Category Archives: Medical Practices

The Burnett Practice

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Breach details

What Names and email addresses.
How much About 175 records.
When 3 October 2012 or earlier
Why The email service provider that the practice used wasn’t suitable to send sensitive medical results because it didn’t provide the appropriate technical security measures. As a result the practice’s email account was hacked.

BW Comments

Organisations should view this as an indication that if cloud-based, web-email services are used, services that offer two-factor authentication (e.g. Google Authenticator) should be selected.

Regulatory action

Regulator ICO
Action Undertaking to comply with the seventh data protection principle
When 26 April 2013
Details The practice must use secure means of communication for test results – email can only be used if its security can be guaranteed. A security policy that is adequate to transfer patient data securely must be put in place, and staff must be made aware of this and trained.

BW Observations

Based on previous decisions, the loss of 175 medical records would seem to be a candidate for a Monetary Penalty rather than an undertaking. However, in this case the Commissioner would have struggled to satisfy the ‘known or should have known’ test given that most people (incorrectly) assume their email is generally safe from third party attack.

Links

View PDF of The Burnett Practice Undertaking (Breach Watch Archive)
View PDF of The Burnett Practice Undertaking (Via ICO Website)

Follow Up

The ICO conducted a follow up assessment on 17 October 2013.
View PDF of the Burnett Practice Undertaking Follow Up (Breach Watch Archive)
View PDF of the Burnett Practice Undertaking Follow Up (Via ICO Website)

Pharmacyrepublic Ltd

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What

Loss of sensitive personal data.

How much

Approximately 2,000 records.

Why

Theft of a patient medication record system.

Regulator

ICO

Regulatory action

Undertaking issued to ensure that adequate procedures are put in place to ensure that PMR pharmacy data is securely handled prior to any future transfer of pharmacy ownership. All staff must be made aware of the data controller’s procedures for the safe storage and retrieval of personal data.

Reason for action

The PMR system was stolen for the pharmacy while it was undergoing a transfer of ownership. Although the PMR was password protected the data controller had not taken adequate steps to safely retrieve the PMR system and return it to the wholesale company, whom they had been paying a monthly retainer to, prior to the transfer of ownership process.

When

27 Mar 2012

Links

View PDF of the Pharmacyrepublic Ltd Undertaking (Via ICO Website)

View PDF of the Pharmacyrepublic Ltd Undertaking (Breach Watch Archive)

Dr. Pervinder Sanghera of Arthur House Dental Care

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What

Loss of personal and limited sensitive personal data.

How much

Unknown.

Why

An unencrypted USB stick containing records relating to patients and employees of Arthur House Dental Care was found in a public place. A number of spreadsheets containing personal data stored on the device were password protected.

Regulator

ICO

Regulatory action

Undertaking issued to ensure that all portable media devices used to store and transport personal data are sufficiently encrypted. Staff must be trained not to take data off site unless necessary.

Reason for action

The memory stick had been utilised as a temporary back-up solution when the existing electronic back-up system at the practice failed. As a result of the back-up failure the memory stick was moved from the dental practice to the data controller’s home for safekeeping on a number of occasions. It is likely the memory stick was lost in transit.

When

01 March 2012.

Links

View PDF of the Dr. Previnder Sanghera Undertaking (Via ICO Website)

View PDF of the Dr. Previnder Sanghera 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)

Healthcare Locums PLC (HCL)

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What

Loss of personal information .

How much

Unknown.

Why

A Network Storage device containing records relating to doctors employed by the data controller was lost or stolen in transit during a move and was sold on eBay. It was eventually recovered.

Regulator

ICO

Regulatory action

Undertaking issued to ensure that contracts are put in place between the Data controller and any contractors it uses to process personal data on its behalf, who must be sufficiently checked. Sufficient physical security measures must be implemented and records of data contained on physical media must be kept.

Reason for action

Neither the network storage device or the personal data contained within it were encrypted. No inventory of equipment being transported was taken and therefore the loss/theft of the device went unnoticed until the eBay buyer contacted the Data controller.

When

14 October 2010

Links

View PDF of the Healthcare Locums PLC Undertaking (Via ICO Website)

View PDF of the Healthcare Locums PLC Undertaking (Breach Watch Archive)

Lampeter Medical Practice

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What
Loss of personal data.

How much
8,000 records.

Why
Loss of an unencrypted memory stick that was posted by recorded delivery.

Regulator
ICO

Regulatory action
Undertaking issued to ensure that any portable media devices used to store data are sufficiently encrypted and that physical security measures are put in place to prevent unauthorised access to physical data, particularly in respect to the unauthorised use of memory sticks.

Reason for action
A practical database was downloaded, without authorisation onto an unencrypted and non password protected memory stick

When
26 May 2010

Links
View PDF of the Lampeter Medical Practice Undertaking (Via ICO Website)

View PDF of the Lampeter Medical Practice Undertaking (Breach Watch Archive)

Billing Pharmacy Limited

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What
Loss of sensitive personal data.

How much
About 1,000 records.

Why
An unencrypted computer containing the personal data of around 1,000 patients was stolen.

Regulator
ICO

Regulatory action
Undertaking issued to ensure that all portable media devices and computers used to store or transport personal data are suitably encrypted. A data protection policy must be drafted and all staff must be made aware of the data controller’s policy for the storage and use of personal data and be trained to follow it. Physical security measures must be adequate to prevent unauthorised access to personal data.

Reason for action
It was not possible to notify the patients affected by the theft as the data on the computer was not separately backed up. Further enquiries revealed that the data controller did not have in place appropriate policies and procedures with regards to data protection matters.

When
8 September 2009

Links
View PDF of the Billing Pharmacy Limited Undertaking (Breach Watch Archive)

Chelsea & Westminster Hospital

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What
Loss of sensitive personal data.

How much
143 records.

Why
An unencrypted memory stick containing patient information was stolen from an unattended and unlocked office being used for a walk in clinic.

Regulator
ICO

Regulatory action
Undertaking issued to ensure that all mobile data storage devices are sufficiently encrypted. Physical security measures must be adequate to prevent unauthorised access to personal data. All staff must be made aware of the data controller’s policy for the storage of personal data and be trained to follow it.

Reason for action
The disc was not encrypted and in fact was not even password protected The employee was not aware that secure network drive and encryption facilities were available and had used a personal memory stick since Trust equipment was not available.

When
2 June 2009

Links
View PDF of the Chelsea & Westminster Hospital Undertaking (Breach Watch Archive)