The unencrypted hard drive - missing from a prison…

The Information Commissioner’s Office really had no choice but to come down hard on the National Offender Management Service recently, after a portable hard drive used to back up the prisoner intelligence database went missing from a prison security department.

Although nobody knew when it had actually gone missing, it could have been gone for almost a week since it had last been used on 18 May 2013 for the weekly back up - but was missing when staff went to back up six days later. It had not been locked in the fireproof safe afterwards, contrary to policy.  Not only was it missing, it was also unencrypted and had not been password protected. It contained sensitive information about almost 3000 prisoners, including names and dates of birth, length of sentence, offence(s), physical descriptions and distinguishing marks, plus intelligence information about drug use and links to other prisoners or organised crime - certainly not the sort of details you’d want to lose.

Although only nine staff members had access to the area where the hard drive was used and the area was controlled by a keypad system, the door to the Security Department could be opened by anyone on the prison staff.

To make matters worse, this wasn’t the first time something like this had happened. Back in October 2011, an almost identical breach involving 16,000 prisoners in another establishment had taken place, and the ICO had been told that because of this, encrypted hard drives had been supplied to 75 prisons that had been using unencrypted portable hard drives to back up prisoner intelligence information. Unfortunately, nobody realised that the encryption software required manual activation and the IT provider was never asked to check that the encryption software was working, so all the 75 prisons carried on using insecure portable hard drives for at least a year afterwards.

The software has now been activated and automatic upgrades enabled. The hard drive was never recovered although it doesn’t appear to have been accessed and there was no evidence that it fell into the wrong hands.

Because there had already been a virtually identical serious breach, the Commissioner considered that this was a very serious contravention of the seventh data protection principle;

“Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data”

The National Offender Management Service was fined £180,000. It just underlines the fact that even though you think you’re doing everything you can to comply with the rules, sometimes it can be the simplest thing you overlook that can lead to a damaging security breach. 

Do you know where your backup drives are kept, and have official policies in place to ensure that they don’t go missing? Are the drives encrypted? Can you imagine what would happen if the personal information you keep backed up were to be lost, either for your business or your clients? If you’re unsure of how to make sure that this sort of faux pas doesn’t ever happen to you, contact me and I will be delighted to provide you with guidance and advice.

Help, it's all gone Pete Tong (wrong)! What to do when a data breach happens.

I was at a conference the other day where the speaker said that information security is low on the list of a company's priorities until it goes wrong.There was a discussion about Talk Talk and how the weakness in their cyber security was well known in IT circles. How much would it have cost Talk Talk to make the necessary changes to the system? I am guessing significantly less than the £80m it has cost them in the four months since the breach.

So what is a data breach? Simply this is when personal information ends up somewhere it isn't supposed to. The big breaches that hit the press involves lots of people's information but in smaller companies it can be as simple as a letter intended for one person being incorrectly sent to someone else, a spreadsheet of information being sent to the wrong email address or a fax being sent to the wrong number. It should not take your organisation to lose lots of information before it takes action. Each breach is an indication that there is something wrong with your systems, whether that be the actual process followed, the equipment or failing to train the individual. Learn from it.

A report by PWC shows that almost all businesses had experienced at least one data breach incident in the past year, with 90% of large organisations and 74% of small businesses reporting a security breach in the survey. In addition to the reputational damage and the cost of "fixing" the weakness, there is the disruption to the business.

The most costly breaches are malicious or criminal attacks, such as hacking.

Negligent employees are the top cause of data breaches.

In many organisations, the same personal information is available to a number of different departments, this increases the potential of a breach as more staff have access. Personal information is a valuable business asset, yet we don't always treat it that way.

So what happens when it goes wrong and there is a data breach?

