Tag: security

AI and Cybersecurity: Why Trust Is the New Battleground 

Artificial intelligence is reshaping cybersecurity. Recent examples of AI behaving in unexpected ways have added urgency to the debate about how these systems should be controlled and where responsibility lies. The first such case involved ChatGPT-maker OpenAI acknowledging that its model had hacked the Hugging Face website. Anthropic and Meta have also reported similar cases. 

In a recent episode of the Guardians of Data podcast, host Ibrahim Hasan spoke with Caroline Wong, cybersecurity expert and author of The AI Cybersecurity Handbook, about how AI is impacting cyber security; from accelerating attacks and strengthening defences to changing the skills cyber professionals need.  

Lowering the barrier for attackers 

AI is making sophisticated cyber hacking capability available to people with far less training. Tasks once requiring extensive manual effort can now be automated or guided by readily available tools. Caroline explained that someone with only “ten to one hundred hours” of experience may now conduct activities that previously demanded “a thousand or ten thousand hours” of expertise. 

Reconnaissance is a good example of this. Attackers can rapidly gather public information about an individual or organisation, including writing style, vocabulary, voice and professional relationships. A task that once took an hour may now take minutes. This brings privacy, data protection and cybersecurity closer together: organisations must consider what information is public, who can access it and how easily AI can turn scattered data into actionable intelligence. 

Social engineering becomes more convincing 

Social engineering targets human behaviour rather than a technical flaw. AI enables criminals to generate fluent, personalised messages in any language and adopt a credible persona; perhaps a senior executive, a worried relativeor a hurried delivery worker. Old advice about spotting poor grammar or suspicious graphics is no longer enough. Deepfake audio and video can imitate familiar people so convincingly that seeing or hearing is no longer believing. 

Modern scams exploit excitement, pressure and trust, and their quality makes occasional mistakes increasingly understandable. Caroline’s practical test for spotting deepfakes and scams is simple: Did I expect this message? Is it asking me to act, disclose information or transfer money? If anything feels unusual or urgent, verify the request through a separate channel. A call apparently from a relative, for example, should be checked by sending a message using trusted contact details; not by relying on the communication that triggered suspicion. As Caroline says, “You’ve got to pay attention to your nervous system, and you’ve got to learn how to pause.” 

Malware at machine speed 

AI is also changing malware. Traditional cyber defences often rely on signatures: recognisable technical characteristics used to identify and block malicious code.
But attackers can now create many variants quickly, including malware that changes inside a system. As Caroline puts it, “Rule-based detection can’t keep pace with
AI-generated novelty.” 

Defenders therefore need to focus increasingly on behaviour rather than appearance. The challenge is to identify what software is doing, such as unusual access or suspicious movement across a network, rather than relying on a fixed fingerprint that may disappear with the next iteration. 

AI gives defenders an advantage too 

The discussion with Caroline was not all doom and gloom. AI can help defenders not just attackers. It can accelerate repetitive security work, including third-party vendor risk assessments, customer due-diligence questionnaires and information gathering. Automating coordination and routine analysis can free security professionals to spend more time on judgement, governance and strategic risk management. 

However, Caroline cautioned against seeing AI as a product that can simply be purchased to make problems disappear. “AI is not a silver bullet,” she stressed. It remains error-prone, requires experimentation and does not remove the need for human communication or sound security basics. Budget disparities also remain: a small organisation cannot deploy the same resources as a multinational. Even AI usage itself carries ongoing token, operational and environmental costs that leaders must assess over time. 

The vulnerability-fixing gap 

The podcast also explored advanced AI systems capable of finding and exploiting software vulnerabilities far faster than humans. Caroline’s key concern is an emerging imbalance: discovery can be compressed from months or days into minutes, while remediation has not accelerated at the same rate. “We now have a significantly improved approach for finding vulnerabilities, but we don’t yet have an equally speedy approach for fixing vulnerabilities,” she warned. 

She was sceptical that banning powerful AI tools, such as Mythos, would provide a durable solution. Equivalent models are likely to emerge elsewhere and prohibition may concentrate access among a privileged few rather than eliminate the capability. The stronger response is therefore governance, controlled access, coordinated disclosure and investment in faster remediation. 

