Month: November 2020

Act Now Launches New RIPA E Learning Course

The Investigatory Powers Commissioner’s Office (IPCO), like its predecessor the Office of the Surveillance Commissioner(OSC), undertakes inspections of public authorities to ensure their compliance with Part 2 of the Regulation of Investigatory Act 2000 (RIPA).
A common feature of an IPCO report into a council is the highlighting of the lack of regular refresher training for those who undertake covert surveillance, including when using social media.  

The coronavirus pandemic as well as decreasing council budgets means that training staff is difficult to say the least. Social distancing and home working make face to face training impossible and live online training may not always be cost effective for those who need a quick refresher.  

Act Now Training is pleased to announce the launch of RIPA Essentials. This is a new e learning course, consisting of an animated video followed by an online quiz, designed to update local authority employees’ knowledge of Part 2 of RIPA which covers Directed Surveillance, Intrusive Surveillance and CHIS. Designed by our RIPA experts, Ibrahim Hasan and Steve Morris, it uses simple clear language and animation to make the complex simple. 

In just 30 minutes your employees can learn about the main provisions of Part 2 of RIPA including the different types of covert surveillance, the serious crime test and the authorisation process. It also covers how RIPA applies to social media monitoring and how to handle the product of surveillance having regard to data protection. All this at a time and in a place of your employees’ choosing. (See the full contents here.) 

Steve Morris said: 

“Ibrahim and I have over 40 years of experience in training and advising local authorities on covert surveillance and RIPA. We have used this experience, as well as the latest guidance from the Home Office and IPCO, to produce an online training course which is engaging, interactive and fun.” 

With full admin controls, RIPA Essentials will help you to build a RIPA compliance culture in your organisation and develop a workforce that is able to identify and address privacy risks when conducting surveillance. The course is specifically designed for local authority investigators including trading standards officers, environmental health officers, licensing officers, auditors and legal advisers.  

You can watch a demo of RIPA Essentials here. Prices start from as little as £69 plus vat per user. For a bespoke quote please get in touch. 

RIPA Essentials follows the successful launch of GDPR Essentials which has been used by our clients to train thousands of staff in the public and private sector.

Act Now Launches New Advanced Certificate in GDPR Practice

Act Now Training is pleased to announce the launch of the Advanced Certificate in GDPR Practice. It comes following 12 months of development and as a result of the success of our GDPR Practitioner Certificate which, over the last few years, has cemented its position as the gold standard for data protection qualifications.  

Our courses are practical and jargon free. We focus on teaching the skills and knowledge to help delegates do their job every day. Our aim is to help delegates become the most complete DPO for the ever-changing privacy landscape.  

“The training provided practical guidance with useful examples to help inform my application of GDPR in the workplace. The focus was on how to use it rather than learning all the legal minutiae, and from the first session I was able to go away and use what I’d learnt in my Information Governance role.” EG, Hampshire CC  

“A highly informative and interactive course which helped to join the dots together and add layers to my understanding of a complex area. I had some reservations as to how it would be possible to achieve an effective course remotely and would it be as engaging as a classroom-based alternative. Frank managed all this and more, he was approachable, highly knowledgeable and made sure the participants were understanding the content.
I would not hesitate to recommend to colleagues.” SW, Harrogate BC 

Having trained over 1500 data protection professionals on our GDPR Practitioner Certificate, we have now answered their call for a more advanced GDPR qualification to help them enhance their skills and knowledge. 

The new Advanced Certificate in GDPR Practice consists of a series of challenging masterclasses in which delegates will analyse and evaluate thought-provoking case studies designed to help them deconstruct and interpret complex GDPR issues. This will help them gain a deeper understanding of the GDPR and further their ability to navigate the legislation and its application. 

The course is set over three days; approximately one masterclass per month and will take a total of 12 weeks to complete. Delegates should expect to do at least five hours of self-study prior to each masterclass. A practical project will be required to be submitted at the end of the course.  

