Sign Of The GDPR Fines To Come…?

GDPR Fines

It was announced last week that the credit reference agency Equifax has been fined by the ICO in  the sum  of £500,000 as a result of failing to protect the personal data of 15 million UK citizens and 146 million in the US during the 2017 data breach.

http://cyberbrokers.co.uk/equifax-the-anatomy-of-a-data-breach/

The long awaited ICO report found that the UK arm did not have in place the appropriate steps for processing and protecting the personal information of its data subjects.

https://ico.org.uk/about-the-ico/news-and-events/news-and-blogs/2018/09/credit-reference-agency-equifax-fined-for-security-breach

The joint ICO and FCA report highlighted the following :-

  • Data was retained for longer than was necessary
  • Inadequate measures were in place to manage personal information
  • IT security was not of the highest standard with the compromise of data being likely.
  • The US Department of Homeland Security had advised Equifax Inc about a critical vulnerability in 2017
  • Customers data should have been treated in a much higher regard.

The investigation was carried out under the 1998 Data Protection Act as opposed to the recent General Data Protection Regulation (GDPR) that came into force on 25th May this year. The ICO imposed the maximum GDPR fine of £500,000 under the previous Act.

Under the GDPR the ICO has the powers to set a maximum possible fine of 4% of Global turnover of a company the consequences therefore of this data breach could have been much higher should this data breach have occurred post 25th May this year.

The approach by the ICO to GDPR fines and the imposing of these to businesses who are responsible for data breach is still very much unknown as the climate remains untested and only time will tell how this is imposed and to its possible severity. The Equifax fine does suggest that the ICO will be treating such data breaches very seriously and will wish to demonstrate that the new legislation does have “teeth” and that they will act accordingly.

 

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Loss of Reputation – The Biggest Cyber Threat ?

Loss of Reputation

Is the loss of reputation on the biggest cyber threats that a business faces today ?

A good reputation takes a long to build up but the emerging cyber threat landscape can ruin this reputation in a matter of hours. It is important therefore that businesses have in place a loss mitigation plan in place in order to manage this disaster case scenario.

One of the highest profile cyber attack in the UK was the data breach at TalkTalk where the long term consequences of this still being felt within the business today.

The impact on the reputation a business of a data breach 

  • Loss of existing customers
  • Loss of confidence in the business
  • Competitors exploiting the situation
  • Share price of the business
  • Loss of future earnings
  • The stigma of a data breach
  • The attractiveness of future investment in the business
  • Attracting new employees
  • Bad management of the data breach

Be Prepared 

It is essential that the business has an incident response plan in place in order to manage the cyber attack and the ensuing  fall out that will inevitably occur.  This would include a crisis management and business continuity plan.

These should be regularly updated with “dry runs” carried out in order to ensure that they work effectively..

Cyber Insurance 

This specialist form of insurance can help manage and mitigate a cyber attack at both the very early stages of a data breach and also help the business through the process. This is facilitated through the incident services that an insurer offers as part of the policy benefits . This includes public relations consultants and access to a solicitors so that sensitive data can be handled in the most effective manner.

The policy also provides coverage for reputational harm or business interruption coverage modules, typically this would encompass loss of profits and increased costs of working as a result of the data breach.

Policy wordings and intent vary considerably in the insurance market and it is therefore important that an insurance broker with a specialism in this area is utilized.

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Cyber breaches hit UK businesses

Ransomware

Cyber breaches are hitting UK businesses according to a recently released commissioned report by the UK Government.

Two thirds of large businesses UK hit by cyber attack in past year

Following the high profile targeting of  TalkTalk , Vodafone , Weatherspoons it is no surprise that large businesses are still the focus of cyber breaches …… the underlying message to these businesses is that they need to improve their cyber security programs in order to combat these threats.

Main Report Findings

  1. 1 in 4 large businesses encountered a breach once a month
  2. Only one-third of all firms had a written security policy
  3. Only 10% of all businesses had an incident response plan in place should a cyber attack occur
  4. 13% of all businesses set cyber security minimum standards for their suppliers
  5. Only 20% of firms validate the providers of cloud computing services.
  6. 7 out of 10 of the attacks involved compromises by viruses, spyware or malware

Why has this happened ?