Trust, judgement and the future workforce 

Ultimately, trust is the new battleground. AI-generated voices, faces and “digital twins” complicate how people establish authenticity. Yet Caroline does not foresee cybersecurity becoming a fully automated discipline. Her five-year vision is a blended workplace in which humans communicate with both human and agentic AI colleagues. The crucial question will be where human oversight is required and at what level of abstraction. 

For professionals in cybersecurity, privacy and data protection, Caroline’s advice is to remain curious, learn quickly and gain hands-on experience with AI. Technical knowledge matters, but so do communication, judgement and the ability to work across organisational boundaries 

The enduring takeaway from this podcast is that AI will amplify capability, not abolish human responsibility. Organisations that combine useful automation with strong governance, verification and experienced judgement will be best placed to manage what comes next. As Caroline observed, “Judgment and opinion and experience are things that the machines cannot take away from us.” 

Listen to the full episode with Caroline Wong here.  

We have two workshops coming up (How to Increase Cyber Security in your Organisation and Cyber Security for DPOs) which are ideal for organisations who wish to upskill their employees about cyber security.

New Podcast: The Impact of AI on Cybersecurity  

“Today, it’s actually very, very easy for attackers to take a piece of malware and effectively launch one hundred different versions all at once.” 

Caroline Wong, Author and Cybersecurity Expert 

Episode 11 of the Guardians of Data Podcast is out now. In this episode we discuss how AI is reshaping trust, identity, cybersecurity, and organisational accountability.  

In recent weeks, governments, regulators and cyber security professionals have been gripped by the emergence of Mythos, the powerful AI model developed by Anthropic. Touted as capable of identifying software vulnerabilities at a level that rivals some of the world’s most skilled human researchers, the model has generated excitement, concern and intense debate.   

Against this backdrop, our guest on this podcast is an internationally renowned cybersecurity leader, educator and technology strategist. Caroline Wong is Chief Strategy Officer at Axari and the author of The AI Cybersecurity Handbook.  

In this conversation, Caroline explains how cybercriminals are using AI to launch sophisticate cyber-attacks. We also discuss how organisations can use the same technology to strengthen their cyber defences.  

But this conversation goes beyond the technical. We discuss why trust is becoming the central battleground in cybersecurity, how deepfakes and AI-generated content are reshaping the way we verify information, and why human judgment remains critical despite rapid advances in automation. We also take a closer look at Mythos itself and what it means for the future of cybersecurity.  

Whether you’re a privacy practitioner, cybersecurity professional or simply interested in understanding how AI is transforming the digital world around us, this is a conversation packed with practical insights and thought-provoking ideas.   

Listen on your preferred platform via our podcast page, or download the episode directly.

This podcast is sponsored by Phaselaw – a purpose-built solution for document disclosures, like subject access requests and FOI requests. Instead of redacting PDFs one by one, or forcing litigation software to do a job it wasn’t designed for, with Phaselaw you get collection, review, and redaction in one workflow. Teams across the World are using it to cut response times from weeks to days. 

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Head to https://www.phase.law/guardians to claim your free trial.  

Previous episodes of the Guardians of Data podcast have featured Tahir Latif talking about responsible AI deployment, Jen Persson, a privacy campaigner, explaining the privacy implications of the Government’s new plans for children’s data, Naomi Mathews and Ibrahim Hasan explaining the law on filming people in public for social media and Olu Odeniyi analysing recent cyber breaches and discussing the lessons learnt.

Cyber Security and Resilience Bill in Parliament 

On 12th November 2025, the Government introduced the Cyber Security and Resilience (Network and Information Systems) Bill in the House of Commons. This is an important development in the evolution of the UK’s cyber security regulation. The Bill is currently at the Committee stage.

The Bill was trailed in the King’s Speech of July 2024, and was followed by the Government publishing its Cyber security and resilience policy statement. The Bill is designed to update the existing Network and Information Systems Regulations 2018 to raise cyber resilience across key parts of the economy, and to give government and regulators more agile powers to respond to evolving threats. Amongst other things, it will expand cyber security regulation to cover more digital services and supply chains, and mandate increased incident reporting to improve the government’s response to cyber-attacks including where a company has been held to ransom. 

