027-03-15 07:40Disconnect the office network and the managed service jump hosts from productionKeep running with extra monitoring, disconnectLateral movement seen in two systemsCrisis leadIncident commanderForensic confirmation of containment
CD-002 (Example)2027-03-15 08:10Publish a status page notice and e-mail affected customers within 2 hWait for full scope, notify nowCustomers already see failures; silence harms trustChief executiveCommunications leadNew facts on data exposure
[CD-NNN]YYYY-MM-DD hh:mm[decision][options][reasons][@decider][@owner][trigger]

5.4 Battle rhythm

Time (Example)ActivityParticipants
Every 4 h in the first 24 h, then twice dailyCrisis team meetingCrisis team
30 min before each meetingSituation report from the incident commanderIncident commander, security lead
After each meetingInternal update to staffCommunications lead, people lead
As agreed per audienceExternal updates (section 7)Communications cell
DailyBoard briefingCrisis lead, chief executive

6. Communication principles and approval

Principles:

  • Speak early, even if only to say what is known, what is being done and when the next update will come.
  • Be accurate. Never guess at cause, scope or numbers; say "we are investigating" instead.
  • Show care for those affected before talking about the organization.
  • Keep one source of truth: every message comes from the approved fact sheet maintained by the communications cell.
  • Tell staff before or at the same time as the public.
  • Give practical guidance to affected people (for example password resets or how to spot phishing that uses the event as a lure).
Message typeDrafted byApproved byTarget approval time (Example)
Internal staff updateCommunications leadCrisis lead30 min
Customer notice and status pageCommunications lead with customer successCrisis lead, legal lead60 min
Regulatory notificationLegal lead with data protection officerLegal lead, chief executiveWithin the legal deadline
Media statementCommunications leadChief executive, legal lead60 min
Investor or lender noticeFinance leadChief executive, legal leadAs required by law or contract

Only the chief executive, the communications lead and named deputies speak to media. All staff are reminded to refer media and social media questions to [press contact].

7. Stakeholder map and communication matrix

AudienceWhat they needOwnerChannelFirst contact (Example)Update frequency (Example)
Staff and contractorsWhat happened, what to do and not do, who to ask, welfare supportPeople leadOut-of-band messaging, all-staff callWithin 2 h of activationEvery crisis meeting
BoardSituation, decisions, exposure, support neededCrisis leadCall, briefing noteWithin 2 hDaily
Affected customersImpact on their service or data, actions they should take, next update timeCustomer success lead with communicationsE-mail, status page, account managersWithin the contractual period, aim 4 hAt least daily
All other customersWhether they are affected, reassurance based on factsCommunications leadStatus page, website noticeSame dayWhen status changes
Supervisory and competent authoritiesLegally required notificationsLegal leadRegulator portals or channels in the contact list (DOC-ISMS-069)Within legal deadlines (section 8)As required
Law enforcementReport of crime, evidence cooperationLegal lead with CISODesignated contactAs decided by the crisis teamAs requested
Insurer and breach counselNotice of claim, approval of external providersFinance lead, legal leadPolicy hotlineWithin the policy notice periodAs required
Critical suppliers and partnersActions needed (block, monitor, assist), confidentialitySupplier managerSupplier contacts in the supplier register (DOC-ISMS-066)Within 4 h when they must actAs needed
MediaShort factual statement, spokesperson availabilityCommunications leadPress release, websiteHolding statement ready within 1 h, released when neededWhen facts change
Investors and lendersMaterial information as requiredFinance leadDisclosure channelAs required by law or contractAs required
Affected individuals (data subjects)What happened to their data, risks, steps to protect themselves, contact pointData protection officerE-mail, letter, websiteWhen the high-risk threshold is met (section 8)Until closure

8. Regulators, authorities and notification duties

Record the time of awareness for each duty in the decision log. The examples below are international examples to check, not a complete or authoritative list.

Regime (Example)Who it applies toDutyDeadlineOwner
GDPR, Regulation (EU) 2016/679, Art. 33Controllers subject to the GDPR (territorial scope in Art. 3)Notify the supervisory authority of a personal data breach unless it is unlikely to result in a risk to peopleWithout undue delay and, where feasible, within 72 h of becoming awareData protection officer
GDPR, Art. 34ControllersInform affected individuals when the breach is likely to result in a high risk to themWithout undue delayData protection officer
GDPR, Art. 33(2)ProcessorsInform the controller (the customer)Without undue delayLegal lead, customer success
NIS2, Directive (EU) 2022/2555, Art. 23Essential and important entities under national lawEarly warning, incident notification and final report of a significant incident to the CSIRT or competent authority24 h, 72 h and one month after the notification, as transposed nationallyLegal lead with CISO
DORA, Regulation (EU) 2022/2554EU financial entitiesClassify and report major ICT-related incidents under the DORA technical standardsDeadlines set in the DORA technical standardsLegal lead
Contracts and data processing agreementsCustomersNotice of incidents affecting their data or serviceAs written in each contractCustomer success lead
[Sector or national rule][scope][duty][deadline][@owner]

Use the personal data breach assessment (compliance/personal-data-breach-assessment) to decide whether the GDPR thresholds are met and to record the reasoning, including decisions not to notify.

