This guide is for use during an active breach.
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Website or Database Compromise — Quick Reference Guide
By Yong Du
Immediate steps and reporting obligations for Canadian organizations when a website is hacked, a database is extracted, or a web shell is discovered under PIPEDA, Alberta PIPA, and BC PIPA.
Typical verdict
RROSH present in most cases — confirmed database access by a malicious actor with personal information in scope almost always meets the threshold
Reporting deadline
As soon as feasible after RROSH is determined — do not wait for forensics to complete before notifying
Documents you will need
- → Internal Incident Record (always required)
- → Web server logs and database query logs for the dwell period (preserve before remediation)
- → OPC PIPEDA Breach Report (if PIPEDA RROSH triggered)
- → OIPC Alberta Notification Form (if AB PIPA applies)
- → OIPC BC Notification (if BC PIPA applies)
- → Individual Notification Letter
- → AB PIPA Individual Notice s.19.1 (if AB PIPA individual notification required)
Do not
- ✕ Restore from backup before preserving logs and the compromised system state — restoration destroys evidence
- ✕ Wait for forensics to complete before notifying — file on available information and supplement as the investigation continues
- ✕ Scope the breach only to confirmed queries in logs — incomplete logging understates actual attacker access
- ✕ Treat patching the vulnerability as the end of the incident — the breach during the dwell period still requires assessment and possible notification
- ✕ Pay an extortion demand instead of notifying — payment does not satisfy regulatory obligations
First 30 minutes
- Do not restore from backup yet — preserve logs first: web server access logs, database query logs, application error logs, and any security event logs covering the dwell period
- Take the affected system offline if the attacker is actively present — after evidence is preserved
- Identify the vulnerability and entry point: SQL injection form, compromised plugin, stolen admin credential, unpatched software
- Change all admin panel passwords and database credentials immediately — the attacker may have captured credentials stored on the server
- Designate an incident lead — all technical findings and communications route through them
- Record the exact date and time the breach was discovered — this starts your response clock
Within 24 hours
- Determine the dwell period: earliest evidence of exploitation in logs, or the date the vulnerability was introduced or publicly disclosed if logs do not show the start
- Map what the attacker could reach from the entry point: which database tables, which file directories, what credentials were stored in config files
- Identify what personal information was in the accessible tables: customer contact data, payment records, hashed or plaintext credentials, SINs, health information, transaction history
- Determine how many individuals are affected and which provinces they are in — this determines whether AB PIPA and BC PIPA apply
- Check for indicators of confirmed exfiltration: large outbound data transfers in logs, database dump files created by the attacker, dark web alerts, customer fraud reports
- Rotate all credentials that may have been accessible: database passwords, API keys, third-party service credentials stored in config or environment files
- Begin your ClearBreach assessment — do not wait for full forensics to start
Within 72 hours
- Complete your RROSH assessment in ClearBreach and review your verdict
- If PIPEDA RROSH threshold is met: file OPC Breach Report as soon as feasible — supplement with additional findings as investigation continues
- If Alberta PIPA applies and RROSH is met: notify OIPC Alberta (breachnotice@oipc.ab.ca) and affected individuals simultaneously
- If BC PIPA applies and RROSH is met: notify the OIPC BC through their official breach notification process and notify affected BC residents directly
- Send individual notifications: describe what happened in plain language, what information was involved, what the organization is doing, and what individuals can do — for credential exposure, advise password changes on your site and any other site where the same password was used; for payment card exposure, advise immediate contact with their card issuer
- Patch the exploited vulnerability — after evidence preservation and assessment are under way
Ongoing — until resolution
- Supplement your OPC and provincial breach reports as forensic findings develop — if material new information changes the scope or RROSH assessment, update regulators and notify individuals who were not previously notified
- Monitor for data misuse: credential stuffing alerts, phishing campaigns using your customer data, fraud reports from affected individuals
- Retain all records — logs, forensic reports, internal assessment records, notifications sent — for 24 months minimum from date of discovery
- Conduct a full security review: vulnerability scan across all web properties, review plugin and dependency versions, enable web application firewall, implement database query logging going forward
- If a card-skimming script was involved: notify your payment processor and card brands immediately — PCI-DSS obligations run in parallel with your PIPEDA and PIPA obligations
Alberta PIPA — specific steps
- Notify the OIPC Alberta and affected individuals simultaneously — simultaneous filing triggers the streamlined review process
- Complete the official OIPC Alberta Notification Form — do not substitute 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
BC PIPA — specific steps
- BC PIPA applies if any affected individuals are BC residents — applies regardless of where your organization is based
- OIPC BC voluntary reporting is available even if RROSH is not present — for compromises where exfiltration cannot be confirmed but the attacker had database access, voluntary reporting demonstrates good faith
- If RROSH is present: notify the OIPC BC through their official breach notification process at oipc.bc.ca and notify affected BC residents directly
- Do not substitute a general public notice for direct individual notification
Dwell period — if logs are incomplete
| Situation | Use as dwell start |
|---|---|
| First malicious query visible in logs | That log timestamp |
| Logs exist but earliest exploitation not visible | Date the vulnerability was publicly disclosed for your software version |
| No logs available for the affected period | Date the vulnerable software or plugin was installed or last updated |
| Plugin or CMS version unknown | Date of last confirmed secure state (last update or security scan) |
Always use the most conservative (earliest) estimate — do not anchor on the discovery date.
MSPs — if managing this for a client
- Notify the client immediately with full technical details: entry point, dwell period, database scope, remediation taken — the client's response clock starts when you inform them
- The client organization is the accountable party under PIPEDA and PIPA for their individuals' personal information; your role is to provide the facts that enable their RROSH assessment
- If your own managed infrastructure was the entry point affecting multiple clients, each affected client requires a separate notification and a separate ClearBreach assessment
- Run each client's assessment under your MSP account and keep all records separate
This guide is educational and does not constitute legal advice. It is grounded in the text of PIPEDA, Alberta PIPA, and BC PIPA and published guidance from the OPC, OIPC Alberta, and OIPC BC. If your situation involves regulatory investigation, litigation risk, or circumstances not addressed here, engage a qualified privacy lawyer.
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