> ## Documentation Index
> Fetch the complete documentation index at: https://docs.orbit.devotel.io/llms.txt
> Use this file to discover all available pages before exploring further.

# Operate the GDPR breach-incident register

> Walk Settings → Compliance → Breach incidents: open a personal-data breach, classify severity, record the supervisory-authority and data-subject notifications, and export the 72-hour attestation for your compliance binder.

# Operate the GDPR breach-incident register

**Settings → Compliance → Breach incidents** is your GDPR Article 33/34
personal-data-breach register. Open an incident, classify its severity, record
when you notified your supervisory authority and the affected data subjects,
and export the 72-hour attestation that proves whether the Article 33 window
was met.

<Note>
  Every control here is tenant-owned: you decide whether an event is a
  notifiable breach, you notify the authority and the data subjects through
  your normal legal channels, and you record those timestamps here. The
  register documents the lifecycle — it never sends a notification itself.
  This page is operational guidance, not legal advice; confirm your
  obligations with your DPO and counsel.
</Note>

For the full endpoint surface and request schemas, read the
[breach incident register reference](/compliance/breach-incident-register).
This page is the console walkthrough.

***

## 1. What counts as a personal-data breach

GDPR Art. 4(12) defines a personal-data breach as a breach of security leading
to the accidental or unlawful destruction, loss, alteration, unauthorised
disclosure of, or access to personal data. A failed deploy, a slow query, or a
dropped call is a **general incident** — handle it in your normal status and
support tooling. The register is for events where **personal data** was
actually exposed or destroyed:

* unauthorised disclosure (a contact list exported to the wrong recipient,
  a phone number written into shared logs),
* unauthorised access (an attacker or an unmanaged device reached customer
  data),
* loss or destruction (personal data deleted or rendered unavailable outside
  your retention plan).

Not every personal-data breach is notifiable. Art. 33 expects notification
"unless the breach is unlikely to result in a risk to the rights and freedoms
of natural persons" — the threshold decision, and its rationale, is yours to
document. When the assessment concludes no notification is owed, take the
**No notification required** branch (section 5) with the rationale recorded in
the incident's remediation notes.

***

## 2. Open an incident and classify severity

Open **Settings → Compliance → Breach incidents** and select
**Open incident**. The form shapes everything downstream:

* **Title + Description** — required. What happened, what data was involved,
  how it was detected. The authority's first questions, answered while the
  details are fresh.
* **Severity** — Low, Medium, High, or Critical. The register summary counts
  critical and high severity so your worst exposure is visible at the top of
  the page. Classification guidance:

  | Level | A working guide |
  | - | - |
  | Low | Minimal scope, trivially containable, little plausible risk. |
  | Medium | Limited scope or contained quickly with residual risk. |
  | High | Significant scope, sensitive categories, or unresolved exposure. |
  | Critical | Widespread or sensitive-data exposure, or active ongoing access. |

  These are working labels: the four values are fixed, the judgement is yours.
* **Discovered at** — the moment you became aware of the breach. **This
  instant starts the Article 33 72-hour notification clock.** Leave it empty
  to start the clock now; set an earlier time when the breach was found
  before you opened the record.
* **Occurred at** — when the breach is believed to have occurred, if known.
* **Scale fields** — affected data subjects, affected records, and data
  categories (one per line). Estimate honestly; you can refine the counts as
  the assessment firms up.
* **Notification required** — on by default. Turn it off only with a
  documented rationale, recorded in the remediation notes.
* **Remediation** — containment steps taken; update it as the response
  progresses.

Save, and the incident lands in status **Detected** with a human reference
(`BR-YYYY-NNNN`). The 72-hour clock is running.

***

## 3. Record the supervisory-authority notification (Art. 33)

The register records notifications — your DPO or counsel files with the
authority through your normal legal channels, then logs the timestamp here.
The register's attestation measures against the timestamps you record; it
never touches an outbound channel.

On the incident's expanded row, select **Record notification**:

* **Party** — choose **Supervisory authority — Art.33**.
* **Notified at** — defaults to now; record the actual send time so the
  attestation is truthful.
* **Method** — the channel used (authority portal, registered letter, email).
* **Reference** — the authority's case number.

Recording the authority notification automatically advances a still-open
incident to **Notified**. Until then, the row's deadline cell shows where the
clock stands: the upcoming deadline while inside the window, or **Overdue**
once 72 hours elapse without an authority notification — and the summary grid
aggregates the overdue count across the register so a breached window is
never silent.

