Tabletop Exercise Script for Incident Response Plan

You are a cybersecurity and regulatory compliance expert tasked with developing a comprehensive tabletop exercise script to test an organization's Incident Response (IR) Plan. This exercise must rigorously evaluate the organization's preparedness for cybersecurity incidents while ensuring strict compliance with applicable data breach notification laws, regulatory requirements, and industry best practices. The final deliverable should be a complete, ready-to-execute tabletop exercise script that can be immediately deployed by the organization's incident response team and leadership.

Document Research and Contextual Foundation

Before drafting the tabletop exercise script, conduct thorough research of any existing incident response plans, cybersecurity policies, regulatory compliance documentation, and previous incident reports that have been provided. Extract specific procedural details, notification timelines, escalation hierarchies, and regulatory obligations that are documented in these materials. Identify the organization's industry sector, applicable regulatory frameworks such as GDPR, CCPA, HIPAA, GLBA, PCI DSS, or sector-specific requirements like NERC CIP for energy or DFARS for defense contractors. Note any specific breach notification deadlines, such as GDPR's 72-hour requirement or state-specific timelines that may range from immediate notification to 90 days. Document the organization's data holdings, particularly any personal information, protected health information, payment card data, or other regulated data types that would trigger specific notification obligations if compromised.

Examine the organizational structure to understand reporting relationships, decision-making authority during crises, and the composition of any existing incident response team or crisis management committee. Identify key stakeholders including the Chief Information Security Officer, General Counsel, Chief Privacy Officer, Chief Executive Officer, communications leadership, and relevant business unit heads. Review any existing tabletop exercise reports or after-action reviews to understand previously identified gaps and ensure this exercise addresses those deficiencies while introducing new challenges that reflect the evolving threat landscape.

Scenario Development and Threat Modeling

Craft a detailed, realistic scenario that presents a credible cybersecurity threat tailored to the organization's specific risk profile, industry sector, and operational environment. The scenario should reflect current threat actor tactics, techniques, and procedures as documented in frameworks such as MITRE ATT&CK, while remaining accessible to non-technical participants. Consider scenarios such as ransomware attacks with data exfiltration that trigger both operational disruption and breach notification requirements, business email compromise leading to fraudulent wire transfers and credential harvesting, supply chain attacks through compromised third-party vendors or software updates, insider threats involving unauthorized access to sensitive customer or employee data, or sophisticated advanced persistent threat campaigns targeting intellectual property or regulated information.

The initial scenario description should establish the date and time of the exercise, the organization's current operational status, any relevant contextual factors such as recent system changes or ongoing projects, and the first indication of suspicious activity. Present this initial information as it would realistically come to the attention of the organization—perhaps through a security alert from an intrusion detection system, a help desk ticket reporting unusual system behavior, a notification from a third-party security researcher, or a customer complaint about suspicious account activity. Provide sufficient technical detail to ground the scenario in reality while ensuring that non-technical participants can understand the implications and participate meaningfully in decision-making discussions.

Establish three to five specific, measurable objectives that align with both the organization's IR Plan and regulatory compliance obligations. These objectives should test whether participants can accurately assess incident severity and determine appropriate escalation procedures within documented timeframes, whether the organization can identify the threshold at which regulatory notification becomes mandatory and initiate those notifications within required deadlines, whether communication protocols effectively coordinate technical response teams with legal counsel and executive leadership, whether the organization can maintain business continuity while containing the incident and preserving forensic evidence, and whether participants understand their individual roles and can execute their responsibilities under pressure with incomplete information.

Participant Roles and Pre-Exercise Preparation

Identify all participants who should be involved in this tabletop exercise, specifying their actual organizational roles and the responsibilities they would assume during a real incident. The core incident response team should include the Incident Response Manager who coordinates technical response activities and serves as the primary liaison between technical teams and leadership, cybersecurity analysts and engineers who perform technical investigation and implement containment measures, IT operations personnel who manage system availability and recovery procedures, and forensic specialists or their designated internal counterparts who ensure evidence preservation and support potential law enforcement engagement.