The Bill imposes new maximum penalties similar to GDPR levels. For more serious breaches, the maximum penalty is up to £17 million, or 4% of a regulated entity’s worldwide turnover, whichever is higher. For other breaches, the maximum penalty is up to £10 million, or 2% of a regulated entity’s worldwide turnover, whichever is higher. 

Key Provisions 

Expanded Regulatory Scope: The Bill will broaden the range of organisations and sectors under regulatory oversight, extending beyond essential services and digital providers to include a wider array of entities integral to national infrastructure. ​ 

Enhanced Regulatory Powers: Regulators will receive increased authority to ensure compliance with cybersecurity standards, including proactive investigation capabilities and mechanisms for cost recovery to support their activities. ​ 

Mandatory Incident Reporting: The Bill mandates comprehensive reporting of cyber incidents, notably ransomware attacks, to improve national threat assessment and response strategies. ​ 

Supply Chain Security: The Bill introduces measures to strengthen supply chain security, granting regulators the power to designate ‘Critical Suppliers’ whose services are integral to public sector operations. ​ 

Regulatory Oversight: The Information Commissioner’s Office will gain greater authority to investigate and enforce compliance among digital service providers, including those that supply technology to the public sector. ​ The ICO recently published its response to the Bill. 

For a detailed analysis of the Bill, read this article by law firm Clifford Chance. 

We have two workshops coming up (How to Increase Cyber Security in your Organisation and Cyber Security for DPOs) which are ideal for organisations who wish to upskill their employees about cyber security. See also our Managing Personal Data Breaches Workshop.

Retail Under Siege Through AI Enabled Cyber Attacks 

The UK retail sector has come under siege in 2025, with an unprecedented wave of cyber attacks. After the Ticketmaster breach in 2024 where millions of users were affected, one would assume retailers had taken note. However, From Marks & Spencer to Louis Vuitton, companies large and small are grappling with relentless, tech-enhanced intrusions that threaten customer trust and digital resilience. It’s almost a daily occurrence these days receiving an email from a company apologising for a data breach. There also seems to be no retailer safe regardless of their size or stature. Sometimes it is a retailer that you may not have even shopped with for a number of years at which point I’m sure you must be thinking, ‘What’s their data retention policy?’ 
 
Below we take a look at some of the major breaches and attacks of 2025 and what you can do to protect your information online. 

High-Profile Retail Cyberattacks of 2025 

Here’s a snapshot of the most disruptive recent cyber incidents: 

Company Date Attack Type Impact & Highlights 
Louis Vuitton UK July 2025 Data breach Customer contact details & purchase history stolen; phishing scams followed 
Marks & Spencer April 2025 Ransomware £3.8M/day in lost revenue; £700M market value wiped; credential theft via vendor 
Harrods May 2025 Attempted breach Real-time containment; no confirmed data loss but serious operational disruption 
Co-op UK May 2025 Ransomware Customer data compromised; back-office systems disabled 
Peter Green Chilled May 2025 Ransomware Disrupted cold-chain deliveries to Tesco, Aldi, Waitrose 
Victoria’s Secret Spring 2025 Web attack E-commerce platform outage during peak shopping period 

These incidents underscore one clear truth: cybercrime is evolving, and no retailer, no matter its size or prestige, is immune. What is worrying is, companies with infinite resources are still extremely vulnerable. 

The Role of AI  

In many of these data breaches, AI was used by hackers to accelerate and deepen the damage. Their tactics included: 

  • Hyper-Personalised Phishing: AI-generated messages mimicked trusted communications, referencing recent purchases to trick recipients. Louis Vuitton customers received convincing fake discount offers. 
  • Credential Cracking and MFA Bypass: AI automated brute-force login attacks, while adversary-in-the-middle techniques stole session tokens to sidestep multi-factor authentication. 
  • Network Reconnaissance: Malicious bots used AI to scan retail systems, identify vulnerabilities, and map out supply chains for deeper impact. 
  • Autonomous Ransomware: Sophisticated strains like DragonForce adapted in real time to avoid detection and self-propagate through connected systems. 
  • Voice Phishing (Vishing): AI-generated voices impersonated IT staff to deceive employees into disclosing access credentials; a tactic especially potent in luxury retail. 

