Who can say yes to licensing incident containment records? A decision tree from SOC lead to signer

Short answer

Start with the incident response director or SOC lead, who knows how handoffs work and where approvals, owner changes and verification notes are kept, then bring in the CEO, who can approve a licensing discussion. For records in the company's own tools, the CISO recommends and general counsel advises. Records an outside provider created may fall under the services agreement, and a security provider's client incidents fall under client contracts.

Visual briefFull-size diagram
A top-down approval tree from the incident response director through the CISO to a split on where the records sit: the company's own tools lead to the CEO with general counsel, while the provider portal leads to the services agreement; the own-tools path lights up to SourceX rights review.
Illustrative routing for a company with its own case tool and an outgoing provider. Each company's contracts decide the real path.

This decision tree is part of the incident containment handoffs guide. It takes a security operations consultant from the first conversation to the right introduction and marks where the answer stays open until SourceX's rights review. It is general information, not legal advice.

Why the person who knows the handoffs is not the one who signs

The incident response director is the right first conversation. They know whether owner changes are kept as history, whether chat approvals quote the case number and which shifts handed over cleanly. In a tool like Microsoft Sentinel they can see the Owner field on every incident row, so they can describe the handoff record precisely.

Knowledge is not authority. NIST's SP 800-61 Revision 3, finalized in April 2025, frames incident response as part of cybersecurity risk management, which places it under the organization's governance rather than with one team. A decision to discuss those records with an outside party follows the same line: up from the SOC to the executive who answers for company information, with counsel alongside.

The tree: four questions to the signer

Work through the questions in order. Each answer either names a decision-maker or adds a reviewer.

  1. Where were the handoff records created?
    • In the company's own case tool, chat and consoles: go to question 2.
    • In an outside provider's portal: the services agreement decides who controls them. The vendor or procurement manager finds the agreement; counsel reads it. Mark these records "unknown" and go to question 2 for the rest.
  2. Is the company itself a security or managed services provider?
    • Yes: most incidents concern its clients, and client contracts govern them. Separate internal incidents from client incidents and go to question 3.
    • No: go to question 3.
  3. Do any incidents carry notification history, regulatory correspondence or a legal hold?
    • Yes: general counsel gates those incidents, and some may stay out of any discussion. Go to question 4.
    • No or unknown: note it and go to question 4.
  4. Will the CEO take a short call, with the CISO recommending?
    • Yes: introduce the CEO, with the incident response director as sponsor.
    • No or unsure: do not submit yet; ask the sponsor to raise it with the CEO.

Most companies with their own SIEM or case tool follow the first branch for the bulk of their records and the provider branch for a smaller slice from an outgoing retainer.

Who owns, who recommends, who approves

PersonWhat they bringDecision role
Incident response director or SOC leadHandoff workflow, systems, coverage by yearStarting contact and sponsor
SOC analyst or case tool adminWhich fields and history are keptInforms; no authority
IT operations leadEndpoint, identity and change recordsInforms
Vendor or procurement managerThe outgoing provider's contract and data handover termsInforms
CISOOwns the security function's records and their sensitivityRecommends
CEOAuthority over company informationApproves and signs
General counselProvider and client contracts, notification history, legal holdsAdvises; often gates

If you worry the conversation may strain your client relationship, read whether referring clients hurts the relationship first.

The services agreement. Notes written by a provider's analysts may be the provider's records, the company's, or shared, depending on the contract. Counsel answers that before anyone counts them in.

Client contracts. For a security provider, client incident records are usually confidential under client agreements. The cybersecurity services fit page explains why client-linked incident details are usually excluded.

People in the records. Sign-in logs and mailbox records identify employees. Under the EU General Data Protection Regulation, personal data is any information relating to an identified or identifiable natural person, and similar rules exist elsewhere. Mailbox content raises its own questions, set out in whether a company can license its email archive. Why data rights matter explains why these answers come first.

What only SourceX's rights review settles

The tree tells a partner whom to introduce. It leaves these open:

  • which record classes the company has the right to license, and whether provider-held notes are among them
  • which incidents are excluded because of client terms, notification history or legal holds
  • how accounts, hosts and people are de-identified or generalized
  • whether there is buyer interest in containment handoff histories, and on what terms

An introduced company needs 50+ full-time employees at peak (contractors excluded), a documented operating history, rights to license and an authorized contact. Companies in the U.S., Canada and the EU qualify, as do companies in the UK, Australia, New Zealand, India, Singapore, South Africa, Latin America, the UAE and Saudi Arabia when at least 90% of the data is in English. Partners sign the Channel Partner Agreement before submitting introductions and never ask for cases, logs or logins. The worked overnight-shift case shows what the records contain, the root cause analysis records page covers a related record type, and the referral brief template has a field for the signer.

Next step

Refer a company. Earn up to $100,000. Default reward: 25% of Actual Supplier Payout, capped at $100,000 cumulatively per referred company. Eligibility and payment conditions apply, and a signed Schedule A or addendum can differ. A lead, meeting or signature alone does not trigger payment.

Once the tree has named the executive who can approve a discussion about the company's incident records, register as a partner, check the company against who qualifies and read the program terms before you make the introduction.

  1. Step 1Share your linkSend your personal link to a company you know.
  2. Step 2Company appliesThe company applies itself at /apply.
  3. Step 3Company signs and is paidThe company signs, delivers its data and is paid by SourceX under its agreement.
  4. Step 4You get your rewardYour 25% of the actual supplier payout. A reward becomes payable after SourceX has paid the referred company under its signed agreement and the payout conditions in the program terms are met, including finance approval and your tax and payment details.

Common questions

Can a SOC analyst with admin rights approve a data discussion?

No. Admin rights to the case tool let someone see every incident; they do not give authority over company records. The analyst can describe what exists, and that is useful, but approval sits with the CEO.

Does the CISO have authority to license security records?

No. They recommend; licensing company information is a decision for the CEO, with counsel, and the CISO's view on sensitivity carries weight in it.

What if the company is itself a managed security provider?

Then most incident records concern its clients, and client contracts govern them. Records of its own internal incidents may be a different matter. Counsel separates the two before any discussion.

Sources

  1. refer.sourcex.si/terms
  2. nist.gov/news-events/news/2025/04/nist-revises-sp-800…
  3. learn.microsoft.com/en-us/azure/azure-monitor/reference/tables/s…
  4. eur-lex.europa.eu/eli/reg/2016/679/oj/eng

Free resources

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Become a referral partner, get your link and introduce the company’s CEO (in an owner-run company, usually the owner). Referral partners can join from most countries. We can't work with partners in countries or regions under U.S. sanctions or on U.S. restricted-party lists. The companies you introduce should be based in the U.S., Canada and the EU, or in the UK, Australia, New Zealand, India, Singapore, South Africa, Latin America, the UAE and Saudi Arabia with at least 90% of their data in English.

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