On 16 October 2017, a member of the public found a USB memory stick which had been lost by a HAL employee. The stick, which contained 76 folders and over 1,000 files, was not encrypted or password-protected. The member of the public viewed the material contained on the memory stick at a local library.
Although the amount of personal and sensitive personal data held on the stick comprised a small amount of the total files, of particular concern was a training video which exposed ten individuals’ details including names, dates of birth and passport numbers as well as the details of up to 50 HAL aviation security personnel.
The USB stick was passed to a national newspaper which took copies of the data before giving the stick back to HAL.
Steve Eckersley, the ICO’s director of investigations, said: “Data protection should have been high on Heathrow’s agenda, but our investigation found a catalogue of shortcomings in corporate standards, training and vision that indicated otherwise. Data protection is a Boardroom issue. It’s imperative that businesses have the policies, procedures and training in place to minimise any vulnerabilities around the personal information that has been entrusted to them.”
The ICO investigation found that only 2% of HAL’s 6,500-strong workforce had been trained in data protection.
Other concerns noted during the investigation included the widespread use of removable media in contravention of HAL’s own policies and guidance and ineffective controls preventing personal data from being downloaded to unauthorised or unencrypted media.
HAL carried out a number of remedial actions once it was informed of the breach including reporting the matter to the police, acting to contain the incident and engaging a third party specialist to monitor the Internet and The Dark Web.
Due to the date of the information breach, the case was dealt with under the provisions and maximum penalties of the Data Protection Act 1998 and not the 2018 Act which has now replaced it.