The Information Commissioner's Office (ICO) has fined the Cabinet Office £500,000 for disclosing the postal addresses of the 2020 New Year Honours recipients online. The ICO found that the Cabinet Office had failed to put appropriate technical and organisational measures in place to prevent the unauthorised disclosure of people's information, in breach of data protection law.
On 27 December 2019 the Cabinet Office published a file on the government's website containing the names and unredacted addresses of more than 1,000 people announced in the New Year Honours list. People from a wide range of professions across the United Kingdom were affected, including individuals with a high public profile. After becoming aware of the data breach, the Cabinet Office removed the weblink to the file. However, the file was still cached and accessible online to people who had the exact webpage address.
The personal data was available online for a period of two hours and 21 minutes and it was accessed 3,872 times.
Due to the data being published in the public domain, the ICO received three complaints from affected individuals who raised personal safety concerns resulting from the breach. The Cabinet Office was also contacted by 27 individuals with similar concerns.
The ICO's investigation revealed that the Honours and Appointments Secretariat (HAS) in the Cabinet Office had introduced a new IT system in 2019 to process the public nominations for the New Year Honours. The IT system was set up incorrectly by the Cabinet Office, which meant that the system generated a CSV file that included postal address data. Due to tight timescales to get the New Year Honours list published, the HAS operations team decided to amend the file instead of modifying the IT system. However, each time a new file version was generated, the postal address data was automatically included in the file.
The Cabinet Office confirmed that there was no specific or written process in place in HAS at the time to sign off documents and content containing personal data before being sent for publication.
The ICO acknowledged that the Cabinet Office had acted promptly when made aware of the data breach, undertaking a full incident review. Further, the Cabinet Office has since instigated several operational and technical measures to improve the security of its systems, and an independent review focusing on data handling was completed in 2020.
Steve Eckersley, ICO director of investigations, said:
When data breaches happen, they have real life consequences. In this case, more than 1,000 people were affected . . . . The Cabinet Office's complacency and failure to mitigate the risk of a data breach meant that hundreds of people were potentially exposed to the risk of identity fraud and threats to their personal safety. The fine issued today sends a message to other organisations that looking after people's information safely, as well as regularly checking that appropriate measures are in place, must be at the top of their agenda.
For further information on this topic please contact Christina Henry at Wiggin by telephone (+44 20 7612 9612) or email ([email protected]). The Wiggin website can be accessed at www.wiggin.co.uk.