Data breaches can have a devastating impact on both organisations and data subjects, regardless of the circumstances. After a breach, organisations can face a multitude of issues, including operational disruption, reputation damage, loss of customer trust and regulatory consequences. Though businesses exist that offer data protection as a service, there are still a few core concepts of data breach management best practices that every business should be aware of.
Developing a long-term data breach framework and security strategy is key for any organisation to remain proactive and help mitigate the consequences of a data breach. It’s important for organisations to have a well-rounded approach to data breach management, and the below is a list of five tips to ensure you build an effective response to both cyber and non-cyber incidents.
Cyber vs non-cyber breaches: What’s the difference?
Some of the biggest personal data breaches in recent history have involved cyber-attacks on organisations by malicious third parties. A prime example is Yahoo’s 2013 breach, which involved 3 billion user accounts and was reportedly initiated by a spear-phishing email.
Despite the growing concern of cyber-assisted breaches, the UK’s Information Commissioner’s Office (ICO) posits that non-cyber incidents still account for the highest number of reported breaches in total.
A non-cyber breach could also be referred to as a physical or offline breach. As each name suggests, these happen through physical means, and usually involve some form of human error. Between October and December 2022, 75% of reported UK personal data breaches were classified as non-cyber, with “data emailed to the wrong recipient” cited as the leading cause, accounting for almost one in five incidents.
Data breach management best practices
No matter the organisation size or industry sector, proactive steps need to be taken to prevent a data breach. A robust plan should seek to offer more than mere protection from data breach penalties; it should allow organisations to respond swiftly and, ideally, provide the following advantages:
- Build customer trust
- Preserve brand reputation
- Strengthen partnerships
- Mitigate business disruption
- Give stakeholders peace of mind
By having a robust plan and well-prepared staff, organisations can reduce the impact of potential attacks whilst demonstrating a firm commitment to safeguarding customer information. While larger organisations typically have dedicated teams and support for ongoing data security training, smaller businesses – especially self-employed individuals – can face unique challenges due to a lack of resources.
Businesses in the UK can review the Information Commissioner’s Office (ICO) data protection guides for small organisations. For businesses in the EU, the European Data Protection Board (EDPB) offers a similar guide.
5 tips for an effective data breach response
1. Establish a data breach response team
This can be a single person or a group, who will manage security incidents. Time is of the essence when responding to a breach, and a dedicated response team will play a vital role in minimising impact whilst safeguarding sensitive information. Ideally this person or team should have a firm understanding of data protection considerations, along with any immediate technical mitigation.
2. Review your data processing activities
Understanding how and where your organisation processes personal data (as well as the current security measures) helps identify potential weaknesses and highlights any risks. Regular reviews should be part of your overall plan, as they will enable you to make informed decisions on how best to allocate resources to strengthen your data protection efforts.
Creating an Information Asset Register, conducting data mapping exercises and building a Record of Processing Activities (RoPA) can all help with this process. In addition, undertaking Data Protection Impact Assessments (DPIAs) on high risk processing activities ensures focus on processes where the impact of a data breach may be more significant.
3. Develop a data breach response plan
Though a risk assessment will identify areas of weakness, a robust data breach response plan ensures staff are prepared if a breach does occur.
The specifics of a plan will vary, and can depend upon organisation size, industry sector and specific data handling practices. As a general rule of thumb, however, data breach response plans should include:
- Details of the data breach response team
- Breach identification and internal reporting and logging procedures
- Legal and regulatory procedures
- Breach containment and mitigation
- External support resources
- Breach risk assessment framework
- Post-breach review procedures
- Training and awareness requirements
4. Monitor for suspicious activity and anomalies
This should be a non-exhaustive and ongoing strategy for identifying potential breaches. Early intervention can reduce the damage caused by cyberattacks or personal data security incidents. Regularly updating and monitoring internal processes based on emerging threats and best practices is ideal. Here are some measures to consider:
- Intrusion Detection Systems (IDS) and Intrusion Prevention Systems (IPS)
- Analyse web application logs for suspicious activities such as multiple login failures
- Conduct regular data protection security audits
- Conduct regular data protection refresher courses for all staff
5. Build a data protection culture
A company culture with in-built data protection awareness and knowledge is perhaps one of the primary factors in data breach prevention. As ICO figures show, the highest number of breaches are non-cyber, and of those, sending an email to the wrong recipient is the most probable cause of a data breach. Ongoing staff awareness and training is a core foundation for a strong data protection company culture.
Summary
Data breaches are an unfortunate reality that we must take into consideration, but by having a robust data breach management plan, organisations of all sizes can reduce the impact of potential attacks and demonstrate a commitment to safeguarding information.
By following these five tips and implementing a step-by-step plan, personal information can be safer, data security can be stronger and the trust and confidence of stakeholders and customers can be ensured. Proactive measures and timely responses are the key for effective data breach management, so don’t sleep on this.