AI has supercharged cybercrime, making attacks faster, more targeted, and far harder to detect. With the emergence of (RaaS) ransomware as a service and (DLS) there is now a marketplace for our data that is much more accessible. 

How Consumers Can Protect Their Data 

While companies bear the financial burden of breaches, consumers often suffer the most; through stolen data, financial fraud, and disrupted services. Lessons for consumers include: 

  • Even luxury brands are vulnerable – don’t assume prestige equals protection. 
  • Cyberattacks are increasingly tailored based on what you buy, how often you shop, and where you live. 
  • Supply chains and vendor access are weak points; your data might be exposed even if the retailer itself isn’t directly breached. 

Whether you shop in-store or online, these simple steps can dramatically improve the security of your personal data: 

Digital Defence 

  • Use Strong, Unique Passwords: A password manager can help you avoid reuse and weak combinations. 
  • Enable Multi-Factor Authentication: Critical for accounts tied to payments or personal information. 
  • Monitor Your Financial Activity: Check bank statements and credit reports for irregularities. Set up alerts where possible. 
  • Be Phishing-Aware: Always verify communications by visiting the retailer’s official website. Don’t click suspicious links or download unexpected attachments. 
  • Don’t Save Your Payment Data: If you can avoid saving your payment/address details with a retailer online then always avoid.  

Data Discipline 

  • Limit the Personal Data You Share: Don’t offer extra details to loyalty schemes or retailers unless absolutely necessary. 
  • Freeze Your Credit (If Breached): Prevent identity thieves from opening new accounts using your stolen details. 

Payment Hygiene 

  • Use Credit Cards Online: They offer better fraud protection and don’t expose your actual bank balance. In addition, you have certain buyer protections when buying on credit card. 
  • Avoid Public Wi-Fi for Shopping: Use a VPN or shop from secure, private networks. 

The digital age has made shopping easier; but also riskier. Cybersecurity now requires a partnership between retailers and consumers. Companies must implement
zero-trust architectures. AI-powered threat detection and employee cyber-awareness training. Meanwhile, consumers should stay informed, cautious, and quick to respond when their personal data is at risk. 

According to Stanford University’s recent study, human error accounted for 88% of data breaches and a recent Accenture study found that there has been a 97% increase in cyber threats since the start of the Russia/Ukraine war.  
 
We have two workshops coming up (How to Increase Cyber Security in your Organisation and Cyber Security for DPOs) which are ideal for organisations who wish to upskill their employees about cyber security. 

The MoD Afghan Data Breach: Could the Information Commissioner have done more? 

On Tuesday, the High Court lifted a superinjunction that prevented scrutiny of one of the most serious personal data breaches involving a UK Government department. In February 2022, a Ministry of Defence (MoD) official mistakenly emailed a spreadsheet containing personal details of over 18,000 Afghan nationals who had applied to move to the UK under the Afghan Relocations and Assistance Policy (ARAP).  

The breach was only discovered in August 2023, when excerpts of the data appeared on Facebook. By then, the damage was done. A new resettlement scheme for those on the leaked list was set up and has seen 4,500 Afghans arrive in the UK so far. The Afghan Relocation Route has cost £400m so far, and the Government has said it is expected to cost a further £450m. Interesting that that the High Court in May 2024 heard it could cost “several billions”. 

Shockingly, people whose details were leaked were only informed on Tuesday. A review of the incident carried out on behalf of the MoD found it was “highly unlikely” an individual would have been targeted solely because of the leaked data, which “may not have spread nearly as widely as initially feared”. On Wednesday though, the Defence Secretary said he was “unable to say for sure” whether anyone had been killed as a result of the data breach. The daughter of an Afghan translator whose details were leaked told the BBC that her whole family “panicked”.  

