How many police officers does it take to email 10,000 criminal records to a journalist by accident?

Just one. But this is not a joke.

A simple mistake caused by the recipient auto-complete function within an email client resulted in Gwent Police committing what has been referred to as the first major UK data security breach since the new regulations introduced by the Information Commissioner’s Office came into force in April this year. What is of particular interest about this case is that a breach of this scale (10,000 records) and gravity (the data leaked involved personal and sensitive information) occurred within a police environment which allegedly had strict policies and procedures. If that is the case, how were the policies circumvented so that the officer was able to commit this breach, and are security incidents caused by human error ultimately unavoidable?

The elephant in the room is that personal and sensitive data such as criminal records should not have been placed in an excel spreadsheet if strict processes were indeed implemented, not even for internal use. In fact, it is important that organisations dealing with personal, sensitive and confidential data have well-defined information asset classification and media handling procedures. Through the identification and labelling of confidential and sensitive data, all information would be classified based on its value and risk to the organisation in terms of Confidentiality, Integrity or Availability. Criminal records, for instance, would be labelled as private, restricted or confidential depending on the classification marking scheme and would be automatically restricted to only personnel who are authorised to access this information. If a similar scheme had been in place at Gwent Police and the information clearly labelled and controlled, then the breach would have been almost certainly avoided because the data included in the email would not have been accessible by non-authorised personnel.

It is possible, though, that Gwent Police actually had all the tools necessary to protect the data, but lacked the general awareness and training extended to all personnel. Certainly it wouldn’t be the only organisation affected by this issue.  Recent data collected by PricewaterhouseCoopers, illustrates that despite spending more than ever on information security, only half of companies surveyed provide staff with any form of security training, and only  one in five large organisations believe their security policies are very well understood by their employees. The results of the latest Information Security Breaches Survey highlight the need for better education in order to reduce risks, as a striking 92 per cent of firms with over 250 employees and 83 per cent of smaller firms (up to 25 members of staff) admit to have recorded a security incident in the past year.

Lack of awareness, little understanding of the implications and perhaps forgetfulness or stress are the most likely causes of human error, which can result in staff ignoring security measures, such as sending confidential data to their private email address, losing an unencrypted USB device or accidentally sending information to the wrong recipient. It is important to note that in these cases, if the data was correctly labelled and encrypted there wouldn’t be a breach of the Data Protection Act. In most cases, the ICO serves an enforcement notice if there is a failure to comply with the Act and the failure has caused or is likely to cause damage or distress to anyone.  The potential repercussions could include the public disclosure of the facts by the ICO, internal disciplinary actions within the organisation or a fine which, under the new regulations, can amount to £500,000.

Comparison with data collected by PwC in 2008 shows that the cost of cybercrime to the business has doubled to more than £10bn in just two years. The average cost of a breach in a large organisation is now between £280,000 and £690,000 (it was £90,000 – £170,000 two years ago) and due to the increased use of cloud computing, risks are rising rather than diminishing. Although the number of organisations with a formal Information Security policy and sufficient IT security tools has improved, the measures seem to be unable to resolve the greatest threat, the human factor: 46 per cent of large organisations have declared that staff have lost or leaked confidential data, which in 45 per cent of cases resulted in a “very” or “extremely” serious breach of information security.

As this data suggests, even with the most advanced technology in place it is not possible to eradicate risk altogether; however, it is possible to mitigate the damage and prevent mistakes like the one the Gwent police officer made by adopting encryption technology and policies that are emitted from the top and are backed up by disciplinary procedures – but it is extremely important that these are accompanied by extensive training and awareness sessions across the organisation. By educating all members of staff, including trusted partners and 3^rd party suppliers, it will help reduce, although not eliminate completely, risks to a level that is acceptable for the organisation, which in the case of large organisations which deal with sensitive information, such as the Police or other public sector organisations, needs to be as low as possible.

David Cowan, Head of Infrastructure and Security

This article has been published on Government & Public Sector Journal: http://www.gpsj.co.uk/view-article.asp?articleid=303

Is information safe enough at NHS trusts?

It looks like NHS trusts are starting to realise that Information Security is not just a matter of using complex passwords, locking drawers at the end of the day and installing the latest firewall and antivirus solutions. The Information Commissioner has been particularly critical of the NHS in the past due to a high proportion of security breaches as a result of inadequate Information Security controls and staff awareness programmes.

The result has been an NHS wide initiative to ensure all removable media including laptops and USB drives are encrypted. However, this may not be enough. As reported by the BBC recently, a remarkable amount of non-medical personnel at UK trusts have access to patient records including recent medical history – at least 100,000 including porters, hospital domestics and IT staff, a Big Brother Watch survey stated.

It seems like the risk is not only from staff at off-shore service providers collecting and selling British data to make a few extra pounds, as reported on ITV not long ago. It also comes from internal personnel who have the potential to access extremely sensitive data without the appropriate authority or preventative controls.

 This is not surprising: data collected in the BIS Information Security Breaches Survey 2009 illustrated that 60 per cent of all companies suffered a security breach in the previous two years and of these, 50 per cent were perpetrated by staff, often premeditated or malicious but in many cases simply a matter of a stolen laptop or lost removal media device.

There is an obvious need for greater awareness of information security regulations across the entire organisation, and measures must be taken to protect personal and sensitive data. Management in particular need to be involved in order to avoid resentment, complacency and to ensure everyone takes the matter seriously.

In the case of the NHS, information at risk is highly sensitive and breaches can have very serious outcomes. Consequences of Data Protection Act breaches are not confined to costly fines and a few employees being fired – it is the organisation’s reputation that suffers the most.

This risk can be mitigated by conducting an independent gap analysis and security review which would assess compliance with Information Security best practice, i.e. ISO27001, IG Toolkit v7, and certify that information held within an organisation is secure, reducing the risk of incidents and the cost to the business.

Equally important are staff awareness sessions to which not only general staff but executive participation is required, which is vital in creating a culture where Information Security is part of the organisation’s DNA.

 

David Cowan, Head of Infrastructure and Security