{"id":2777,"date":"2026-06-01T10:33:44","date_gmt":"2026-06-01T10:33:44","guid":{"rendered":"https:\/\/sawaryn.com\/uslugi\/incident-and-breach-response\/"},"modified":"2026-07-14T16:40:27","modified_gmt":"2026-07-14T16:40:27","slug":"incident-and-breach-response","status":"publish","type":"service","link":"https:\/\/sawaryn.com\/en\/uslugi\/incident-and-breach-response\/","title":{"rendered":"Incident and Breach Response"},"excerpt":{"rendered":"<p>We\u2019ll determine whether this constitutes a personal data breach. We\u2019ll let you know if you need to report the matter to the UODO and whether you need to notify the data subjects. We\u2019ll provide you with a clear list of steps to take. In urgent cases, we\u2019ll get back to you with an initial assessment within just a few hours.   <\/p>\n","protected":false},"featured_media":0,"template":"","meta":{"_acf_changed":false},"specialization":[1215],"practice_area":[],"class_list":["post-2777","service","type-service","status-publish","hentry","specialization-gdpr"],"acf":{"short_description":"We will check whether this is a personal data breach. We will tell you whether the matter must be reported to the UODO and whether the individuals concerned must be notified. You will receive a clear list of steps from us. In urgent matters, we return with an initial assessment within a few hours.","full_description":"<strong>Data breach? We will tell you what it means and what to do.<\/strong>\n\nWe will check whether this is a personal data breach. We will tell you whether the matter must be reported to the UODO and whether the individuals concerned must be notified. You will receive a clear list of steps from us. In urgent matters, we return with an initial assessment within a few hours.\n\nTo start: a fast assessment and a plan for the first hours.\n<h2>CLIENT PROBLEM<\/h2>\nAfter an incident, three questions arise: what is it, what must we do, and who decides. Without that, chaos comes easily, and time is usually short.\n\n\"First we organise the facts. Then we take a decision that can be clearly justified - inside the company and externally.\"\n\nIT gathers the facts, the business wants to limit the impact, and the legal and data-protection teams must close out their duties. The management board needs one answer: what we are doing and why. We step in immediately and organise the matter step by step.\n<h2>MOST COMMON PROBLEMS \/ CHALLENGES<\/h2>\n<strong>Is this even a breach?<\/strong>\n\nNot every incident is a data breach. But a wrong classification costs you: either you trigger procedures unnecessarily, or you are late with what must be done.\n\nWe will check whether the event triggers GDPR duties and tell you what to do straight away. You receive a list of actions for the first hours and information on what is still missing for the next decisions.\n\n<strong>Business benefit:<\/strong> a fast start on the right actions and fewer internal disputes.\n\n<strong>Risk of inaction:<\/strong> delays and decisions taken without a proper basis.\n\n<strong>You have little information, but decisions are already needed<\/strong>\n\nAt the start it is rarely clear exactly what happened and whom it affects. Even so, you must watch deadlines and avoid making the problem worse.\n\nWe will set priorities for the first hours and help you decide with incomplete information. We will also clarify who does what so actions do not diverge across departments.\n\n<strong>Business benefit:<\/strong> control over actions and fewer unnecessary moves.\n\n<strong>Risk of inaction:<\/strong> dragging out decisions and a higher risk of formal errors.\n\n<strong>It is unclear who is responsible for what<\/strong>\n\nIT, legal, data protection, the business, the management board and external providers each see the incident from a different angle. Without one action path, conflicting decisions and communication chaos appear quickly.\n\nWe define roles, responsibilities and the sequence of actions. We indicate who decides, what duties arise from contracts with counterparties, and how to protect the company's position.\n\n<strong>Business benefit:<\/strong> fewer misunderstandings between departments and faster decisions by the management board.\n\n<strong>Risk of inaction:<\/strong> blurred accountability, internal conflicts and errors in communication with partners.\n\n<strong>Report to the UODO or not?<\/strong>\n\nThis is one of the hardest decisions after an incident. The company must not only choose a direction, but also be able to justify and document it.\n\nWe assess the reporting duty, prepare the rationale for the position taken, and support preparation of the report if it is needed.\n\n<strong>Business benefit:<\/strong> greater certainty of the decision and coherent documentation if questions or further verification arise.\n\n<strong>Risk of inaction:<\/strong> a late response, an incomplete report, or no rationale for the position taken.\n\n<strong>Whether and how to notify individuals<\/strong>\n\nYou do not always have to notify individuals. If you do - the message must be clear and complete, because mistakes return as questions, complaints and extra work.\n\nWe will say whether notification is required. If it is - we will prepare the message: plain, factual and without unnecessary risks.\n\n<strong>Business benefit:<\/strong> greater control over the message and fewer misunderstandings.\n\n<strong>Risk of inaction:<\/strong> inconsistent information, extra questions and communication chaos.\n\n<strong>How to close the matter and not face the same problem in a month?<\/strong>\n\nAfter the first response, many companies simply want to \"close the topic\". Without a summary and a remediation plan, the incident leaves open risks.