The report also highlighted the fact that many firms do not have cyber security programs in place that are in accordance with government guidance such as the Cyber Essentials Scheme and the “10 Steps Guide to Cyber Security”. This is must be a major concern to the Government as these two measures alone would install a good level of cyber security.

Cyber Essentials is generally more difficult to achieve for larger businesses as their systems tend to involve the use of bespoke software and its management. This certification is geared more to standardized systems which is more akin to SME’s . There is therefore a question here whether Cyber Essentials needs to be adapted to larger businesses?

Cyber Insurance

The report also makes reference to 37% of firms having in place some form of cyber insurance , this is either in the form of extensions to professional indemnity insurance policies or stand alone policy specific cyber insurance policies.

A concern raised by the report is that there is a lack of knowledge about what was covered under a cyber insurance policy and the insurance industry therefore has a role to play in helping businesses understand this form of insurance.

Cyber breaches will continue to impact on businesses unless they have a formal cyber security program in place to protect them from the increasingly sophisticated cyber attacks that can compromise a businesses.

Malvertising…..the hidden threat

Malvertising

Malvertising …… the hidden threat – last week a number of major news websites saw their advertisment hijacked by a malicious angler campaign that attempted to install ransomware on users computers. The attack, which was initially targeted at US users, hit websites including the BBC, AOL, New York Times and the NFL ……the combined volume of traffic for these websites totalled billions of visitors.

http://www.theguardian.com/technology/2016/mar/16/major-sites-new-york-times-bbc-ransomware-malvertising

It is understood that the malware was delivered through multiple ad networks, and used a number of vulnerabilities, which included a recently-patched flaw in Microsoft’s former Flash competitor Silverlight.

The Daily Mail , Skype and and the Premier League Fantasy website have all been targeted within the last month with malvertising campaigns.

Malvertising uses advertising networks to spread malicious flash objects and other pieces of malicious code to other websites. Hackers will then upload these malicious flash objects and other pieces of malicious code to ad networks, paying the network to distribute them like as if they are real advertisements.

For example you could visit a newspaper’s website and an advertising script on the website would download an ad from the ad network. The malicious advertisement would then in turn try to compromise the web browser.

Malvertising takes advantage of flaws in software that the user is utilizing in order to infect the user on a legitimate websites, this reduces the need to fool the user to visiting a malicious website.

The most popular times for these attacks are on a Friday when there is less monitoring being carried out for suspicious activities and when there is heavy web surfing during the weekends.

There are a number of methods used for injecting malicious advertisements or programs into webpages such as :-

  • Pop-up ads
  • Drive by downloads
  • Web widgets
  • Malicious banners on websites
  • Third party advertisments on websites
  • Third party forums such as forums or help desks

There are a number of ways of protecting websites from malvertising attacks such as keeping plug-ins and web browsers updated. Risk management also has an important role to play in particularly management and surveillance of the supply chain.

A cyber insurance policy can provide coverage for an attack of this nature through the disruption it may cause to a business and also the vendor services provided via monitoring and forensic investigation.

Cyber Business Interruption – “Biggest Concern”

cyber business interruption

Cyber business interruption is considered by 49% of businesses to be their biggest concern in the event of  a cyber breach according to the Institute of Directors recent policy report “Cyber Security; underpinning the digital economy”

Cyber security: underpinning the digital economy

The report, sponsored by Barclays carried out a survey of 1000 businesses which showed that one in eight members suffered damage as a result of a cyber business interruption attack. Of this 11% suffered actual financial loss which demonstrates that cyber crime can impact on the balance sheet of businesses in a significant fashion. Interestingly only 28% of these incidents were reported to the police.

Some other highlights of the Institute of Directors Policy Voice Survey were as follows:-

  • 57% had a formal cyber/information security strategy in place
  • 49% said they provided cyber awareness training for employees
  • 43% didn’t know where their data was physically stored
  • 72% experienced social engineering scams
  • 20% hold cyber insurance (with 21% unsure if they did have this)
  • 21% are considering the purchase of cyber insurance

The survey demonstrates that cyber security is taking a much higher profile within businesses and they are now actively improving their cyber security but there is room for considerable improvement. There were many key moments in 2015 with the high profile breaches of TalkTalk and Ashley Madison which has made businesses look up and think ” could this happen to us”? The answer is of course “yes” and in fact could be happening right now with an average breach taking six months to discover.

