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PIPEDAAB PIPAAll sectors

Ransomware Attack — Quick Reference Guide

Immediate steps, checklists, and reporting deadlines for Canadian organizations responding to a ransomware attack under PIPEDA and Alberta PIPA.

Typical verdict

HIGH to CRITICAL

Reporting deadline

As soon as feasible after RROSH is determined — regulators expect days, not weeks

Documents you will need

  • Internal Incident Record (always required)
  • OPC PIPEDA Breach Report (if PIPEDA RROSH triggered)
  • OIPC Alberta Notification Form (if AB PIPA applies)
  • Individual Notification Letter
  • AB PIPA Individual Notice s.19.1 (if AB PIPA individual notification required)

Do not

  • Pay the ransom before obtaining legal advice — sanctions risk
  • Wipe affected systems before forensic review is complete
  • Wait for full forensic confirmation before filing — act on available information
  • Use the encryption event date as your breach start date — use the dwell time start date

First 30 minutes

  • Isolate affected systems from the network — do not shut them down unless instructed by your incident response firm
  • Disable compromised accounts and revoke active sessions
  • Call your cyber insurer — most policies require notification before remediation begins
  • Preserve all available logs: firewall, endpoint, and authentication logs from before the encryption event
  • Designate one person as incident lead — all communications route through them
  • Do not communicate the breach details over systems that may still be compromised

Within 24 hours

  • Engage an incident response firm if you do not have internal forensic capability
  • Identify dwell time — when did the attacker first enter the environment? This is your breach start date
  • Identify what personal information was on affected systems:
    • Health or medical records
    • Financial or banking information
    • SINs or government-issued ID
    • Passwords or credentials
    • Contact information
    • Employee records
  • Determine whether data was encrypted at rest before the attack — this affects your RROSH score
  • Confirm whether a third-party vendor was involved (entry point or data processor)
  • Run your ClearBreach assessment — do not wait for full forensic results to begin assessing

Within 72 hours

  • Complete your RROSH assessment in ClearBreach and review your verdict
  • If PIPEDA RROSH threshold is met: file OPC Breach Report — do not delay for further investigation
  • If Alberta PIPA applies and RROSH is met: notify OIPC Alberta (breachnotice@oipc.ab.ca) and affected individuals simultaneously
  • Send individual notifications directly — do not substitute a website notice for direct notification under Alberta PIPA
  • Begin populating your Internal Incident Record — include all actions taken with timestamps
  • Obtain legal advice specifically on sanctions risk before any ransom payment decision

Ongoing — until resolution

  • Update your Internal Incident Record as new information becomes available
  • Track vendor communications in writing — if vendor was involved, document every exchange
  • Reassess RROSH if new facts materially change the breach scope
  • Retain all records for 24 months minimum from breach start date

Alberta PIPA — specific steps

  • Notify OIPC Alberta and affected individuals simultaneously — this triggers the streamlined review process and a private closing letter
  • Complete the official OIPC Alberta Notification Form — do not submit an informal letter
  • Attach the AB PIPA Individual Notice (s.19.1) to your OIPC Alberta submission (Section D)
  • Submit by email to breachnotice@oipc.ab.ca

MSPs — if managing this for a client

  • Confirm your service agreement before acting on the client's behalf — who leads regulatory notification?
  • If ransomware entered through your systems or tools, you are a direct party to the breach
  • Document all client communications with timestamps
  • Run a ClearBreach assessment under your MSP account for the affected client organization

This guide is not legal advice. It provides practical guidance on Canadian privacy breach response. Consult a qualified privacy lawyer before submitting reports to regulators.

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