9. Holding statements and message templates

Holding statement for media and website (first hours):

[Organization name] is responding to [an incident affecting some of our
systems / a disruption to our services] identified on [date]. We acted
immediately to [contain the issue / protect our customers' information]
and are working with [specialist advisers]. Our priority is the
[safety of our people and] service to our customers. We will share more
information at [time or channel]. Customers with questions can contact
[contact point].

First customer notice (affected customers):

Subject: Service incident affecting [service], [date]

We are writing to tell you about an incident that affects [service].
What happened: on [date and time UTC] we identified [short factual
description]. What we are doing: [containment and recovery actions].
What this means for you: [impact known so far, or "we are still
investigating whether your data is affected"]. What you can do now:
[practical steps]. We will update you by [time] and at least [daily].
Contact: [named contact and channel].

Internal staff message:

Team, we are managing [an incident affecting our systems]. The crisis
team is leading the response. Please: do not discuss the incident on
social media or with anyone outside the company; send any media or
customer questions to [contact]; follow instructions from IT about
[systems or passwords]; report anything suspicious to [security
contact]. Your welfare matters: contact [people lead] if you need
support. Next update at [time].

Statement after containment:

[Organization name] has contained the incident identified on [date].
[Services are restored / Most services are restored, with remaining
services expected by date]. Our investigation, supported by [independent
specialists], has found [confirmed facts]. We have [notified relevant
authorities and affected customers]. We have taken steps to [prevent a
repeat]. We apologise for the disruption and thank our customers for
their patience.

10. Cyber crisis scenario: ransomware with data theft

Setting (Example): Quillmere Health Systems (320 staff), clinical scheduling software and managed service for hospitals. On a Monday morning, scheduling services for hospital customers fail and files on the managed service hosts are encrypted. A ransom note claims that patient appointment data has been copied and will be published in 7 days.

Time from detection (Example)EventCrisis team action
0 h 00Monitoring alerts on mass file changes; incident commander declares top severityIncident commander calls the crisis lead (criteria C1, C4)
0 h 25Crisis lead activates the teamCoordinator opens decision log, team assembles on the out-of-band bridge
1 h 00First meetingCD-001 disconnect affected segments, engage forensic provider and breach counsel, inform the insurer, record awareness time for notification clocks
1 h 30Hospitals report missed appointment bookingsCD-002 status page notice and customer e-mail within 2 h; hospitals advised to use manual booking workaround from the BCP
3 h 00Forensic triage confirms data staging on one serverLegal lead and data protection officer start breach assessment; as processor, inform controller hospitals without undue delay
6 h 00Backup integrity confirmed on immutable copiesICT recovery manager plans restore under the ICT readiness plan
20 h 00NIS2 assessment: entity in scope under national law, incident significantLegal lead submits early warning before 24 h
30 h 00Ransom stance decidedCrisis team records decision and reasons with counsel, in line with law and sanctions checks
48 h 00Core scheduling restored for 90% of hospital customersContainment statement released, staff update, customer calls
70 h 00Incident notification to the authorityLegal lead submits before 72 h
Day 10All services restored, monitoring increasedStand-down decision prepared (section 11)

Key questions for the exercise:

  • Who decides to disconnect services that hospitals depend on, and how is clinical safety considered?
  • How do the processor duties to hospitals and any direct duties under NIS2 fit together, and who speaks to which regulator?
  • What do staff tell hospital users who call before the customer notice is out?
  • What evidence does the team need before saying data was or was not taken?

11. Stand-down, recovery and review

Stand down when:

  • the situation is stable and handed to normal incident, continuity or project management;
  • remaining legal notifications have owners and dates;
  • customer and staff communication has moved to normal channels;
  • the decision log is complete and stored.

After stand-down:

  1. Hold a post-incident review within [10] working days (isms/post-incident-review), covering both the response and the crisis management: timeliness of activation, quality of decisions, communication effectiveness, stakeholder feedback.
  2. Enter actions in the corrective action process (DOC-ISMS-087) and the continual improvement register (DOC-ISMS-088).
  3. Update this plan, the holding statements and the contact annex.
  4. Report the crisis and lessons to management review (DOC-ISMS-085) and to the board.
  5. Plan follow-up communication with affected customers and individuals.

