The Missing Piece in Your Privacy Stack

Organizations today face an ever-evolving privacy landscape, marked by new regulations, shrinking notification windows, and an exponential increase in data breaches and incidents.

How do you know whether your program is keeping pace? RadarFirst’s sixth annual Privacy Incident Management Benchmarking Report offers a data-driven answer. Drawing on millions of incidents assessed through our platform, the report reveals where organizations excel—and where they stumble—in managing and notifying data breaches.

In a deep-dive webinar, RadarFirst veterans reviewed the report’s headline findings. They examined not only the high-profile, large-scale breaches that capture headlines but also the day-to-day operational incidents that make up the majority of a privacy team’s workload within regulatory risk management. 

Along the way, they highlighted critical benchmarks—notification rates, breach sources, response timelines, and the transformative impact of automation—that every privacy leader should know.

The Value of Day-to-Day Privacy Incident Management

“Most people, when they think of a breach, they just think of the big one… But what we’re really here to help you with are the bulk of these incidents that are usually fewer than a hundred people, almost always fewer than ten.”
– Zelda Ollentia, Director of Product

While high-profile breaches capture headlines, the vast majority of privacy incidents are small-scale, often affecting only one or two individuals.

Zelda emphasized that these “onesie-twosie” incidents can carry significant risk amid laws, rules, and regulations if left unmanaged:

• Even a single misdirected email containing unencrypted personal information can trigger notification obligations.

• Automated documentation and risk assessment ensure that “smell-test” decisions (e.g., assuming encryption removes any notification requirement) are defensible.

• Visibility into small incidents helps organizations identify “leaks” in their processes and shore up controls before they escalate.

Incident Size Trends: The 2025 Breakdown

RadarFirst’s privacy incident management metadata reveals:

Fewer than 1 individual affected: 70% of all incidents (2025) — Steady high share, reflecting countless administrative slips or minor misdirected communications over the past six years.

“Generally, less than two percent of incidents end up being that big… but almost ninety percent of incidents are fewer than ten or even one individual.”
– Doug Kruger, VP of Business Development

1–10 individuals affected: 20% of all incidents (2025) — A gradual uptick from roughly 15% in 2019, indicating more teams are logging these bite-sized incidents instead of dismissing them.

11–100 individuals affected: 8% of all incidents (2025; up to 17% this year) — A noticeable jump, suggesting organizations are getting better at identifying and documenting mid-scale events.

More than 100 individuals affected: Less than 2% of all incidents (2025) — Still rare “big breaches,” yet these continue to capture the lion’s share of public attention.

Why the “Small” Incidents Matter

1. Volume Equals Risk:
   Although a one-person email misaddressed to the wrong recipient might seem trivial, hundreds or thousands of these go unmanaged every year. Left undocumented, they compound risk and open gaps in your compliance defenses.
2. Hidden Costs Add Up:
   Each minor incident still demands investigative time, legal review, and risk assessment. When multiplied by the tens of thousands, the FTE burden can be enormous, often diverting resources from truly critical cases.
3. Early Warning Signals:
   A spike in mid-scale incidents (11–100 individuals) may indicate systemic process issues, such as misconfigured mailing lists, faulty redaction tools, or lapses by third-party vendors. Tracking these trends helps privacy teams pinpoint and remediate root causes before they balloon into headline-grabbing breaches.

This consistency underscores the crucial importance of streamlining the management of minor incidents, which comprise the majority of a privacy team’s workload.

Notification Rates: How Often Does an Incident Become a Breach?

RadarFirst defines:

• Incident: Any unauthorized disclosure of personal data.
• Breach: An incident determined to be notifiable to regulators, affected individuals, or third parties.

“Those companies that rely on manual reactive processes are just struggling to keep pace. But those who invest in automation… are best positioned to reduce resolution times, limit risk exposure, and build lasting trust.”
– Doug Kruger

Across all industries in 2025, 8.5% of incidents were notifiable, meaning that over 91% of documented disclosures did not meet the breach criteria.

Automation helps organizations maintain low notification rates.

Industry-specific notification rates show:

• Healthcare: 11.06%
• Financial Services: 3.5%
• Insurance: 4.0%

Healthcare’s higher rate reflects both the sensitivity of medical data and the sheer volume of data handlers across providers and third-party vendors.

Incident Timelines: From Occurrence to Notification

Efficient incident response hinges on understanding—and optimizing—each phase from when data is exposed to when notifications go out. RadarFirst segments the lifecycle into three critical phases:

“Discovery to assessment… takes about two weeks. That’s where automation can save you nearly ten days compared to manual processes.”
– Nick Church, Staff Engineer

Occurrence to Discovery

• Average: 7 days
• What it measures: Time from the actual unauthorized disclosure (e.g., misdirected email, lost hard drive) to when the privacy team first learns of the incident.
• Key drivers: Employee awareness of reporting channels, clarity of incident submission forms, and organizational culture around data mistakes.

Discovery to Assessment

• Average: 14 days
• What it measures: Time taken to gather facts, evaluate risk factors (data sensitivity, number of individuals affected), and decide whether the incident qualifies as a notifiable breach.
• Pain points: Manual information gathering, back-and-forth with IT or business units, legal reviews, and inconsistent documentation templates.

Assessment to Notification

• Tightly clustered around deadlines imposed by law or contract (e.g., 24-, 48-, or 72-hour windows). This phase is often compressed, as teams race to meet regulatory cutoff times once a breach decision is made.

Notably, there is no strong correlation between the total number of incidents an organization handles and its response speed, meaning any team, large or small, can optimize these phases through better processes and tools.

Why Speed Matters

• Regulatory Risk: Missing a statutory deadline—even by hours—can trigger hefty fines, enforcement actions, or mandatory public disclosures.
  
• Contractual Penalties: For service providers, contractual SLAs (some as tight as one hour!) can carry severe financial or reputational consequences if unmet.
  
• Stakeholder Trust: Swift assessments and transparent communications bolster confidence among customers, partners, and boards.

Driving Program Improvements with Data

“Insights like these are helpful as you seek to build a business case for investing in any type of privacy automation.”
– Doug Kruger, VP of Business Development

Throughout the session, the speakers stressed:

• Measure continuously. Track incident volumes, notification rates, and timelines across internal vs. external sources and by industry.
  
• Automate for consistency. Free privacy teams from subjective decision-making so they can focus on complex breaches.
  
• Benchmark boldly. Use your report data to compare against peers and make the business case for investment in privacy automation.

Actionable Recommendations

RadarFirst’s 2025 Privacy Benchmarking Report underscores that effective data incident management is about more than mitigating headline-grabbing breaches. Nearly 90 % of incidents affect ten or fewer individuals, yet these “small” events account for the lion’s share of a privacy team’s workload and risk exposure. 

By documenting every incident, regardless of size, and automating triage and risk assessments, organizations can not only build a robust audit trail but also free up resources to focus on truly critical cases. Moreover, with an average seven-day window to discovery and a two-week stretch to assessment, tightening each response phase through standardized forms, pre-built risk templates, and interim SLAs can dramatically reduce legal and reputational exposure.

Perhaps most striking is that automation isn’t just a “nice to have” for large programs; teams of any size can optimize their timelines and notification rates. Across industries, only 8.5 % of documented incidents become notifiable breaches—yet manual processes often drive over-notification, overload privacy teams, and erode stakeholder trust. By leveraging RadarFirst’s platform to enforce consistent documentation, streamline workflows, and benchmark performance against peers, organizations can transform incident management from a reactive burden into a proactive advantage.