“No one knows where the data has been sent to – it could be sent to the Taliban, they could have their hands on it,” she said. Her grandmother, who is still in Afghanistan, is “completely vulnerable”, she added. 

This is not the first time the MoD has mishandled Afghan data. In December 2023, it was fined £350,000  for disclosing details of people seeking relocation to the UK shortly after the Taliban took control of Afghanistan in 2021. The MoD sent an email to a distribution list of Afghan nationals eligible for evacuation using the ‘To’ field, with personal information relating to 245 people being inadvertently disclosed. The email addresses could be seen by all recipients, with 55 people having thumbnail pictures on their email profiles.  
Two people ‘replied all’ to the entire list of recipients, with one of them providing their location.  

ICO’s Response 

Despite the scale and sensitivity of the latest MoD data breach, the Information Commissioner’s Office (ICO) has decided not to take any regulatory action; no, not even a reprimand! In its press release, the ICO praised the MoD’s internal investigation and mitigation efforts, stating that “no further regulatory action is required at this time”. 

Compare this case to the data breach involving the Police Service of Northern Ireland (PSNI). Last year, the ICO fined the PSNI £750,000 after staff mistakenly divulged the surnames of more than 9,483 PSNI officers and staff, their initials and other data in response to a Freedom of Information (FoI) request. The request, via the What Do They Know.Com website, had asked the PSNI for a breakdown of all staff rank and grades. But as well as publishing a table containing the number of people holding positions such as constable, a spreadsheet was included. The information was published on the WDTK website for more than two hours, leaving many fearing for their safety. 

In September las year it was announced that a mediation process involving the PSNI is to take place to attempt to agree the amount of damages to be paid to up to 7,000 staff impacted by the data breach. The final bill could be as much as £240m, according to previous reports. Compare that with the impact and cost of the latest MoD data breach. 

Other ICO enforcement actions in the past few years for security failures include: 

  • Cabinet Office (2020): Fined £500,000 for publishing New Year Honours list online. Cause? Spreadsheet error. 
  • HIV Scotland (2021): Fined £10,000 when it sent an email to 105 people living with HIV. All the email addresses were visible to all recipients, and 65 of the addresses identified people by name. From the personal data disclosed, an assumption could be made about individuals’ HIV status or risk.   
  • Mermaids (2021): Fined £25,000 for failing to implement an appropriate level of security to its internal email systems, which resulted in documents or emails containing personal data being searchable and viewable online by third parties through internet search engine results.  

In the MoD case, the ICO claims it considered the “critical need to share data urgently” and the MoD’s “steps to protect those most affected”. But urgency wasn’t the issue; it was negligence. The breach occurred during routine verification, not a crisis. Even more concerning, the ICO’s own guidance states that breaches involving unauthorised disclosure of sensitive data, especially where lives are at risk, should trigger enforcement action. 

This lack of action by the ICO raises serious questions about the ICO’s independence and willingness to challenge government departments. Even if it felt a fine was not appropriate, a report to Parliament (under Section 139(3) of Data Protection Act 2018) would have highlighted the seriousness of the issues raised and consequently allowed MP’s to scrutinise the MoD’s actions.  

This breach is a national scandal; not just for its scale, but for the lack of transparency, accountability, and regulatory action. If the UK is serious about data protection, it must demand more from its regulator. Otherwise, the next breach may be even worse and just as quietly buried. 

Yesterday, the Commons Defence Committee confirmed it would launch its own inquiry, and Dame Chi Onwurah, chair of the Commons Committee for Science Innovation and Technology, said that it is writing to the Information Commissioner pushing for an investigation. Watch this space! 

STOP PRESS: This afternoon the BBC reports that the data breach was much worse than previously thought: it contained personal details of more than 100 British officials including those whose identities are most closely guarded – special forces and spies. Is an ICO u turn incoming?

We have two workshops coming up (How to Increase Cyber Security in your Organisation and Cyber Security for DPOs) which are ideal for organisations who wish to upskill their employees about cyber security.