12. Training and exercises

Exercise typePurposeFrequency (Example)Participants
Contact and call-out testProve the team can be reached and assembled out of hoursQuarterlyAll members and deputies
Plan walkthroughFamiliarize new members, check roles and contactsOn joining, and annuallyNew members
Tabletop exercisePractise decisions and communications on a scenarioTwice a yearCrisis team, incident commander, BC lead
Joint exerciseTest interfaces with incident response, BCP and ICT recovery togetherAnnuallyCrisis, incident and recovery teams
Media trainingPrepare spokespeopleAnnuallyChief executive, communications lead, deputies

Each exercise has objectives, an observer who records performance and a short report with actions (security/tabletop-exercise).

13. Size tiers

AspectSmall: Quillmere Analytics Ltd (46 staff)Medium: Quillmere Health Systems (320 staff)Large: Quillmere Group (2,400 staff, 6 sites)
Crisis team5 people: CEO (lead), Head of Engineering Operations (security and continuity), finance lead, a founder for communications, external breach counsel on retainer8 roles as in section 3, with the full-time ISMS manager as crisis coordinatorGroup crisis team plus a site crisis team at each of the 6 sites; country leads in the 4 countries
CommunicationsStatus page, customer e-mail, one spokespersonCommunications lead plus customer success for hospital customersGroup communications with country press contacts and local languages
RegulatorsCustomers as controllers; supervisory authority only for own staff and marketing dataHospitals as controllers, own controller duties, possible NIS2 duties as a managed service provider (ICT service management, NIS2 Annex I) under national lawSeveral regulators in 4 countries; OT safety authorities for plants
ExercisesOne tabletop and two call-out tests a yearProgramme in section 12Group exercise plus site exercises, aligned with the existing ISO 22301 programme
IntegrationOne document with the BCPSeparate plan linked to BCP and incident responsePart of the integrated management system, alongside the certified ISO 22301 BCMS

14. Records and evidence

RecordProvesOwnerLocationRetention (Example)
Approved plan and revision historyPlan is controlled and currentCrisis leadDocument management system and offline copiesCurrent plus 3 superseded versions
Contact annex verification logContacts are currentCrisis coordinatorContact annex3 years
Activation records, decision logs, action trackersPlan was used and decisions can be explainedCrisis coordinatorRestricted crisis folderAt least 6 years, or longer if litigation is possible
Communications issued (final versions with time and approver)Messages were approved and timelyCommunications leadRestricted crisis folderAt least 6 years
Regulatory notifications and acknowledgementsLegal duties were metLegal leadLegal register (DOC-ISMS-014), incident register (DOC-ISMS-021)As required by law
Exercise reports and actionsTeam is trained and plan is testedCrisis leadExercise records3 years
Post-incident review reportsLessons were learnedISMS managerDOC-ISMS-0223 years

Set final retention in the documented information register (DOC-ISMS-028) after legal advice.

15. References

ReferenceEditionUse
ISO 22361:2022, security and resilience, crisis management, guidelines2022Crisis leadership, decision-making and communication concepts (cited)
ISO 22301:2019 + Amd 1:2024, business continuity management systems, requirements2019, Amd 1 2024Response structure and link to business continuity
ISO/IEC 27001:2022 + Amd 1:2024, information security management systems, requirements2022, Amd 1 published 2024-02-23A.5.5, A.5.24 to A.5.29
ISO/IEC 27035-1:2023, information security incident management, principles and process2023Interface with incident management
Regulation (EU) 2016/679 (GDPR)As amendedArticles 33 and 34 breach notification
Directive (EU) 2022/2555 (NIS2)OJ L 333, 27.12.2022Article 23 reporting obligations, as transposed nationally
Regulation (EU) 2022/2554 (DORA)OJ L 333, 27.12.2022Major ICT-related incident reporting for financial entities

Related templates: compliance/incident-response-plan, compliance/business-continuity, isms/ict-readiness-business-continuity-plan, ops/incident-commander-handbook, ops/incident-severity-matrix, security/tabletop-exercise, compliance/personal-data-breach-assessment, isms/authority-special-interest-contacts, isms/isms-communication-plan, isms/post-incident-review, isms/supplier-register, isms/control-evidence-matrix.

Standard and licence note

Structure aligned with the crisis management guidance of ISO 22361:2022 and with ISO/IEC 27001:2022 (including Amd 1:2024) Annex A controls A.5.5 and A.5.24 to A.5.29. The team structure, criteria, matrices, holding statements, scenario and guidance are original wording. ISO/IEC text is not reproduced: standards are cited by number and clause or control number only, with short descriptions written for this template. ISO and IEC standards are copyrighted; obtain the official standards from ISO or your national standards body before relying on this template. Check the current edition of each standard and the current text of each law before use. This is a documentation format, not legal advice. Template licence: MIT.

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