The legal and compliance contingent must include General Counsel or designated legal representatives who provide legal guidance on notification obligations and litigation risk, the Chief Privacy Officer or Data Protection Officer who assesses personal data impact and manages regulatory notifications, compliance officers who ensure adherence to industry-specific requirements, and outside counsel if the organization typically engages external legal support for breach response. Executive leadership participation should encompass the Chief Executive Officer or designated crisis management authority who makes strategic decisions about business continuity and external communications, the Chief Information Security Officer who translates technical findings into business risk assessments, relevant business unit leaders whose operations may be affected, and the Chief Financial Officer if the incident has financial reporting implications or affects financial systems.

Communications and stakeholder management roles should include corporate communications or public relations leadership who manage media relations and public statements, customer service leadership who coordinate responses to customer inquiries, human resources representatives if employee data is compromised or if the incident involves potential insider threats, and investor relations if the organization is publicly traded and the incident may be material. For each participant, provide pre-exercise materials including relevant sections of the IR Plan, their specific role description and decision-making authority, any regulatory notification templates or checklists they may need to reference, and background information about the organization's systems, data holdings, and regulatory obligations sufficient to enable informed participation.

Progressive Scenario Injects and Decision Points

Design a series of four to five scenario injects that progressively escalate the incident complexity, introduce time pressure, and test different aspects of the IR Plan and regulatory compliance framework. Each inject should be presented on a separate page or slide with a timestamp indicating how much time has elapsed since the initial incident detection, new information that has come to light, specific questions that participants must address, and expected outputs or decisions that should result from discussing this inject.

The first inject presents the initial incident detection and tests the organization's ability to recognize a potential security event, initiate the IR Plan, and execute initial response procedures. Describe the specific indicators of compromise such as unusual network traffic patterns, unexpected system behavior, security tool alerts, or user reports. Provide enough technical detail to enable meaningful discussion about whether this represents a false positive, a minor security event, or a potentially significant incident requiring full IR Plan activation. Participants should discuss and document their initial assessment of incident severity using the organization's classification framework, immediate containment actions to prevent further compromise while preserving evidence for forensic analysis, notification and escalation procedures including who must be informed immediately and through what channels, preliminary scope assessment to identify potentially affected systems and data, and evidence preservation measures to support forensic investigation and potential regulatory reporting or litigation.

The second inject escalates the incident by revealing that the compromise is more extensive than initially assessed, introducing complications that test containment strategies and cross-functional coordination. Present findings from initial forensic investigation such as evidence of lateral movement across the network, indicators that sensitive data may have been accessed or exfiltrated, discovery of persistent backdoors or additional malware, or identification of the attack vector such as a compromised vendor connection or successful phishing campaign. This inject should force participants to grapple with whether the incident has crossed the threshold requiring regulatory notification, what additional containment measures are necessary even if they disrupt business operations, whether to engage external forensic investigators and legal counsel, how to coordinate technical response with legal evidence preservation requirements, and what preliminary notifications should be made to cyber insurance carriers, law enforcement, or regulatory bodies.

The third inject introduces external pressures and communication challenges that require careful legal and strategic judgment. Present one or more complications such as a ransom demand from the threat actor including proof of data exfiltration and threats to publish stolen data, media inquiries indicating that news of the incident has leaked publicly, notifications from customers or business partners who have detected suspicious activity potentially related to the incident, or preliminary contact from a regulatory authority requesting information about the organization's response. Participants must discuss and decide how to respond to threat actor communications while avoiding actions that could be construed as negotiating with criminals in violation of sanctions laws, what information can be disclosed publicly and what must be withheld to protect the investigation or avoid prejudicing regulatory proceedings, whether the organization has sufficient information to make required regulatory notifications or whether additional investigation is needed, how to coordinate messaging across legal, communications, and technical teams to ensure consistency, and what notifications must be made to affected individuals, customers, or business partners under contractual or regulatory obligations.

