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Incident Response Policy

Procedures for detecting, reporting, containing, and recovering from security incidents.


What is a security incident?

Any event that threatens the confidentiality, integrity, or availability of Patria Investments’ systems or data, including:

  • Unauthorized access or access attempts to systems or data
  • Malware, ransomware, or phishing attacks
  • Data breach or suspected data exfiltration
  • Credential compromise (leaked tokens, passwords, keys)
  • Denial of service attacks against production systems
  • Insider threat activity

Severity levels

SeverityDescriptionResponse SLA
CriticalActive breach, data exfiltration, ransomwareImmediate — 24/7 response
HighCredential compromise, unauthorized privileged accessWithin 4 hours (business hours)
MediumSuspicious activity, failed intrusion attemptsWithin 24 hours
LowPolicy violations, minor misconfigurationsWithin 5 business days

Response process

flowchart LR
    Detect[Detect / Report] --> Triage[Triage & Severity]
    Triage --> Contain[Contain]
    Contain --> Investigate[Investigate]
    Investigate --> Remediate[Remediate]
    Remediate --> Postmortem[Postmortem]

1. Detect & report

  • Anyone who suspects an incident must report it immediately
  • Report via: Security team email or ServiceNow — category Security Incident
  • For Critical/High incidents out of hours: contact on-call via Contacts

2. Triage

  • The Security team assesses severity within 30 minutes of report
  • Incident commander is assigned for Critical/High incidents
  • A dedicated communication channel is opened (Teams / Slack)

3. Contain

  • Isolate affected systems: revoke credentials, block accounts, isolate network segments
  • Preserve evidence: do not delete logs, restart services, or wipe machines without Security team approval

4. Investigate

  • Root cause analysis conducted by Security + Engineering
  • Timeline of events documented
  • Scope of impact assessed (systems affected, data involved)

5. Remediate

  • Apply fixes, rotate credentials, patch vulnerabilities
  • Confirm containment before restoring systems to production

6. Postmortem

  • Postmortem written within 5 business days for Critical/High incidents
  • Use the postmortem template
  • Lessons learned shared with the broader team

Contacts

RoleContact method
Security on-callSee Contacts
Incident reportingServiceNow → Security Incident
Legal / DPO (data breach)See Contacts

Danger

Data breach notification: Under LGPD, a confirmed data breach involving personal data must be reported to the DPO immediately.
The DPO will determine whether notification to ANPD and affected individuals is required within 72 hours.