The second rule of incident response is to follow the plan

From the who-put-the-frying-pan-in-that-fire dept.

Several weeks ago, DataBreaches.net received a complaint concerning a breach involving the Montgomery County Housing Opportunities Commission in Maryland.  It seems that a vendor’s 1099 tax statement had been sent to the wrong recipient.  It was not a particularly unusual breach, but the 1099 had been sent as an unencrypted attachment to an email, so I read on.

It appears matters deteriorated further when a recipient notified the sender of their mistake. The employee then sent out another email with the subject line: CORRECTION Please disregard previous HOC 1099 statement email 4005. The email said:

Please disregard previous 1099 statement email. Corrected 1099 statement has been mailed!

And that’s all it said. No, “Please securely delete the email and notify us that you’ve done so.” Just “please disregard.”

Not satisfied with the incident response, the recipient attempted to call the sender, but the office had closed early due to inclement weather. Indeed, over the next week, the recipient reportedly made several attempts to reach the sender by phone, but never received a call back. And that’s when DataBreaches.net was contacted. The recipient was appalled that a 1099 had been sent via unencrypted email and was concerned that perhaps her 1099 had been sent to others. And she was concerned and angry at the incident response. So angry that she even reached out to the state’s Attorney General to notify him of the incident and to complain.

DataBreaches.net contacted the HOC and spoke with them about the incident. It seems that there was only one person whose 1099 had been erroneously emailed as an attachment, but that 1099 had been sent to 1900 recipients.

“HOC takes this data event very seriously,” a spokesperson stated to DataBreaches.net, explaining that they were in the process of preparing notification letters to everyone who had received the errant 1099. Within 24 hours of the mistake, the spokesperson said, HOC had called and emailed the one affected individual to inform them of the breach and to offer them credit monitoring protection services.

In response to this site’s inquiry, the spokesperson informed me that HOC’s policy is to only use postal mail for 1099’s, and the employee had violated policy by attaching a 1099 to an email. Having failed to comply with policy and having screwed up, the  employee compounded the problem when – on her own initiative and without approval – she sent out the second email to everyone telling them to ignore the email with the incorrect 1099. That “disregard it” email, which infuriated and concerned recipients, was never approved by HOC.

So today’s take-home message: make sure your employees understand that if they screw up, they should not try to handle/correct the breach on their own but should follow your protocols and incident response plan by notifying the appropriate department or supervisor. It’s obvious to those of us who routinely report on breaches that a poor incident response can create  concern, anger, and distrust, but your employees need periodic re-training and reminders of the importance of following the plan.