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

Public sector, private data – is outsourcing the Service Desk too risky?

As the Treasury announce cuts amounting to £6.25bn, £95m of which deriving from a reduction in IT spending, attention is once more directed towards outsourcing as a means to reduce IT expenditure. But Information Technology stores and processes large amounts of personal, sensitive and confidential data, and when it comes to the public sector it can have a very high level of sensitivity, hence a lot of trust is bestowed upon personnel that have access to it. It is already difficult to place confidence in in-house staff, due to the high number of data breaches that are perpetrated by internal staff, backed up by statistics, but the option of off-shore outsourcing elevates the threat level from code yellow to code red.

Widespread use of Cloud computing is unlikely to become a reality in the foreseeable future: strict regulations relating to the Data Protection Act, which the public sector in particular follows religiously, make it virtually impossible to obtain assurances that the data stored outside the organisation’s premises is adequately controlled and kept secure. However, remote access provided to support staff based at another location, be it in the same or another country, still presents a risk in that information can still be collected and recorded. 

With the government CIO, John Suffolk, encouraging the use of outsourcing to countries offering cheaper labour as a cost-cutting strategy, it is time to understand to what extent this can be done and if the public sector can really benefit from off-shoring the Service Desk after all.

Organisations in the public sector are essentially different from private companies: although it seems obvious, it is important to bear in mind that they are funded by British taxpayers, and therefore work for them. However, providing access to personal and sensitive data to companies thousands of miles away and outside the European Union which have different culture, ethics and laws might put the safety of their personal details at risk. For instance, information such as identity, financial and health records can fall into the wrong hands and be used for malicious intent. Not long ago, ITV found that British medical and financial records held abroad could be bought for just a few dollars. No matter how ‘rare’ this event might be, it is not a risk Britons are prepared to take, if the decision were up to them.

It is certainly difficult for organisations in the public sector to carry out a satisfactory level of service when their budgets are being reduced, but it is important to think about the consequences of outsourcing the IT department: a move initially intended to save money can end up making the organisation lose money as a result of large fines and court cases, and most importantly, it can lead to a loss of credibility and reputation.

Recognising a ‘safe’ provider is not easy, especially as identification of a risky supplier often only happens once a breach has been committed, when it might be too late for an organisation to escape liability and to save face. However, it is possible to assess a provider’s trustworthiness before a breach occurs: they should follow Best Practice and have a mature Information Security Management System in line with the ISO 27001 standard, assessed through an independent security review, risk assessment and gap analysis.

There are also better alternatives to extreme or risky versions of outsourcing. For example, the IT department can be kept internal, for better control, but be managed by a third party which is aware of the stringent safety measures necessary for working in this peculiar sector. That said, most information security breaches pertain to threats inside an organisation and are in many cases not a malicious act but a consequence of ignorance, frustration or lack of risk awareness. Well-trained and appropriately-skilled Support staff can reduce these security incidents to a minimum, as would implementing organisational-wide information security awareness sessions.

Management commitment within the industry is especially important to convey the significance of protecting personal and sensitive data and the seriousness of breaching the Data Protection Act, which does not only concern IT staff. Extensive training is necessary to raise awareness across the entire organisation – whenever there is a data breach it is never the provider that suffers the worst consequences, but the organisation’s reputation.

 

David Cowan, Head of Infrastructure and Security

This opinion piece appears in this week’s Dispatch Box on Public Technology: http://www.publictechnology.net/sector/public-sector-private-data-outsourcing-service-desk-too-risky