Category Archives: ICO undertaking

Luton Borough Council

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What

Discovery of flawed encryption.

How much

None

Why

A flaw in the encryption of memory sticks allowed them to be reformatted, removing the encryption.

Regulator

ICO

Regulatory action

Undertaking issued to ensure that all encryption is up to a sufficient standard.

Reason for action

Encryption was of an insufficient standard and this was only discovered during a recall of old devices.

When

02 September 2011.

Links

View PDF of the Luton Borough Council Undertaking (Via ICO Website)

View PDF of the Luton Borough Council Undertaking (Breach Watch Archive)

London Borough of Greenwich

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What

Two incidents of disclosure of sensitive personal information.

How much

Two records.

Why

Information sent to incorrect email addresses.

Regulator

ICO

Regulatory action

Undertaking issued to ensure that the Council’s IT policy specifically makes it clear that data is not to be sent to personal emails.

Reason for action

Both incidents saw staff fail to adhere to the Council’s IT policy, regarding the encryption of data. However the policy did not explicitly prevent the sending to data to personal emails.

When

10 August 2011.

Links

View PDF of the London Borough of Greenwich Undertaking (Via ICO Website)

View PDF of the London Borough of Greenwich Undertaking (Breach Watch Archive)

Lush Cosmetics

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What

Compromise of credit card details.

How much

5,000 records.

Why

Malicious website intrusion.

Regulator

ICO

Regulatory action

Undertaking issued to ensure that the website is subject to continued penetration testing and kept to an appropriate level of security.

Reason for action

Security measures in place were deemed insufficient to prevent a determined attack.

When

09 August 2011.

Links

View PDF of the Lush Cosmetics Undertaking (Via ICO Website)

View PDF of the Lush Cosmetics Undertaking (Breach Watch Archive)

Bay House School

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What

Loss of sensitive personal data.

How much

20,000 records.

Why

Malicious website intrusion.

Regulator

ICO

Regulatory action

Undertaking issued to ensure that encryption is used, annual penetration tests are performed and password policies are updated to ensure security.

Reason for action

A member of staff was using the same password for the school’s website and management systems, allowing the attackers, including at least one pupil, with the system administration information required to attack the system.

When

08 August 2011.

Links

View PDF of the Bay House School Undertaking (Via ICO Website)

View PDF of the Bay House School Undertaking (Breach Watch Archive)

HCA international Limited

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What

Loss of sensitive personal data.

How much

Unknown.

Why

Theft of an unencrypted laptop from one of the group’s hospitals.

Regulator

ICO

Regulatory action

Undertaking issued to ensure that sufficient standard encryption is used and physical security is upgraded.

Reason for action

  • Laptop containing the data was unencrypted.
  • Physical security of the laptop was deemed insufficient to prevent theft.

When

05 August 2011.

Links

View PDF of the HCA International Limited Undertaking (Via ICO Website)

View PDF of the HCA International Limited Undertaking (Breach Watch Archive)

Lewisham Council and Wandle Housing Association

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What

Loss of personal data.

How much

20,000 records.

Why

Loss of an unencrypted memory stick in a London pub.

Regulator

ICO

Regulatory action

Undertaking issued to ensure that data is not transferred onto unencrypted personal media devices.

Reason for action

Staff were insufficiently trained and unaware of the dangers of copying sensitive information to personal, unsecure, devices.

When

04 August 2011.

Links

View PDF of the Lewisham Council Undertaking (Via ICO Website)

View PDF of the Lewisham Council Undertaking (Breach Watch Archive)

View PDF of the Wandle Housing Association Undertaking (Via ICO Website)

View PDF of the Wandle Housing Association Undertaking (Breach Watch Archive)

Kirklees Metropolitan Council

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What

Personal data unnecessarily disclosed.

How much

18 records.

Why

Records let visible in an employees’ car.

Regulator

ICO

Regulatory action

Undertaking issued to ensure that sufficient security measures are implemented and checked to prevent inappropriate disclosure of personal data.

Reason for action

Similar accidental disclosures had already occurred during the past year and insufficient measures had been put into place to prevent any reoccurrences.

When

29 July 2011.

Links

View PDF of the Kirklees Metropolitan Council Undertaking (Via ICO Website)

View PDF of the Kirklees Metropolitan Council Undertaking (Breach Watch Archive)

University of York

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What

Loss of personal data.

How much

148 records.

Why

Failure to close a test area on the University’s website that contained student records.

Regulator

ICO

Regulatory action

Undertaking issued to ensure that university IT staff ensure the appropriate security of all data following maintenance.

Reason for action

Insufficient managerial control was in place to ensure that the test version of the database was deleted.

When

20 July 2011.

Links

View PDF of the University of York Undertaking (Via ICO Website)

View PDF of the University of York Undertaking (Breach Watch)

Lancashire Police Authority

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What

Loss of sensitive personal data.

How much

Unknown.

Why

Sensitive personal data was accidentally published on the data controller’s website.

Regulator

ICO

Regulatory action

Undertaking issued to ensure that sufficient training and security measures are put into place to prevent accidental disclosure of sensitive data.

Reason for action

The data controller was insufficiently familiar with the relatively new system being used to publish their website and failed to take immediate action having been made aware of the error.

When

19 July 2011.

Links

View PDF of the Lancashire Police Authority Undertaking (Via ICO Website)

View PDF of the Lancashire Police Authority Undertaking (Breach Watch Archive)

Northamptonshire Healthcare NHS Foundation Trust

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What

Loss of sensitive personal data on two occasions.

How much

One record.

Why

A patient’s records had not been indexed.

Regulator

ICO

Regulatory action

Undertaking issued to ensure sufficient measures are put into place for the storage and security of physical records.

Reason for action

Not all records held by the data controller were indexed.

When

18 July 2011.

Links

View PDF of the Northamptonshire Healthcare NHS Foundation Trust Undertaking (Via ICO Website)

View PDF of the Northamptonshire Healthcare NHS Foundation Trust Undertaking (Breach Watch Archive)