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Data breach – one rule for one, one rule for another! What would happen at your organisation?

28/10/2022

Rishi Sunak's decision to reappoint Suella Braverman six days after she was forced to resign for a security breach is facing new questions about the "multiple breaches of the ministerial code". https://www.theguardian.com/politics/2022/oct/26/suella-braverman-return-after-security-breach-defended-by-james-cleverly

Was she lucky? Would you and your organisation be so fortunate?

Ignoring politics, imagine a different scenario.

  • A recently appointed Board member in a regulated global institution is alleged to have breached internal rules.
  • They  sent confidential and sensitive company documents from a "personal email", inadvertently copying an unintended recipient into the email
  • The Executive self-reported their actions which they say were a "technical infringement".
  • The CEO [HR/COMPLIANCE TEAM] says s/he has "addressed the issue".

What might the Executive or firm be at risk of?

❓An internal investigation?

❓A performance review?

❓Formal disciplinary proceedings?

❓A fitness and propriety re-assessment?

❓A regulatory probe into the firm's data security system and controls?

❓An internal review of usage of work and personal devices?

❓Losing stakeholder and the public trust and confidence?

❓A regulatory[s] fine? [FCA/ICO/OTHER?]

❓The sack following an act of gross conduct charge?

OR

❓Could this have been avoided by more attention paid to the particular needs of the new executive – induction training?

Cyber-security training and culture is important for everyone

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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.  

news disclaimer -

As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.