In January 2013 US beverage giant Coca Cola confirmed laptops containing data belonging to 74,000 individuals including former and current employees, contractors and suppliers were stolen by an employee from Coca Cola headquarters in Atlanta. The type of personal information affected by this incident included names, social security numbers, addresses, financial compensation details and ethnicity.
Following the incident Coca Cola suffered heavy criticism for failing to adequately protect the personal information and for the delay in notifying those individuals affected. In November 2014 a class action suit was subsequently filed by those affected and Coca Cola are now facing further reputational damage and potential legal and financial impacts.
The on-going effects of this incident highlight the importance of ensuring appropriate and adequate organisational and technical measures are taken in relation to the security, storage and use of personal information on portable devices such as laptops.
Under Irish data protection law data controllers and processers have an obligation to put appropriate security measures in place to prevent loss and unauthorised disclosure or alteration of data. There is also a requirement to take reasonable steps to ensure staff and other persons at the place of work are aware of these security measures and their obligation to comply with them.
The Office of the Data Protection Commissioner has issued a comprehensive guidance note on data security which states that the most important security measure to be implemented relates to staff training and awareness. Encryption is seen as an essential security measure where data is to be stored on a portable device (e.g. Laptop, mobile phone and Ipad/tablet etc.).
To ensure compliance with the security requirements in data protection law, organisations should assess the devices used by their business to determine if the appropriate measures are in place to minimise the risks associated with portable device theft, loss or unauthorised access.