Think W3 Limited

Breach details

What A malicious hacker was able to access significant amounts of customer data, including credit card details, after targeting Think W3 Limited’s website.
How much 1,163,996 records containing credit or debit card details, of which 430,599 were current.
When 21 December 2012.
Why A system intended for internal purposes was installed on the same web-sever as the businesses e-commerce application containing customer data. In order to facilitate working from home this service could be accessed via a login page on a non-customer facing website which was publicly available over the internet. The login page was not secure due to a coding error that was missed, as no security testing had been done the basis that this page was not public facing. The hacker was able to exploit this vulnerability and gain administrative access to all the data on the web server.

Regulatory action

Regulator ICO
Action Monetary penalty of £150,000
When 23 July 2014.

Why the regulator acted

Breach of act Breach of the Seventh Data Protection Principle: Think W3 limited failed to take appropriate technical measures to ensue the security of personal data, predominately though failing to undertake suitable security testing, due to a failure to understand the extent to which the web server could be accessed via the internet, or to meet PCI DSS compliance requirements.
Known or should have known  By 2011 Think W3 Limited were aware of a number of issues with its PCI  DSS compliance, causing them to review their security practises. However they were slow in implementing improvements, despite being aware of the risk of contravention.
Likely to cause damage or distress Although CCV2 / CvC2 values were not obtained, the data obtained was clearly of interest to the attacker, due to the targeted nature of the attack, and could be used for fraudulent purposes. The data subjects would rightly be distressed to learn that their data had been accessed by a malicious third party.