Incident Response
Reviewed: 2026-07-22 · Canon: generation 8, effective 2026-07-21 · Status: documented runbook. Not yet exercised against a paying-customer incident, because there are no paying customers yet. Tested response is an explicit gate before production real-data use.
1. Detection
| Channel | Purpose |
|---|---|
| Cloud monitoring and alerting | Infrastructure thresholds: service health, database connections, error rates |
| Application error tracking | Application faults, scrubbed of regulated data by design |
| Deployment and CI signals | Failed releases, integrity check failures |
| Customer or user report | Inbound via support email and product surfaces |
| Vendor notification | Per contract and BAA terms once executed |
| Internal review | Founder weekly review of anomalies and near-misses |
Severity is assigned at first triage: Sev 1 (regulated data or integrity at risk, or a customer-facing outage) through Sev 4 (routine).
2. Triage
Founder rotation
- Giles-Evan Mboumi (CEO): primary on-call, customer communications lead
- Christian Montgomery (COO): security and operations lead
- Abhishek Jha (CTO): technical and architecture escalation
Formal paging tooling is a later formalization; the current model is a founder rotation with direct escalation.
First-response checklist
- Confirm severity (Sev 1 through 4)
- Open the incident channel
- Capture initial state: timestamp, affected surface, scope of impact
- Pull monitoring and error-tracking context
- If Sev 1 with customer impact: notify per contractual terms
- Begin remediation; preserve forensic evidence before destructive fixes
3. Communication
| Trigger | Window | Channel |
|---|---|---|
| Suspected PHI breach (once real data exists) | Within 60 days per HIPAA (45 CFR 164.404); faster on confirmed exposure and per customer BAA terms | Direct customer communication plus written notice |
| Service-impacting outage (Sev 1) | Within 24 hours of impact start | Per customer terms |
| Vendor incident affecting Rōvn | Within 24 hours of vendor confirmation | Forward vendor notice plus Rōvn-specific impact statement |
| Resolved incident | Within 7 days of resolution | Post-incident summary |
Investor notification: Sev 1 events that materially affect the commercial trajectory are included in the next investor update with summary and remediation. Routine events are not surfaced.
4. Post-mortem cadence
- Initial blameless post-mortem within 24 hours of resolution.
- Template fields: date, impact, root cause, detection, response, resolution, lessons, action items.
- Action items tracked with owner and due date; customer-facing post-mortem provided per contractual terms.
5. PHI breach protocol (activates with real data)
If PHI exposure is suspected:
- Preserve forensic evidence immediately (cloud audit logs, access logs, application logs, ledger snapshot)
- Begin internal investigation within 1 hour
- Engage outside counsel (Jason Acevedo, Klehr Harrison)
- No public disclosure pre-investigation
- Customer notification triggers on confirmation, within the HIPAA and contractual windows
If PHI exposure is confirmed:
- Customer notification per BAA terms
- HHS OCR notification per the Breach Notification Rule (500-or-more individuals: within 60 days; smaller: annual log)
- Affected-individual notification within 60 days of discovery
- Media notification where the rule requires it
Current state: there is no production PHI flow, so this protocol has no live exposure to act on. It is documented now so it is not improvised later.
6. Vendor incident protocol
- Confirm scope with the vendor
- Identify affected Rōvn surfaces and, later, customers
- Pull internal evidence for the incident window
- Notify affected parties per contractual terms
- Track for cumulative review at the quarterly compliance check-in
7. Specific playbooks
7.1 Regulated data in error tracking (scrub failure)
- Disable the sender for the affected surface
- Review the recent event window for scrub failures
- Engage the vendor to delete affected event data
- Trigger the breach protocol if confirmed
7.2 Database exfiltration suspected
- Lock down database access; revoke the affected service identity
- Pull database and cloud audit logs
- Identify the vector; snapshot state for forensics
- Notify per protocol if data was exposed
7.3 AI provider incident
- Confirm vendor status
- Route to an approved alternate model path (the runtime is model-agnostic; fallback is never silent)
- Queue in-flight work; verify no regulated payload left the approved boundary
7.4 Source integrity (wrong data returned)
- Pause the affected adapter (source activation fails closed)
- Review source receipts for affected verifications
- Escalate to the source; re-verify through an alternate path
7.5 Audit ledger integrity failure
- Immediate Sev 1
- Treat any chain break as potential compromise; freeze writes, snapshot, investigate
- Full account-activity review; engage counsel
8. Tooling status
| Tool | Status |
|---|---|
| Cloud monitoring, logging, and alerting (Google Cloud) | Staged |
| Application error tracking | Staged |
| Incident channel (founder channel) | Active |
| Formal paging rotation | Later formalization |
| Public status page | Target |
| Forensic snapshot automation | Designed; tested response is a real-data gate |
End of incident response.