ICO Reprimands Law Firm for GDPR Breach 

Last week, the Information Commissioner’s Office (ICO) issued a reprimand to a Hampshire law firm following a data breach that affected over 8,000 individuals. 

Levales Solicitors LLP, a law firm specialising in criminal and military law, was reprimanded after an unknown cyber-attacker gained access to its secure cloud-based server.
The attacker used legitimate credentials to infiltrate the system, eventually leaking personal data on the dark web including  

  • Name, Address, Date of Birth
  • National Insurance Numbers 
  • Criminal data, including allegations, investigations, and prosecutions 
  • Details of complainants, victims (including children), and legally privileged information 
  • Prisoner Numbers, Health Status, and previous convictions 

A total of 8,234 data subjects were affected by the breach, with 863 individuals considered at high risk of harm due to the nature of the sensitive data involved.
This included data related to serious offences such as murder, terrorism, sexual offences, and matters involving vulnerable adults or children. 

The ICO’s reprimand focuses on the infringement of two key articles of the UK GDPR: 

  • Article 32(1)(b): The need to ensure ongoing confidentiality, integrity, availability, and resilience of processing systems. 
  • Article 32(1)(d): The requirement to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks involved. 

What Went Wrong? 

The ICO found that Levales Solicitors LLP failed to ensure the ongoing confidentiality of its systems, making it vulnerable to the cyberattack (Article 32(1)(b)). Several critical issues were identified by the ICO: 

No Multi-Factor Authentication (MFA): MFA, a basic yet crucial security measure, was not in place for the domain account affected by the breach. This allowed the attacker to access the system using stolen credentials. Despite its simplicity, MFA is considered one of the most effective ways to prevent unauthorised access. 

Weak Password Management: Levales had no clear password policy in place at the time of the breach, relying instead on computer prompts to guide password strength and updates. The lack of a formalised approach to password management further exposed the firm’s systems to risk. 

Unknown Point of Compromise: Levales Solicitors LLP was unable to determine how the attacker obtained the credentials, demonstrating a lack of sufficient oversight into how the breach occurred. 

The ICO also criticised Levales for failing to implement appropriate technical and organisational security measures (Article 32(1)(d)). Notably: 

Outsourced IT Management: Levales had outsourced its IT management but had not reviewed or updated security measures since 2012. The firm was unaware of basic security processes, such as detection, prevention, and monitoring systems in place with their third-party provider. 

Inadequate Contract Reviews: The ICO expects that organisations outsourcing services conduct regular reviews to ensure security measures are up-to-date and appropriate. Levales had not reassessed their IT service contract since signing it, leaving potential vulnerabilities unchecked. 

The National Cyber Security Centre (NCSC) provides a 12-step guide on supply chain security, which advises that vulnerabilities within contracts can be easily exploited if the responsibilities and security measures between the provider and controller are not clearly defined or regularly reviewed. 

Despite these significant failings, the ICO did acknowledge that Levales had taken remedial steps following the breach, including: 

  • Introducing Multi-Factor Authentication (MFA) for all user accounts. 
  • Updating service contracts with third-party providers to ensure better security. 
  • Conducting a comprehensive review of existing systems and prioritising firewall upgrades. 

After taking all factors into consideration, including the remedial steps taken by Levales, the ICO decided to issue a formal reprimand under Article 58(2)(b) of the UK GDPR.  

Key Takeaways  

The decision reflects the seriousness of the firm’s failings in securing sensitive personal data and underscores the importance of robust data security practices for all organisations, particularly those handling highly sensitive information. All businesses are advised to take the following steps to comply with GDPR requirements: 

  • Implement Multi-Factor Authentication (MFA) for all accounts to reduce the risk of credential theft. 
  • Ensure that password policies are robust and regularly reviewed. 
  • Review contracts with third-party service providers to confirm that appropriate security measures are in place and understood by both parties. 
  • Regularly assess and update security systems to ensure they remain effective against evolving cyber threats. 
  • Document and monitor the security measures in place, ensuring that they are tailored to the specific risks associated with the data being processed. 