\n\nWe prepare a summary of the event, decisions and remediation recommendations. You receive material for the management board and a change plan that genuinely reduces the risk of recurrence.\n\n<strong>Business benefit:<\/strong> concrete conclusions, clear responsibilities and greater readiness for the future.\n\n<strong>Risk of inaction:<\/strong> repeating the same mistakes and \"closing\" the matter only on paper.\n<h2>HOW OUR SOLUTION WORKS<\/h2>\nFrom the first classification to the remediation plan\n\nWe do not leave you with interpretation alone. We walk through the decisions and documents so you know what to do at each moment - and have it properly described.\n\n<strong>Fast classification of the event<\/strong>\n<ul>\n \t<li>We gather the key facts.<\/li>\n \t<li>We separate what we know from what still needs to be established.<\/li>\n \t<li>We make a preliminary assessment of whether this is a personal data breach.<\/li>\n \t<li>We set priorities for the first hours.<\/li>\n<\/ul>\n<strong>Result:<\/strong> Preliminary classification of the event and a list of urgent decisions.\n\n<strong>Analysis of the scale and effects of the incident<\/strong>\n<ul>\n \t<li>We describe what happened and how it came about.<\/li>\n \t<li>We estimate the scale and possible effects for individuals.<\/li>\n \t<li>We identify risks and propose scenarios for further action.<\/li>\n<\/ul>\n<strong>Result:<\/strong> Risk assessment and scenarios for further action.\n\n<strong>Assessment of duties toward the authority<\/strong>\n<ul>\n \t<li>Analysis of the duty to notify the President of the UODO.<\/li>\n \t<li>Preparation of the rationale for the position taken.<\/li>\n \t<li>Indication of a safe and practical course of action.<\/li>\n \t<li>Support for decisions under time pressure.<\/li>\n<\/ul>\n<strong>Result:<\/strong> Recommendation: we report \/ we do not report, with rationale.\n\n<strong>Preparing the notification and documentation<\/strong>\n<ul>\n \t<li>Drafting the breach notification.<\/li>\n \t<li>circumstances, effects and measures taken.<\/li>\n \t<li>Organising the material for the management board and the operational team.<\/li>\n \t<li>Securing consistency of the position and documentation.<\/li>\n<\/ul>\n<strong>Result:<\/strong> Ready incident documentation and a full set of materials for further action.\n\n<strong>Support for communication to individuals and partners<\/strong>\n<ul>\n \t<li>Assessment of whether the individuals concerned must be notified.<\/li>\n \t<li>Setting the direction and content of communication.<\/li>\n \t<li>Analysis of duties toward counterparties, processors and partners.<\/li>\n \t<li>Support in organising communication among stakeholders.<\/li>\n<\/ul>\n<strong>Result:<\/strong> A communication plan and recommendations for relations with individuals and partners.\n\n<strong>Closing the matter and a remediation plan<\/strong>\n<ul>\n \t<li>Summary of the event and decisions taken.<\/li>\n \t<li>Remediation recommendations.<\/li>\n \t<li>Indication of process and organisational changes.<\/li>\n \t<li>An action plan reducing the risk of the incident recurring.<\/li>\n<\/ul>\n<strong>Result:<\/strong> A summary for the management board or team and a post-incident remediation plan.\n<h2>WHO THIS SERVICE IS FOR<\/h2>\nFor organisations that, after an incident, must move quickly to the right decisions\n\nFor situations where, after an incident, you must move quickly from \"we do not know\" to decisions and action - without chaos between departments.\n<ul>\n \t<li>Data Protection Officer \/ person responsible for data protection<\/li>\n<\/ul>\nWhen you need to establish quickly whether a breach occurred and which duties to trigger.\n<ul>\n \t<li>Legal team \/ head of compliance<\/li>\n<\/ul>\nWhen you need a risk assessment, a recommendation for the management board and coherent documentation.\n<ul>\n \t<li>Management board \/ chief operating officer<\/li>\n<\/ul>\nWhen a fast decision, risk limitation and organised team action matter.\n<h2>STAGES OF WORK<\/h2>\nHow collaboration looks step by step\n\nIn an incident, the sequence of actions matters. That is why we work in stages: we gather facts, take decisions, prepare documents and close the matter with a remediation plan.\n\n<strong>Stage 1. Recognition and classification<\/strong>\n\nWe gather the most important information, organise what is known, and assess whether a breach occurred and which decisions are urgent here and now.\n\n<strong>What the client gains:<\/strong> A clear starting point, priorities for the first hours and less improvisation.\n\n<strong>Stage 2. Analysis and decisions<\/strong>\n\nWe assess the scale and effects of the incident. We check duties toward the UODO, individuals and partners. At the end you receive a recommendation: what we are doing and why.\n\n<strong>What the client gains:<\/strong> A basis for decisions, a lower risk of error and greater control of the situation.\n\n<strong>Stage 3. Documentation and communication<\/strong>\n\nWe prepare notifications, rationales and materials needed for further action. We also help shape communication so it is coherent and understandable.\n\n<strong>What the client gains:<\/strong> Organised documentation, coherent messages and less risk of secondary escalation.\n\n<strong>Stage 4. Remediation actions<\/strong>\n\nWe summarise the event, decisions and risks. We indicate what must be improved organisationally and in process terms to reduce the risk of recurrence.