Over on Salted Hash, Steve Ragan commented on the Alpha Payroll Services phishing incident, first reported on Daily Dot. The premise of his article appears to be that the employee who was fired was a victim, too. Steve writes, in part:
The employee, victimized by the same person who later victimized Alpha Payroll clients, was fired because they believed the email was legitimate.
And we know that — how? The notification letter simply asserts that the employee was terminated. It doesn’t explain why. DataBreaches.net can think of a number of explanations, the first being that yes, the employee became the scapegoat for inadequate security policies and protocols. In that scenario, Alpha Payroll Services fired the employee as a way of being able to demonstrate to their clients that they are very, very upset that an employee did this and it’s an outlier situation.
But there are other possible reasons the employee may have been terminated, some of which Steve does point out:
Was the employee really fired for falling for the phish, or was the employee fired for not following some protocol that required getting approval for emailing W-2 information? And if the employee violated protocols, did the employee have any history of violating protocol in the past?
Was the employee authorized to email W-2 data under any circumstances, and if so, was there any limit to what could be sent that the employee violated? Because this is a personnel matter, DataBreaches.net doubts we will get much clarification on these possibilities.
But while we’re on the topic of clarification, there was no mention in the notification letter of whether the data were sent unencrypted or encrypted. DataBreaches.net assumes, for now, that they were sent unencrypted. Was that a violation of any protocols?
There’s a lot we don’t know yet, and jumping to conclusions that the employee was punished for believing the phishing email was genuine seems a bit premature.
But apart from the issue of fairness, there’s the issue of effectiveness. Does firing an employee make others less susceptible to fall for a phishing attempt for fear of losing their job? FairWarning’s data suggests that firing employees who violate policies and making that known within the workforce reduces employee misbehavior, but would that also apply to falling for a phish? Possibly not, but having clear policies and procedures that involve verification and authorization from up the chain, combined with consequences for failure to follow those procedures might make a difference.
So do we just say, “it’s a mistake, and it could happen to anyone,” or do we say, at some point, “this was a totally avoidable mistake and we will hold the employee accountable?
Steve cites some professionals who feel punishing is not a useful response:
“Any perceived benefit to firing someone over a mistake is offset by the harm done to culture and trust,” said Keith Crawford, an IT Services Manager in Little Rock, Arkansas.
Dan Tentler, founder of Phobos Group, agreed, adding that if organizations punish people who click on malicious emails or fall for a Phishing scam, they create a culture of fear. Instead, organizations should create an economy, by rewarding those who do well during awareness training.
If the FTC investigates this incident under its Section 5 authority, we might find out whether APS really had adequate policies and procedures in place with appropriate technical safeguards.
Hopefully, Alpha Payroll Services will provide additional details, although they have as yet to respond to several inquiries made yesterday.