Data Breaches & Threats

April 1, 2020

Obviously, writing this in the midst of the Coronavirus outbreak, airlines all round the world are suffering huge impacts from the effects of the isolation, quarantine and travel restrictions that are in place.  Cyber security might not be at the top of their agenda, but it’s certainly at the top of Cathay Pacific’s.

The virus, and the global pandemic it has led to, is an unprecedented (the most used word in 2020) event, one that no-one could really have foreseen a few months ago.  We would all forgive companies from suffering disruption and business losses due to a situation so random.

Cyber security issues are predictable

Cyber security is a much more foreseeable risk.  For one thing, there is an accepted wisdom that cyber security breaches are a matter of “when, not if”.  If this is to be believed (and for businesses that handle large volumes of personal data it is probably right), then any given company needs to expect a data loss at some point.

But this should not drive a fatalistic attitude and resignation to a loss occurring.  It has six real implications:

Don’t make it easy for hackers

The most important thing is to try and make it difficult (rather than trivial) for an attacker to gain access to systems and data.  That means not leaving obvious and easily exploitable routes for them to take advantage of; this is often referred to as cyber hygiene; much like the hand washing advice during the Coronavirus outbreak, this is about reducing the chances of infection (or attack) by covering off easily defensible vectors.  Here is one lesson from the Cathay Pacific case:

“The ICO found Cathay Pacific’s systems were entered via a server connected to the internet and malware was installed to harvest data. A catalogue of errors were found during the ICO’s investigation including: back-up files that were not password protected; unpatched internet-facing servers; use of operating systems that were no longer supported by the developer and inadequate anti-virus protection.”

Follow/adopt cyber hygiene standards and guidelines

This really follows from the first point.  There are several standards, all around the world, that encapsulate the core principles of cyber security.  Adopting or following these means that you can align security to the advice on minimum standards from experts – whether those be UK, US, Australian etc.

Steve Eckersley, ICO Director of Investigations, said:

“This breach was particularly concerning given the number of basic security inadequacies across Cathay Pacific’s system, which gave easy access to the hackers. The multiple serious deficiencies we found fell well below the standard expected. At its most basic, the airline failed to satisfy four out of five of the National Cyber Security Centre’s basic Cyber Essentials guidance.”

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Make sure you can detect cyber security attacks/suspicious activity

If a breach does occur, the sooner you know about it and can understand what is happening (or what did happen) the better.  You can avert wider impacts, curtail data losses, notify people early before they fall victim to fraud, and start fixing holes in systems to prevent inward compromise.

Cathay Pacific did detect the breach and employed a firm to help them deal with it.  But the timespan of dates is alarming:

  • The earliest date of the unauthorised access to Cathay Pacific’s systems was 14 October 2014
  • The earliest known date of unauthorised access to personal data was 7 February 2015
  • Cathay Pacific became aware of suspicious activity in March 2018

So yes, the attack was detected, but only after several years.  Yes, YEARS!

Be able to respond when a cyber security breach occurs

If you assume you will have a breach despite having sound controls in place, and despite rigorous monitoring, then knowing what your plan is to deal with it is paramount: having companies, either known or on retainer, for technical consulting or forensic work to address the technical side of a breach; knowing what the plan will be around comms to customers, regulators, markets; having processes to cope with the management of the internal teams and personnel that will be involved.  Businesses need to prepare and test these preparations.

Finally … avoid fines

We might say that we can learn a lot from the Cathay Pacific case.  But sadly, the mistakes they made constitute mostly things that we really already know.  It is yet another case of risks not being properly anticipated and handled.

One goal is to avoid fines.

Cathay Pacific was fined £500,000.  The maximum amount possible under the Data Protection Act which was in force when the breach occurred.  GDPR (now in force) allows for fines up to €20,000 or 4% of global turnover, whichever is greater.

Cathay Pacific’s global revenues are HK$111bn.  This is about £11bn, so 4% of that (assuming the nature of the breach merited the maximum fine again) is £460 million.  Much more than their annual profits of around £243m.

No company can afford not to learn these lessons, and quickly.  Having visibility of the gaps in their cyber defences will enable organisations to prioritise issues for remediation.  At a time of much distraction, using a cyber risk audit tool will provide operational focus and some much needed peace of mind.

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