Here's your basic action plan:
1 - Can you get it back? Do you know where it is and can you retrieve it?
2 - Do you know what information has been breached, who it is about and what the information was? In this case you will need to consider whether the information that has been released could cause potential damage or distress to the individual. You may then need to contact affected individuals and inform them of the breach. You may also need to contact the ICO and notify them of the breach.
3 - Investigate and remedy how the breach occurred so that further breaches are avoided. This may involve specialist advice or skills.
4 - Contact the police if applicable.
5 - Continue to update those who need to know with information about the incident.
6 - Create a policy which shows how you will handle a loss of data. This helps everyone understand what they should be doing.
7 - Train your staff in data protection compliance so they understand the importance of good data management and security.

Please remember that these are the basics, I would always advise that you seek professional advice for your circumstances. Remember you have already made a mistake by losing the information, don't compound it by not dealing with the breach correctly.

If you would like to discuss your data protection arrangements then please get in touch. 

ICO warns organisations about cyber security. Could you be at risk?

The Information Commissioners Office has suggested that organisations need to act to ensure that the information collected via their websites is secure. This is after a hotel booking website was hacked and the details of 3814 customers were accessed. You can read the full ICO comment here.

This isn't the first incident of websites being hacked for their customer details. In May 2014, Ebay was the subject of hackers and they advised all their account holders to change their password.

In April 2012, the British Pregnancy Advise Service website was hacked the name and logon details of the administrator leaked. At the time the ICO said “Ignorance is no excuse. It is especially unforgiveable when the organisation is handing information as sensitive as that held by the BPAS. Data controllers must take active steps to ensure that the personal data they are responsible for is kept safe."

Ernst and Young have researched cyber attacks and produced a report. Ernst and Young report. Cyber threats are regularly reported in the media and this indicates that attacks are becoming more sophisticated and persistent. If your organisation has not experienced an attack yet, it will no doubt be targeted.

PWC reports that cyber attacks have increased 41% over the last year and the report shows that most attacks are undertaken by a current employees.

Both the PWC and Ernst and Young report are interesting and show the importance of ensuring appropriate security and policies are in place.

If you would like some help identifying any potential weaknesses, please contact me at Lesley@audit-and-risk.co.uk. I shall be happy to help.

Are you protecting your customer information?

One of the most valuable things a company has is its information on customers and clients. Most businesses have information about past customers but also a potential pool of future customers through a mailing list.

So you have details which are valuable to your business but how secure is that information?

Can a member of staff download your customer database onto a memory stick?

Would you know that it had happened?

Can a member of staff email your database to themselves or someone else?

The ICO can prosecute staff who send emails containing personal information. A paralegal was sending emails to himself containing personal information about clients before he left one law firm to join another, the ICO prosecuted.

A car rental manager was prosecuted for selling information about customers, who had an accident, to a claims company. The car rental company picked up an irregularity and reported it to the ICO.

People are concerned about the security of their information and want to do business with organisations that hold their information securely and don't share it with other organisations. Do you systems ensure that your customer information remains yours and you know who has access to it at any time?

If you are concerned about your data security contact me at Audit & Risk Professionals and I will be happy to talk you through how we can help.

Top IT security threats

The Information Commissioners Office has recently issued a report on the top IT data security threats which have led to some data breaches and some monetary penalities for the companies involved.

The top eight computer security weaknesses highlighted in the report include:

• a failure to keep software security up to date;
• 
  
  a lack of protection from SQL injection;
• 
  
  the use of unnecessary services;
• 
  
  poor decommissioning of old software and services;
• 
  
  the insecure storage of passwords;
• 
  
  failure to encrypt online communications;
• 
  
  poorly designed networks processing data in inappropriate areas; and
• 
  
  the continued use of default credentials including password.

 You can read the full report at http://ico.org.uk/news/latest_news/2014/~/media/documents/library/Data_Protection/Research_and_reports/protecting-personal-data-in-online-services-learning-from-the-mistakes-of-others.pdf

The report is not aimed at IT professionals and is an easy read, highlighting the most common errors organisations make with some good examples.