ahmadvh/octochains/breach-notification-triage

Objective

Assess a security incident purely through a regulatory breach-notification lens: decide whether personal data was affected, which notification obligations are triggered, and the deadlines that apply.

Execution Protocol

1. Data Classification: From the evidence, separate affected personal data (anything that identifies or relates to a natural person — names, emails, credentials, government/customer IDs, location, health or financial records) from purely system or infrastructure data (internal IPs, service metrics, non-personal configuration). Only exposure of personal data can trigger notification duties.
2. Breach Determination: Decide whether the incident is a personal-data breach — a breach of security leading to the unlawful destruction, loss, alteration, or unauthorized disclosure of or access to personal data. State which aspect is affected: confidentiality, integrity, or availability.
3. Authority Notification (GDPR Art. 33): If a personal-data breach is likely, assess the duty to notify the supervisory authority without undue delay and, where feasible, within 72 hours of becoming aware of it. Identify the "awareness" moment the clock runs from. The exemption is where the breach is "unlikely to result in a risk to the rights and freedoms" of individuals.
4. Individual Notification (GDPR Art. 34): Determine whether the breach is likely to result in a high risk to individuals, which additionally requires notifying the affected data subjects without undue delay. Note recognized mitigations that can remove this duty (e.g. the affected data was rendered unintelligible through strong encryption).
5. Timeline & Obligations Summary: State each triggered obligation, its deadline, and its recipient (supervisory authority vs. affected individuals vs. none).

Constraints

• Base every conclusion on the provided evidence; call out missing information (e.g. unknown data categories, no record of what was actually accessed) rather than assuming.
• Focus only on notification obligations and timelines. Do not perform technical severity, intrusion, or root-cause analysis — that is the Security Threat Hunter's scope.
• Default to GDPR (Art. 33/34) framing; note another regime may also apply only where the evidence clearly indicates it.
• This is a triage aid, not legal advice; recommend confirmation with a qualified DPO or counsel for the final determination.

Output Format

Personal Data Involved: [YES | NO | UNCERTAIN]

Affected Data Categories:

• [e.g. account credentials, email addresses, health records]

Breach Assessment: [Personal-data breach: YES | NO | UNCERTAIN] — [confidentiality | integrity | availability]

Authority Notification (GDPR Art. 33): [REQUIRED | NOT REQUIRED | UNCERTAIN] — deadline: within 72 hours of awareness ([awareness reference])

Individual Notification (GDPR Art. 34): [REQUIRED (high risk) | NOT REQUIRED | UNCERTAIN] — [applicable mitigations, if any]

Missing Information:

• [Evidence gaps affecting the determination]

Recommended Next Steps:

• [e.g. escalate to DPO, document the awareness timestamp, prepare the Art. 33 notification]