Richard Benham, Professor of Cyber Security Management , the author of the report has identified four key trends that are likely to become increasingly important in the coming years:-

  1. Cyber in the boardroom – cyber risk is now at boardroom level and cyber risk strategies are likely to be formulate here.
  2. Cyber education – the UK government will play an important role through the promotion of Cyber Essentials and the instigation of courses such as The National Awareness Course.
  3. The Cloud – this will rise in prominence but businesses most not ignore the management of their data.
  4. Cyber insurance – this form of insurance has developed in recent years to cover both first and third party exposures of a businesses , whilst still an evolving product it is being considered by more businesses and this is likely to increase.

The Institute commented  “Our report shows that cyber must stop being treated as the domain of the IT department and should be a boardroom priority. Businesses need to develop a cyber security policy, educate their staff, review supplier contracts and think about cyber insurance.”

The report concludes highlighting that cyber security is an international threat, the suggested key is to have in place a credible plan that can assess the large spectrum of threats and how these can best be managed by a business.

UK businesses can achieve this through robust cyber security management , this should be complemented with cyber insurance on the basis that coverage is appropriate for the business and that it is not recognized to be the “cure for all evils” in the cyber threat landscape that exists today.

A cyber insurance policy can provide coverage for cyber business interruption by way of standard coverage or a bespoke policy endorsement therefore helping a business to manage this cyber peril.

Cyber Security risks face education sector

cyber security risks

Is the education sector facing cyber security risks?

In the US last week a hacker broke into the University of California’s computer system which contained 80,000 students. This apparently occurred in December whilst the university was in the process of patching a security flaw in their financial management system.

University of California

This followed a similar breach earlier this year at the University of Florida where private information of current and former employees were accessed going back to 1980. A lawsuit has been issued which is seeking a class action status. There was also criticism on how the breach was managed.

On this side of the Atlantic in December university students were unable to submit work as a result of the academic computer network called “Janet” coming up against a distributed denial of service (DDOS) attack causing reduced connectivity and disruption. The University of Manchester was one of the universities impacted by the DDOS attack.

Earlier, last year the University of London Computer Centre (ULCC) was hit by a cyber attack which again left millions of students unable to access the organisation’s IT services. The centre provides services to over 300 UK institutions and supports over two million higher education and further education students on its open-source learning platform Moodle.

The education sector accounted for nearly 10 per cent of all breaches in the past year, according to cyber security company Symantec.

Symantic Internet Threat Report 2015

Personal Data

Universities and colleges contain an abundance of personal data which makes them attractive to hackers, such as credit card details, medical information of current and former students and employees. This also becomes complicate to manage as students come from many different parts of the world bringing with them wide ranging data protection regulations.

Multiple Entry Points

The education sector traditionally provides multiple entry points with a huge spectrum of users having access to its networks. The access is also available 24/7 365 days a year via many devices that may not be secure such as laptops logging in from remote wi-fi locations.

Social Media

Within the education framework social media features prominently and in the absence of social media policies with specific standards in place this can leave a university vulnerable in terms of the inadvertent sharing of information that may not be meant for the public domain.

Separate Networks

A college or polytechnic may consist of a number of separate networks which may not contain a high level cyber security and therefore present a number of cyber security risks.

Intellectual Property

Certain establishments contain highly sensitive research information in the fields of science, health , defense  and aerospace. This could make them a target for hackers and terrorist organisations.

Cyber Security Research

Cyber security research itself could also be a target with the Global Centre for Cyber Security Capacity building  in Oxford University’s Martin School. A number of universities have been awarded Academic Centres for Excellence in Cyber Security Research, such as the Bristol and Kent Universities which means that they will work more closely with the Government Communications Headquarters (GCHQ).

Cyber liability insurance can play a very important role in supplying an extra layer of comfort in the event of a cyber attack to education establishments, providing coverage for a significant number of the potential cyber security risks that exist in this sector.