Response
The first response to an AI data breach
Close the exposure and protect any secrets that leaked. Then establish whether personal data was caught up in it, since the answer shapes what you owe the regulator.
Last reviewed against legislation.gov.uk, National Cyber Security Centre and OWASP GenAI Security Project. Sources
The clock
Awareness starts it
The reporting target is measured from the moment you become aware of the breach [1]. Treat the first report as that moment, whether it came from a supplier, a researcher or a colleague.
Write this down first
The time, the person who raised it and what they said. A late notice has to explain the delay [1], and a clear note is the best support for that explanation.
The sequence
In order
Work through these in order and give each to a named person.
-
1
Shut the door. Take the open service offline, cancel the shared link or pause the tool. Wiz said Microsoft invalidated the exposed link two days after it was told [8]. -
2
Change what leaked. Any key, token or password that appeared in a log, prompt or repository should be considered compromised. Wiz found secret keys inside the DeepSeek logs [7]. -
3
Take copies before you tidy up: access logs, configuration files and screenshots of what was exposed. -
4
Pin down the data. Note the categories involved and roughly how many people and records, because a regulator notice has to describe both [1]. -
5
Contact any supplier involved and ask for its written account. -
6
Make the reporting decision and write down why. See how to report.
Judgement calls
Where teams stall
Three questions slow most responses down.
Is it personal data
OWASP names personal details and health and money records among what an LLM application can give away [5]. If any of it concerns identifiable people, assess the incident as a personal data breach.
Can the data be recalled
Do not assume so. Ask the supplier in writing what it has deleted and what it cannot, and file the answer with the incident record.
Who speaks to affected people
Agree one voice. Where people must be told, the law asks for plain language that describes the nature of the breach [2]. See telling people.
Afterwards
Close the loop
Add the cause to your risk register and update the response plan. Check that your written record of the breach is complete [1].
Keep reading
Read next
Response plan
What to add to your incident response plan for AI tools: owners, data stores, supplier contacts, decision rights and the NCSC's advice for leaders.
Read the guide
Reporting
When and how a personal data breach involving AI tools must be notified under UK GDPR, what the notice contains and what to record if you do not report.
Read the guide
Telling people
When individuals must be told about a personal data breach involving AI tools, what the message should say and the exceptions the law allows.
Read the guideHow CyPro can help
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When data has leaked through an AI tool, its logs or its storage, the early decisions shape what you must report and to whom. An incident response team helps you contain the exposure, establish what was involved and prepare your notifications.