This course has been designed and will be delivered by our senior associate, Susan Wolf, and our director, Ibrahim Hasan. Susan has over ten years’ experience teaching practitioners on the LLM Information Rights Law at Practice at Northumbria University. She has also designed our very popular FOI Practitioner Certificate course. Ibrahim has been designing and delivering practical data protection courses for over 20 years. 

Ibrahim said: 

“I am really looking forward to teaching this course. I hope to challenge, inspire and provoke delegates into thinking about advanced GDPR concepts and their application.
It will be hard work for the delegates (and the tutor) but worth it! 

These together with a series of practical tasks is sure to enthuse and excite delegates on their way to advancing their skills.” 

This advanced course is exclusively available to those who have completed the Act Now  GDPR Practitioner Certificate as it builds on the knowledge and skills developed in that course. There is an application process for places which are limited to 8 per course.  

The course has a special introductory price of £2,150 plus vat, which is £500 off the RRP. Application forms are available on our website. If you wish to discuss your suitability for this course before applying, please get in touch and we will be happy to help. 

Ticketmaster Fined £1.25m Over Cyber Attack

GDPR fines are like a number 65 bus. You wait for a long time and then three arrive at once. In the space of a month the Information Commissioner’s Office (ICO) has issued three Monetary Penalty Notices. The latest requires Ticketmaster to pay £1.25m following a cyber-attack on its website which compromised millions of customers’ personal information.  

The ICO investigation into this breach found a vulnerability in a third-party chatbot built by Inbenta Technologies, which Ticketmaster had installed on its online payments page. A cyber-attacker was able to use the chatbot to access customer payment details which included names, payment card numbers, expiry dates and CVV numbers. This had the potential to affect 9.4million Ticketmaster customers across Europe including 1.5 million in the UK. 

As a result of the breach, according to the ICO, 60,000 payment cards belonging to Barclays Bank customers had been subjected to known fraud. Another 6000 cards were replaced by Monzo Bank after it suspected fraudulent use. The ICO said these bank and others had warned Ticketmaster of suspected fraud. Despite these warnings it took nine weeks to start monitoring activity on its payments page. 

The ICO found that Ticketmaster failed to: 

  • Assess the risks of using a chat-bot on its payment page 
  • Identify and implement appropriate security measures to negate the risks 
  • Identify the source of suggested fraudulent activity in a timely manner 

James Dipple-Johnstone, Deputy Information Commissioner, said: 

“When customers handed over their personal details, they expected Ticketmaster to look after them. But they did not. 

Ticketmaster should have done more to reduce the risk of a cyber-attack. Its failure to do so meant that millions of people in the UK and Europe were exposed to potential fraud. 

The £1.25milllion fine we’ve issued today will send a message to other organisations that looking after their customers’ personal details safely should be at the top of their agenda.” 

In a statement, Ticketmaster said:  

“Ticketmaster takes fans’ data privacy and trust very seriously. Since Inbenta Technologies was breached in 2018, we have offered our full cooperation to the ICO.
We plan to appeal [against] today’s announcement.” 

Ticketmaster’s appeal will put the ICO’s reasoning and actions, when issuing fines, under judicial scrutiny. This will help GDPR practitioners faced with similar ICO investigations.   

Ticketmaster is also facing civil legal action by thousands of fraud victims. Law firm Keller Lenkner, which represents some of these victims, said: 

“While several banks tried to alert Ticketmaster of potential fraud, it took an unacceptable nine weeks for action to be taken, exposing an estimated 1.5 million UK customers,” said Kingsley Hayes, the firm’s head of cyber-crime.  

Data Protection Officers are encouraged to read the Monetary Penalty Notice as it not only sets out the reasons for the ICO’s conclusion but also the factors it has taken into account in deciding to issue a fine and how it calculated the amount. This fine follows hot on the heels of the British Airways and Marriott fines which also concerned cyber security breaches. (You can read more about the causes of cyber security breaches in our recent blog post.) 