This is not the first time that a law firm has been found to be in breach of GDPR.
In 2022 fined Tuckers Solicitors LLP £98,000 for a data breach of GDPR.
The fine followed a ransomware attack on the firm’s IT systems which saw the attacker had encrypting 972,191 files, of which 24,712 related to court bundles.  60 of those were exfiltrated by the attacker and released on the dark web.  Some of the files included Special Category Data. Tuckers reported the breach to the ICO as well as affected individuals through various means including social media.  

The ICO concluded that were a number of areas in which Tuckers had failed to comply with, and to demonstrate that it complied, with the Security Principle. Their technical and organisational measures were, over the relevant period, inadequate.
Amongst other things the lack of Multi-Factor Authentication was highlighted by the ICO. 

Data security is a cornerstone of GDPR compliance, and reprimand involving Levales Solicitors LLP highlights the potential consequences of not taking proper precautions. Organisations should treat this as a wake-up call to evaluate and strengthen their own data protection measures, particularly in areas where sensitive or high-risk data is involved. 

We have two workshops coming up (How to Increase Cyber Security in your Organisation and Cyber Security for DPOs) which are ideal for organisations who wish to up skill their employees about cyber security. See also our Managing Personal Data Breaches Workshop. 

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RAC Employees Sentenced for Selling Personal Data 

On 8th October 2024, two former RAC employees were sentenced for unlawfully copying and selling over 29,500 lines of personal information.  

The two former employees worked as customer service specialists at the RAC’s call centre in Stretford. Their unlawful conduct was discovered by the RAC after it installed new security monitoring software. The software showed employee one of them had unlawfully accessed and copied personal information relating to people involved in road traffic accidents. A subsequent search of  employee one’s mobile phone showed the information was shared in a WhatsApp chat with employee two. Messages indicated that a third party was paying for the information. 

At a hearing at Minshull Street Crown Court on 8 October 2024, both former employees were sentenced to 6 month prison sentences, suspended for 18 months, and each were ordered to complete 150 hours of unpaid work. Both defendants had previously pleaded guilty to offences under the Computer Misuse Act 1990 and Data Protection Act 2018. Prosecution costs will be considered at a Proceeds of Crime hearing listed for 5 March 2025. 

Section 55 of the old Data Protection Act 1998 can still be used to bring a prosecution where an offence pre-dates the current Section 170 of the Data Protection Act 2018, as in the above case. It is interesting to note that the ICO also cited section 1 of the Computer Misuse Act 1990 which carries a maximum of 2 years imprisonment on indictment.   

In June 2023, the Information Commissioner’s Office (ICO) disclosed that, since 1st June 2018, 92 cases involving Section 170 offences were investigated by its Criminal Investigations Team. The most recent of these was in September 2024, when an employee pleaded guilty to retaining and selling 3,600 pieces of customer records obtained from the car leasing company he worked for. He was ordered to pay a fine of £1,200 and £300 costs. 

It is important to note that, if a disgruntled or rogue employee commits a data protection offence, the employer may also be liable for the consequences. More on our recent blog on this subject. 

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Transport for London Cyber Attack 

Transport for London (TfL) is currently dealing with a cyber attack that has targeted its computer systems. Sources within TfL have revealed that staff have been encouraged to work from home where possible, as the attack primarily affects the transport provider’s back-office systems at its corporate headquarters. TfL is collaborating closely with the National Crime Agency and the National Cyber Security Centre to respond to the incident. 

Shashi Verma, TfL’s Chief Technology Officer, said: 

“We have implemented several measures to address an ongoing cybersecurity incident within our internal systems. The security of our systems and customer data is of utmost importance, and we are continuously assessing the situation throughout this incident.”  

Mr Verma emphasised that, although a complete assessment is still underway, there is no current evidence of customer data being compromised. If it turns out that any personal data has been compromised, whether employee or customer data,  of course TfL will need to consider reporting the matter to the Information Commissioner’s Office (ICO) as a personal data breach under Article 33 of the UK GDPR. As a statutory body, failure to do so could lead to TfL being fined up to £8.7 million. If the ICO investigates and finds a breach of the DP Principles (e.g. security) this could rise to £17.5 million. 