The fourth inject advances the timeline to test recovery decision-making and regulatory notification execution. Present a scenario where forensic investigation has reached preliminary conclusions about the scope of compromise, the organization must decide whether to restore systems from backups or rebuild from scratch, regulatory notification deadlines are approaching or have arrived, and affected individuals must be notified according to applicable breach notification laws. Participants should address whether the forensic findings are sufficient to meet regulatory requirements for describing the nature and scope of the breach, what specific data elements were compromised and how many individuals are affected, what notifications must be sent to regulatory authorities such as state attorneys general, the HHS Office for Civil Rights, or European data protection authorities, what content must be included in individual notifications and through what method they will be delivered, whether credit monitoring or other remediation services should be offered to affected individuals, and what public disclosures are required for publicly traded companies or regulated entities.

Consider adding a fifth inject if needed to address specific regulatory scenarios such as cross-border data transfer implications requiring notifications to multiple international regulators, third-party vendor involvement requiring coordination with the vendor's incident response and notification to other affected organizations, law enforcement requests for information or requests to delay public notification, or sector-specific requirements such as NERC CIP reporting for critical infrastructure or SEC disclosure obligations for material cybersecurity incidents.

Facilitation Guidance and Exercise Mechanics

Provide detailed facilitation guidance for the exercise leader who will guide participants through the scenario. The facilitator should begin with a clear statement of exercise objectives, ground rules emphasizing that this is a learning environment where honest discussion is valued over demonstrating perfect knowledge, and logistical details about timing and breaks. Explain that the facilitator's role is to present each inject, pose probing questions to stimulate discussion, ensure all participants have opportunities to contribute, keep the exercise moving according to the timeline, and document key observations and decisions without judging or correcting participants during the exercise itself.

For each inject, provide the facilitator with specific discussion questions designed to test whether participants understand their roles and the IR Plan procedures, whether they can identify the relevant regulatory requirements and notification triggers, whether they recognize the need to coordinate across technical, legal, and business functions, and whether they can make risk-based decisions with incomplete information under time pressure. Include guidance about how long to spend on each inject, what key points should emerge from the discussion, and what red flags might indicate significant gaps in the IR Plan or participant understanding that should be noted for the debrief session.

Debrief, Evaluation, and Remediation Planning

Conclude the exercise with a structured debrief session designed to capture observations, identify gaps, and develop actionable remediation plans. The facilitator should guide participants through a systematic review of the exercise beginning with what went well, including effective procedures, good decision-making, and successful coordination. Progress to identifying challenges and gaps such as unclear procedures or authorities in the IR Plan, insufficient understanding of regulatory notification requirements or timelines, communication breakdowns between teams or with leadership, resource constraints or capability gaps that hindered effective response, and unrealistic assumptions in the IR Plan about available information or decision-making speed.

For each identified gap or challenge, facilitate discussion about root causes and potential solutions. Document specific remediation actions with sufficient detail to enable implementation, including updates needed to the IR Plan or supporting procedures, additional training or exercises needed for specific teams or individuals, resources or capabilities that should be acquired such as forensic retainer agreements or automated notification systems, and process improvements to enhance coordination or decision-making. Assign each remediation action to a specific owner with a realistic target completion date and establish a follow-up process to track implementation and verify that improvements are effective.

Prepare a comprehensive after-action report that documents the exercise scenario and objectives, participant list and roles, key observations and findings organized by IR Plan phase or functional area, identified gaps with associated risk assessments, remediation actions with owners and timelines, and recommendations for future exercises to test improvements or address additional scenarios. This report should be distributed to exercise participants, executive leadership, and any governance bodies responsible for cybersecurity oversight such as the board of directors or audit committee, ensuring that lessons learned translate into tangible improvements in the organization's incident response capabilities and regulatory compliance posture.