\n\n<strong>What the client gains:<\/strong> A remediation plan, material for the management board and practical conclusions for the future.","icon":null,"order_within_specialization":0,"flexible_content":[{"acf_fc_layout":"hero","section_header":{"section_header":{"eyebrow":"","heading":"Naruszenie danych? Powiemy Ci, co to oznacza i co zrobi\u0107.","heading_highlight_mode":"split","heading_split":{"small_part_text":"Data breach?","strong_part_text":"We will tell you what it means and what to do.","":null,"small_part_size":"","strong_part_size":"","tag":"h2","style":"inherit","alignment":"inherit"},"description":"We will check whether this is a personal data breach. We will tell you whether the matter must be reported to the UODO and whether the individuals concerned must be notified. You will receive a clear list of steps from us. 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But a wrong classification costs you: either you trigger procedures unnecessarily, or you are late with what must be done.","solution_title":"","solution_description":"<p>We will check whether the event triggers GDPR duties and tell you what to do straight away. You receive a list of actions for the first hours and information on what is still missing for the next decisions.<\/p>\n\n<p><strong>Business benefit:<\/strong> a fast start on the right actions and fewer internal disputes.<\/p>\n\n<p><strong>Risk of inaction:<\/strong> delays and decisions taken without a proper basis.<\/p>","icon":"","accent":"pink","open":false},{"problem_title":"You have little information, but decisions are already needed","teaser_description":"At the start it is rarely clear exactly what happened and whom it affects. Even so, you must watch deadlines and avoid making the problem worse.","solution_title":"","solution_description":"<p>We will set priorities for the first hours and help you decide with incomplete information. We will also clarify who does what so actions do not diverge across departments.<\/p>\n\n<p><strong>Business benefit:<\/strong> control over actions and fewer unnecessary moves.<\/p>\n\n<p><strong>Risk of inaction:<\/strong> dragging out decisions and a higher risk of formal errors.<\/p>","icon":"","accent":"violet","open":false},{"problem_title":"It is unclear who is responsible for what","teaser_description":"IT, legal, data protection, the business, the management board and external providers each see the incident from a different angle. Without one action path, conflicting decisions and communication chaos appear quickly.","solution_title":"","solution_description":"<p>We define roles, responsibilities and the sequence of actions. We indicate who decides, what duties arise from contracts with counterparties, and how to protect the company's position.<\/p>\n\n<p><strong>Business benefit:<\/strong> fewer misunderstandings between departments and faster decisions by the management board.<\/p>\n\n<p><strong>Risk of inaction:<\/strong> blurred accountability, internal conflicts and errors in communication with partners.<\/p>","icon":"","accent":"blue","open":false},{"problem_title":"Report to the UODO or not?","teaser_description":"This is one of the hardest decisions after an incident. The company must not only choose a direction, but also be able to justify and document it.","solution_title":"","solution_description":"<p>We assess the reporting duty, prepare the rationale for the position taken, and support preparation of the report if it is needed.<\/p>\n\n<p><strong>Business benefit:<\/strong> greater certainty of the decision and coherent documentation if questions or further verification arise.<\/p>\n\n<p><strong>Risk of inaction:<\/strong> a late response, an incomplete report, or no rationale for the position taken.<\/p>","icon":"","accent":"orange","open":false},{"problem_title":"Whether and how to notify individuals","teaser_description":"You do not always have to notify individuals. If you do - the message must be clear and complete, because mistakes return as questions, complaints and extra work.","solution_title":"","solution_description":"<p>We will say whether notification is required. If it is - we will prepare the message: plain, factual and without unnecessary risks.<\/p>\n\n<p><strong>Business benefit:<\/strong> greater control over the message and fewer misunderstandings.<\/p>\n\n<p><strong>Risk of inaction:<\/strong> inconsistent information, extra questions and communication chaos.<\/p>","icon":"","accent":"pink","open":false},{"problem_title":"How to close the matter and not face the same problem in a month?","teaser_description":"After the first response, many companies simply want to \"close the topic\". Without a summary and a remediation plan, the incident leaves open risks.","solution_title":"","solution_description":"<p>We prepare a summary of the event, decisions and remediation recommendations. You receive material for the management board and a change plan that genuinely reduces the risk of recurrence.<\/p>\n\n<p><strong>Business benefit:<\/strong> concrete conclusions, clear responsibilities and greater readiness for the future.<\/p>\n\n<p><strong>Risk of inaction:<\/strong> repeating the same mistakes and \"closing\" the matter only on paper.<\/p>","icon":"","accent":"violet","open":false}],"section_meta":{"anchor_id":"","is_enabled":true}},{"acf_fc_layout":"box_variants","variant":"process-detail","section_header":{"section_header":{"eyebrow":"Our solution","heading":"from the first classification to the remediation plan","heading_highlight_mode":"none","heading_split":{"small_part_text":"","strong_part_text":"","":null,"small_part_size":"","strong_part_size":"","tag":"h2","style":"inherit","alignment":"inherit"},"description":"We do not leave you with interpretation alone. 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