Back in the day major cyber incidents involving personal data were sure to be the subject of an ICO fine. In 2018, British Airways and  Marriott International were fined £20 million and  £18.4 million respectively. More recently the ICO has issued more reprimands in line with its policy on public sector enforcement. It recently issued a reprimand to the Electoral Commission following the discovery that unspecified “hostile actors” had managed to gain access to copies of the electoral registers, from August 2021. On 26th June 2024, the ICO announced that it will now review the two-year trial before making a decision on the public sector approach in the autumn.  

This is not the first cyber attack on a major public service provider in the capital.  Last month the ICO announced that it had issued a GDPR Notice of Intent of £6.09 million to an NHS IT supplier. This comes after its findings that the company failed to adequately protect the personal data of 82,946 individuals in breach of Article 32 of the UK GDPR.  As a key IT and software provider for the NHS and other healthcare organisations across the country, Advanced often holds role of Data Processor for many of its clients. The breach in question occurred during a ransomware attack in August 2022. Hackers exploited a vulnerability through a customer account that lacked multi-factor authentication, gaining access to multiple health and care systems operated by Advanced. The compromised data included phone numbers, medical records, and even details on how to access the homes of 890 individuals receiving at-home care. 

We have two workshops coming up (How to Increase Cyber Security in your Organisation and Cyber Security for DPOs) which are ideal for organisations who wish to up skill their employees about cyber security. See also our Managing Personal Data Breaches Workshop. 

London Hospitals Hit By Major Cyber Attack

The Independent reports this afternoon that two major London hospital trusts have had to cancel all non-emergency operations and blood tests due to a significant cyber attack. Both King’s College Hospital Foundation Trust and Guy’s and St Thomas’ Hospitals Foundation Trusts have seen their pathology systems compromised by malware.

Synnovis, the service provider responsible for blood tests, swabs, bowel tests, and other critical services for these hospitals, was targeted in this attack. The impact is widespread, affecting NHS patients across six London boroughs. The affected hospitals include Guy’s Hospital, which operates the Evelina children’s hospital, Harefield Hospital, King’s College Hospital, Princess Royal University Hospital, Royal Brompton Hospital, and St Thomas’ Hospital.

On Monday, Synnovis confirmed the severity of the attack, which has disrupted services for tens of thousands of patients. As the hospitals work to mitigate the damage and restore services, the incident highlights the vulnerability of healthcare systems to cyber threats and the far-reaching consequences such attacks can have on patient care.

The Information Commissioner’s Office is yet to comment. 

We have two workshops coming up in September (Introduction to Cyber Security and Cyber Security for DPOs) which are ideal for organisations who wish to up skill their employees about data security. See also our Managing Personal Data Breaches Workshop.  

MOD Payroll Data Hacked

The government has raised concerns about a cyber attack on an armed forces payroll system, with indications pointing towards China as the suspected perpetrator. Defence Secretary Grant Shapps is set to address Members of Parliament today, although he is not expected to directly attribute blame to any specific party.
Instead, he is likely to emphasise the threat posed by cyber espionage activities conducted by hostile states.

The affected system, utilised by the Ministry of Defence (MoD), contains sensitive information such as names and bank details of armed forces personnel, with a few instances where personal addresses may also be included. Managed by an external contractor, the breach came to light in recent days, prompting government action, although there’s no evidence suggesting data was actually extracted from the system.

The investigation into the breach is still in its early stages and attributing responsibility can be a complex and time-consuming process. While official accusations may not be made immediately, suspicions are reportedly pointing towards China, given its history of targeting similar datasets.

Those impacted by the breach will receive communication from the government regarding the incident, with a focus on addressing potential fraud risks rather than immediate personal safety concerns.

At the time of writing it is not clear if the MoD has reported the data breach to the ICO as required by the UK GDPR. In December 2023, the MoD was fined £350,000 for disclosing personal information of people seeking relocation to the UK shortly after the Taliban took control of Afghanistan in 2021. 

We have two workshops coming up (How to Increase Cyber Security and Cyber Security for DPOs) which are ideal for organisations who wish to upskill their employees about data security.