This guide is for use during an active breach.
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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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