Brand Phishing Response RACI: Roles, Decisions, and Handoffs

A brand phishing response RACI assigns one accountable owner to each decision while showing who performs, advises on, and receives updates about the work. It prevents a detected impersonation case from stalling between fraud, SOC, legal, communications, and customer support.

This guide is about operating ownership, not the technical removal sequence. Brandefense already has a response guide for lookalike and phishing domains and a step-by-step phishing takedown process. Use this RACI to decide who must act, approve, advise, and stay informed around those procedures.

What Does a Brand Phishing Response RACI Control?

A RACI controls decision rights and handoffs. It does not replace an incident plan, evidence standard, provider procedure, legal advice, or technical runbook.

Responsible roles perform the work. The accountable role owns the result and makes the final decision. Consulted roles provide input before a decision. Informed roles receive a timely update but do not approve the action.

Assign labels to decisions rather than broad phases. “Legal is consulted on a public warning” is clearer than “Legal supports response.” The first statement tells the case lead when input is required and what can otherwise proceed.

• Case acceptance: Does the report meet the organisation’s threshold for a managed response?
• Internal containment: Which email, web, identity, or fraud controls should change?
• External submission: Is the evidence ready for the relevant provider or platform?
• User communication: Does the affected audience need an approved warning?
• Closure: Have operational and recordkeeping conditions been met?

CISA advises people to resist suspicious requests and report phishing attempts. An enterprise reporting channel should route the report to an owner without asking the reporter to investigate the suspected asset.

Which Roles Belong in a Brand Phishing Response RACI?

Include roles that can make or execute a case decision. Avoid adding every stakeholder to every row, because excessive consultation can become another source of delay.

A fraud or brand-protection lead usually owns the external abuse case. This role coordinates case status, brand evidence, provider correspondence, and related-asset monitoring. The role may sit in security, fraud, legal, or marketing.

The SOC owns internal telemetry and defensive controls. It checks whether employees or managed systems interacted with the reported asset and coordinates technical containment when evidence supports action.

Legal advises on authority, trademark evidence, privacy, jurisdiction, and formal escalation. Legal should not become the default approver for routine technical blocks unless organisational policy requires that decision.

Communications and customer support manage audience-facing language and inbound reports. Identity, IT, and fraud operations act when the case indicates compromised access, payment risk, or account misuse.

Smaller organisations can assign several roles to one person. The RACI should still name the separate responsibilities so that evidence review, containment, communication, and closure are not silently skipped.

How Should the RACI Assign Core Decisions?

Start with a compact decision matrix and adapt it to the organisation. The example below is a defensive operating model, not a universal legal or organisational requirement.

Each row should have one accountable role. Two accountable roles create a negotiation at the moment a decision is needed. If authority changes by severity, create separate rows for routine and high-impact cases.

Consultation must have a trigger. Legal input may be required when personal data, a formal notice, law enforcement, or a disputed trademark claim enters the case. Routine provider correspondence may follow a preapproved template.

What Must Each Handoff Record?

A handoff is complete only when the receiving role acknowledges it. Sending a message or changing an assignee does not prove that someone accepted the work.

Keep one shared case record with a case identifier, current owner, severity, status, next decision time, and affected channel. Link evidence and correspondence instead of duplicating uncontrolled copies across inboxes.

• Decision requested: state the exact approval or action needed.
• Reason: summarise observed facts and separate them from analyst inference.
• Evidence location: point to the controlled record and its collection time.
• Deadline: state when the next decision or update is due.
• Fallback owner: identify who receives the task if the primary owner is unavailable.
• Acknowledgement: record who accepted the handoff and when.

Do not make recipients reopen a suspected asset to understand the case. CISA recommends avoiding links and attachments in suspicious messages and using known contact routes. Case summaries should preserve that safety principle.

Use neutral language in the handoff. “A page displayed the approved sign-in design and requested credentials at the recorded time” describes an observation. Claims about the operator’s identity or intent require separate evidence.

How Do You Maintain Coverage Outside Business Hours?

A RACI fails when it names a role but ignores availability. Define working hours, escalation contacts, acknowledgement targets, and the authority granted to the on-call responder.

The on-call role needs a bounded set of preapproved actions. It may accept a case, apply reversible controls, preserve evidence, and notify decision owners. Public statements, formal notices, or irreversible actions may require a different authority.

Set severity triggers that change the contact path. Active distribution, reports of submitted credentials, payment diversion, executive impersonation, or broad customer impact can justify immediate escalation under organisational policy.

Test the fallback route. A shared mailbox without a monitored schedule is not coverage. A named deputy without access to the case system cannot complete the handoff.

Keep the duty model proportionate. A smaller team may use an incident commander who contacts specialist owners only when defined triggers appear. The goal is dependable decisions, not a large permanent committee.

How Does the RACI Connect to Containment and Takedown?

The RACI surrounds the technical workflow with ownership. It tells the team who may classify the case, approve an external submission, change internal controls, communicate with users, and confirm closure.

It should not restate provider routing, evidence capture, removal verification, or recurrence-monitoring steps. Those procedures belong in the existing response and takedown guides, where they can be maintained without conflicting instructions.

Internal containment and external takedown can run in parallel. The SOC lead may own technical blocks while the brand lead owns provider correspondence. Both workstreams should report status to the same accountable case owner.

The phishing and lookalike-domain use case explains how external monitoring supports response. The phishing monitoring and domain abuse page describes the broader commercial capability.

NIST SP 800-61 Rev. 3 integrates incident response with cybersecurity risk management. The RACI should connect case-level decisions with existing incident, identity, fraud, communications, and risk processes.

When Should the RACI Require Legal or Executive Escalation?

Escalation criteria should be written before a stressful case. Otherwise, teams either consult too late or send every routine decision to senior stakeholders.

Legal consultation may be appropriate when a case involves disputed ownership, personal data, law enforcement, a formal notice, cross-border requirements, or a public allegation. The precise trigger depends on policy and counsel.

Executive notification should focus on decisions and material impact. A useful update states what is known, what remains uncertain, which controls are active, who owns the next action, and when the next update will arrive.

Do not treat an automated provider acknowledgement as a completed action. The case owner should keep the status accurate and avoid telling stakeholders that removal occurred before the operational team verifies it.

How Should Teams Test and Measure the RACI?

Measure whether ownership works, not whether every case is fast. Provider, platform, jurisdiction, channel, and evidence quality can affect external timelines.

• Unowned time: minutes between intake and assignment to an accountable owner.
• Handoff acknowledgement: time until the receiving role accepts the task.
• Decision latency: time between a complete request and the recorded decision.
• Reassignment count: handoffs caused by unclear scope or authority.
• Overdue updates: cases that passed their next review time without a status entry.
• Exception use: cases that required an emergency or executive route.
• Reopen rate: cases reopened because closure ownership or conditions were incomplete.

Review these measures by decision type. Combining a routine internal block with a public communication approval can hide where governance actually stalls.

Run a tabletop exercise with a realistic report. Ask who accepts it, who can apply immediate controls, who approves external communication, what happens after hours, and who closes the record.

Update the RACI when an exercise exposes an unavailable owner, an unclear trigger, or a missing system permission. A useful matrix reflects actual authority and access rather than an ideal organisation chart.

Review the matrix after organisational changes and significant cases. The final owner should record each change, its effective date, and which procedures depend on it.