Panasonic UK has signed an Undertaking with the Information Commissioner’s Office (ICO) following the theft of an unencrypted laptop containing personal data relating to people who had attended a hospitality event run by a third party company on Panasonic’s behalf. The incident is a good reminder that your contracts with business associates or vendors need to include your stringent data security and data protection requirements.
The ICO learned on August 8, 2012 that a laptop computer containing the names, home addresses, contact details, dates of birth, nationality, passport details, dietary requirements and emergency contact details of 970 people who had attended hospitality events arranged by Panasonic UK had been stolen from an unlocked hotel room.
The laptop was password protected, but was not encrypted or physically secured in any way.
The hospitality events were being run on Panasonic’s behalf by an unnamed third party company, which was acting as a data processor. There was a contract in place between Panasonic and the third party company, but the data protection provisions were extremely limited. Panasonic has comprehensive policies around data protection which, if followed, would have prevented this breach, however it has been unable to demonstrate that these requirements were ever communicated to the third party company.
It is understood that the passport information was collected on the basis that hotels are legally required to obtain this data for any guests who are non-UK citizens. However, passport data was collected for all guests, regardless of whether they were non-UK citizens or even staying at the hotel, and were then retained, as the third party company and Panasonic felt it might be useful in the event of an emergency.
You can read the undertaking here (pdf).