Article 14 sets an early warning without undue delay and within 24 hours of awareness. A notice follows without undue delay and within 72 hours. A report chain that works only in office hours can fail.

The alert plan should answer four questions at all times. Who checks the trigger? Who decides if the maker must report? Who can file? Who proves that the filing worked?

Name people and backups

Name a main person and at least one backup for each role. Give the on-call staff a current contact, not a team name with no owner. Set how long to wait for a reply before calling the backup.

Keep legal and product security choices apart. Do not let either rest on one person. A short-term delegate must know their limits and when to raise doubt.

Define the escalation envelope

For each role, record the contact order, reply time, power limit, and systems needed. State the fact that sends the case to the next person. The on-call event lead should own the live due time. They should see if trigger review, approval, filing, or proof is holding up the case.

Prepare a short handoff pack. Name the maker, product, trigger result, awareness time, and due times. Add approved facts, open points, CSIRT route, and proof location. The backup should not search many private mail boxes to grasp the case.

Keep each password private. Each assigned person needs their own controlled access. Use an approved way to hand off the case. Do not share a password or loose file dump.

Rehearse the difficult handoffs

Test a case that starts late on Friday, crosses time zones, and lacks full product facts. Check that the team can find the CSIRT route and open the filing account. It must join the approved facts and save proof of a fake filing.

In a second drill, make the main lawyer and filing person hard to reach. Ask the backups which choices they can make and which need a higher owner. Keep the outside clock in view while they wait. Stop before any real outside act.

Measure proof that can be seen. Was the contact accepted? Was the pack found and trigger choice clear? Was the approval path chosen and draft made? Was fake filing proof saved? A claim that someone “would handle it” is not a result.

End with a named owner for each gap. A perfect drill score is not the goal. The chain must stay owned when the first people called are away.

Continue this workflow with the reporting-access continuity plan and the readiness exercise.