International health insurance business Bupa has been fined £175,000 after a staffer tried to sell more than half a million customers' personal information on the dark web.
The miscreant was able to access Bupa's CRM system SWAN, which holds records on 1.5 million people, generate and send bulk data reports on 547,000 Bupa Global customers to his personal email account.
The information – which included names, dates of birth, email addresses, nationalities and administrative info on the policy, but not medical details – was then found for sale on AlphaBay Market before it was shut down last year. The ad read:
DB [database] full of 500k+ Medically insured persons info from a well-known international blue chip Medical Insurance Company. Data lists 122 countries with info per person consisting of Full name, Gender, DOB, Email Address plus Membership Details excluding CC Details.
The staffer was one of 20 users with unfettered access to search, view and download data onto personal drives from SWAN, and worked at in the Partnership Advisory Team at Bupa Global's Brighton Office.
In June last year, an external partner spotted the data was for sale on a site accessible via ToR, and reported it to Bupa, who sacked the culprit and 'fessed up to the UK's privacy watchdog.
After investigating, the Information Commissioner's Office fined the insurance company £175,000 for systemic failures to protect personal data, which is a breach of data protection laws.
Bupa should have had a system that flagged up unusual activity like bulk data extraction, but it was defective.
According to the ICO's report (PDF), because Bupa failed to routinely monitor the SWAN activity log it didn't notice a defect that resulted in certain reports being logged incorrectly or not at all.
It also criticised the fact some staff could not only run and generate bulk data reports but also download or export them to separate applications, including file-sharing platforms and social media (yes, really).
In this case, the employee – who took the information between January and March 2017 – attached the data to emails in zip files and Excel files.
The ICO noted that the reason the staff had these abilities was in order to respond quickly to broker enquiries, which it said "illustrates the tension between customer satisfaction and information security".
Bupa failed to undertake adequate risk assessment of the abilities granted to these users, or to the 1,351 others who could access customer data.
"That was a material organisational inadequacy, given the volume of personal data accessible through SWAN, the number of data subjects involved, the number of individuals with access to SWAN, and the ease with which they could access it," the ICO said.
The watchdog also noted that the firm's domestic CRM system, SWIFT, which contains 2.3 million records, doesn't allow reports to be generated directly from the system by Intermediary Team members, and has a functioning system for recording accurate logs.
Bupa has until 29 October to pay up, and if it does so by 26 October the penalty will be reduced by 20 per cent. ®