75% of fines issued by the ICO under GDPR relate to cyber security. This is a top regulatory priority for the ICO as well as supervisory authorities across Europe.
Data Protection Officers should place cyber security at the top of their learning and development plan for 2021.  

We have some places available on our forthcoming Cyber Security for DPOs workshop. This and other GDPR developments will be covered in our next online GDPR update workshop.

The Marriott Data Breach Fine

The Information Commissioner’s Office (ICO) has issued a fine to Marriott International Inc for a cyber security breach which saw the personal details of millions of hotel guests being accessed by hackers. The fine does not come as a surprise as it follows a Notice of Intent, issued in July 2018. The amount of £18.4 million though is much lower than the £99 million set out in the notice.  

The Data 

Marriott estimates that 339 million guest records worldwide were affected following a cyber-attack in 2014 on Starwood Hotels and Resorts Worldwide Inc. The attack, from an unknown source, remained undetected until September 2018, by which time the company had been acquired by Marriott.  

The personal data involved differed between individuals but may have included names, email addresses, phone numbers, unencrypted passport numbers, arrival/departure information, guests’ VIP status and loyalty programme membership number. The precise number of people affected is unclear as there may have been multiple records for an individual guest. Seven million guest records related to people in the UK. 

The Cyber Attack 

In 2014, an unknown attacker installed a piece of code known as a ‘web shell’ onto a device in the Starwood system giving them the ability to access and edit the contents of this device remotely. This access was exploited in order to install malware, enabling the attacker to have remote access to the system as a privileged user. As a result, the attacker would have had unrestricted access to the relevant device, and other devices on the network to which that account would have had access. Further tools were installed by the attacker to gather login credentials for additional users within the Starwood network.
With these credentials, the database storing reservation data for Starwood customers was accessed and exported by the attacker. 

The ICO acknowledged that Marriott acted promptly to contact customers and the ICO.
It also acted quickly to mitigate the risk of damage suffered by customers. However it was found to have breached the Security Principle (Article 5(1)(f)) and Article 32 (Security of personal data). The fine only relates to the breaches from 25 May 2018, when GDPR came into effect, although the ICO’s investigation traced the cyber-attack back to 2014. 

Data Protection Officers are encouraged to read the Monetary Penalty Notice as it not only sets out the reasons for the ICO’s conclusion but also the factors it has taken into account in deciding to issue a fine and how it calculated the amount.  

It is also essential that DPOs have a good understanding of cyber security. We have some places available on our Cyber Security for DPOs workshop in November. 

The Information Commissioner, Elizabeth Denham, said: 

“Personal data is precious and businesses have to look after it. Millions of people’s data was affected by Marriott’s failure; thousands contacted a helpline and others may have had to take action to protect their personal data because the company they trusted it with had not.”

“When a business fails to look after customers’ data, the impact is not just a possible fine, what matters most is the public whose data they had a duty to protect.” 

Marriott said in statement:  

“Marriott deeply regrets the incident. Marriott remains committed to the privacy and security of its guests’ information and continues to make significant investments in security measures for its systems. The ICO recognises the steps taken by Marriott following discovery of the incident to promptly inform and protect the interests of its guests.”

Marriott has also said that it does not intend to appeal the fine, but this is not the end of the matter. It is still facing a civil class action in the High Court for compensation on behalf of all those affected by the data breach.  

This is the second highest GDPR fine issued by the ICO. On 16th October British Airways was fined £20 million also for a cyber security breach. (You can read more about the causes of cyber security breaches in our recent blog post.) The first fine was issued in December 2019 to Doorstep Dispensaree Ltd for a for a comparatively small amount of £275,000. 

This and other GDPR developments will be covered in our new online GDPR update workshop. Our next online GDPR Practitioner Certificate is fully booked.We have added more courses. 

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