After 66,806 individual records leaked the JFSC have written directly to 2,477 people

The JFSC claims to hold approximately 1 million separate records in its registry system. In many instances, this includes individuals listed on multiple occasions due to their numerous roles and different relationships with multiple service providers. The JFSC says that only names and addresses were accessed with no link to any specific registered entity or any role held.

Of the 1 million, 66,806 individuals have had their names and addresses accessed [illegally by an unknown actor[s]] via an API in circumstances where this information was not already in the public domain through the registry system.

Of the 66,806, the JFSC has directly written  [see below] to the 2,477 people who were assessed as being impacted [at possible harm] in accordance with the obligations under the Data Protection (Jersey) Law 2018.

The JFSC says they only wrote to those people who we have assessed as falling into a higher risk category.  The risk assessment followed an internationally recognised practice using the framework issued by the European Union Agency for Cyber Security (ENISA) [https://www.enisa.europa.eu/publications/dbn-severity -/- https://www.enisa.europa.eu/publications/dbn-severity/@@download/fullReport  ] and have communicated according to the outcomes of the risk assessment.

In addition to the letter, they communicated more widely with a public statement and provided further information on its website.

• https://www.jerseyfsc.org/registry-system-public-statement/
• https://www.jerseyfsc.org/media/7432/jersey-financial-services-commission-press-release-registry-system-20240307.pdf -/- https://www.jerseyfsc.org/news-and-events/registry-system-statement/

The JFSC says if an induvial has not received a letter and has any concerns or queries:-

• They can contact the JFSC via the dedicated email address query@jerseyfsc.org OR
• They can contact their local service provider or contact us. The JFSC says it will continue to work with service providers, and they will be able to provide more information to their clients directly.

THE JFSC LETTER CONTAINS THE FOLLOWING DETAILS [THE ACTUAL LETTER FOLLOWS BELOW]:-

1. Notification under Article 20 of the Data Protection (Jersey) Law 2018
2. We are writing to make you aware that on 23 January 2024, a vulnerability was detected in the registry system of the Companies Registry at the Jersey Financial Services Commission.
3. We identified that your name and address, which was not meant to be in the public domain, had been accessed.
4. The information which was accessed was limited to your name and address only and did not link you to a specific registered entity or any role held.
5. The fact that the information was held by us may however indicate a link with Jersey.
6. The vulnerability has been closed and your name and address can no longer be accessed in this way.
7. We deeply regret that this occurred.
8. We have undertaken a forensic review with independent technical and cyber security partners.
9. The review established the vulnerability was due to a misconfiguration in our third party supplied registry system, which had been implemented in January 2021.
10. We have been working throughout with the Jersey Office of the Information Commissioner.
11. We are currently undertaking further investigations to determine how this happened and there is more detailed information available via our website jerseyfsc.org.
12. Again, we deeply regret this has occurred.

13. If you have any queries, please contact us via this dedicated email address query@jerseyfsc.org.

JFSC

• https://www.jerseyfsc.org/media/7433/notification-letter-from-the-jfsc.pdf
• https://www.jerseyfsc.org/media/7432/jersey-financial-services-commission-press-release-registry-system-20240307.pdf
• https://www.jerseyfsc.org/news-and-events/registry-system-statement/

Breach Risk Assessment

• https://www.enisa.europa.eu/publications/dbn-severity
• https://www.enisa.europa.eu/publications/dbn-severity/@@download/fullReport