***

## 4. Record data-subject notification (Art. 34) and exemptions

Art. 34 obliges you to inform the affected people **without undue delay** when
the breach is likely to result in a **high risk** to their rights and
freedoms. Record it the same way, with party **Affected data subjects —
Art.34**, noting how recipients were reached (email batch, letter campaign).

Two exemptions most often end the Art. 34 analysis early, mirrored from
Art. 34(3):

* **Encryption** — the data was rendered unintelligible to unauthorised
  parties (for example, encrypted, with the key uncompromised).
* **Low likelihood of high risk** — the assessment concluded a high risk to
  individuals is unlikely.

Document either exemption in the incident record (the remediation notes and
the notification record itself), and the attestation reports each party's
side independently — the 72-hour clock belongs to Art. 33, but a binder that
omits the Art. 34 rationale is an audit finding waiting to happen.

***

## 5. Advance the lifecycle and close

Expand a row and use the **Lifecycle status** control:

**Detected → Under assessment → Contained → Notified → Closed**

* **Detected** — the open state the incident is born into.
* **Under assessment** — forensics and scoping underway; keep the affected
  counts and data categories updated.
* **Contained** — the exposure is stopped; record the containment step in
  remediation.
* **Notified** — set automatically when the authority notification is
  recorded.
* **Closed** — the response is complete.

An incident that still owes a supervisory-authority notification **cannot be
closed**: the close is rejected with a conflict until you record the Art. 33
notification or document that notification is not required. The second
terminal state, **No notification required**, is the documented-exemption
branch — flip **Notification required** off and record the rationale before
taking it.

***

## 6. Export the attestation for the compliance binder

On the expanded row, select **72-hour attestation**. The dialog renders the
compliance statement: discovery instant, computed Art. 33 deadline, each
party's recorded notification timestamp and method, the hours elapsed, and a
compliant/not-compliant verdict. Select **Export attestation** to download it
as a JSON file named with the incident reference (`breach-attestation-BR-…`).

File it in your [evidence binder](/guides/compliance-evidence-binder) as your
proof that the authority notification landed inside the Art. 33 window — or,
when it did not, as the honest record your DPO accounts for. The register's
own summary (open and overdue counts by severity and status) is the
at-a-glance view an auditor or your board asks for first.

***

## 7. Access control — owner and admin only

Reads are workspace-wide, but writing to a regulatory register is an
owner/admin action: opening incidents, advancing status, and recording
notifications are restricted to the **owner** and **admin** roles, mirroring
the platform's administrative guard on its write surface. Assign member
roles accordingly, and keep in mind every write — open, update, notification,
export — lands in your [audit log](/guides/audit-log) with the actor and the
incident reference, so the register reads as a reviewed trail, not an
anonymous log.

***

## Worked example — a leaked phone number in shared logs

A carrier webhook handler briefly logged a customer MSISDN into a shared log
bucket. Your on-call engineer spotted it during routine review at 09:12.

1. **Open** — 09:25. Title *"MSISDN leaked into shared logs by carrier
   webhook"*, severity **Medium**, discovered at back-dated to 09:12 (the
   honest clock start), data categories *"Phone numbers (MSISDN)"*, affected
   data subjects estimated at 1.
2. **Assess** — status moved to **Under assessment**; you confirm the scope
   is a single number over a 40-minute window and patch the counts.
3. **Contain** — the logging statement is disabled at 10:48; status moves to
   **Contained** with the remediation note.
4. **Notify the authority** — your DPO files with the DPA at 16:40 the same
   day (31.5 hours after discovery). Record notification → **Supervisory
   authority — Art.33**, method *authority portal*, reference the DPA case
   number. The incident moves to **Notified**.
5. **Assess Art. 34** — one phone number, no associated content: the
   assessment concludes no high risk. That exemption is recorded in the
   incident notes rather than as an Art. 34 notification.
6. **Attest** — export the attestation (`breach-attestation-BR-2026-0007.json`)
   and file it in the binder; it records 31.5h, inside the 72h window,
   compliant.
7. **Close** — after the post-incident review, status moves to **Closed**.

***

## Related references

* [Breach incident register reference](/compliance/breach-incident-register) —
  the full API surface and register semantics.
* [Data Subject Access Requests (DSAR)](/compliance/dsar) — the other half of
  GDPR operations.
* [GDPR Processing Register (ROPA + DPIA)](/compliance/privacy-register) — the
  Art. 30/35 documentation that sits beside the breach register.
* [GDPR posture guide](/compliance/gdpr-posture-guide) — how the posture
  controls fit together.
* [Assemble and seal an evidence binder](/guides/compliance-evidence-binder) —
  where the attestation files.
* [Audit log](/guides/audit-log) — where every register write lands.


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