The finding that should be of greatest concern to senior management is that response decisions were made without consulting the appropriate authority. This is because response decisions are critical actions that can affect the outcome and impact of a security incident, and they should be made by the designated authority who has the responsibility and accountability for the incident response. According to CISA, the Department of Justice, through the FBI and the NCIJTF, is thelead agency for threat response during a significant incident, with DHS’s investigative agencies—the Secret Service and ICE/HSI - playing a crucial role in criminal investigations1. If response decisions are made without consulting the appropriate authority, it may result in:

Legal or regulatory violations: The response actions may not comply with the applicable laws or regulations, such as data breach notification, evidence preservation, or privacy protection. This may expose the organization to legal or regulatory penalties, lawsuits, or reputational damage.

Ineffective or counterproductive actions: The response actions may not be aligned with the incident response plan, best practices, or standard operating procedures. This may cause more harm than good, such as escalating the incident, destroying evidence, or compromising recovery efforts.

Lack of coordination and communication: The response actions may not be coordinated or communicated with the relevant stakeholders, such as senior management, legal counsel, public relations, or external partners. This may lead to confusion, inconsistency, or mistrust among the parties involved in the incident response.

Therefore, senior management should be most concerned about the finding that response decisions were made without consulting the appropriate authority, and they should take corrective actions to prevent this from happening again in the future. References: Cybersecurity Incident Response | CISA1