Back in January, I noted that Lush Cosmetics had been hacked and customer data acquired and misused. The company reportedly only became aware of the breach after receiving reports from almost 100 customers who had become victims of card fraud. Today, the UK’s Information Commissioner’s Office revealed that Lush was required to sign an undertaking following the breach. From the undertaking:
The Information Commissioner (the ‘Commissioner’) was provided with a report by the data controller that their website had been subject to a malicious intrusion, potentially compromising approximately 5000 customer credit card records.
Whilst the data controller did have a number of security measures in place, these were not sufficient to prevent a determined attack on the systems. The systems in use at the time also failed to fully log system activity, rendering the precise nature of the attack difficult to assess. It has been noted that the data controller has since taken prompt and substantial remedial action, re-establishing an appropriate standard of security to the systems and minimising the opportunity for a repeat of such an incident.
In settlement of the charges, the firm agreed to:
1) Appropriate technical and organisational measures are employed, and maintained, to prevent the unlawful processing of customer data, particularly within web based systems;
2) Only the minimum amount of customer personal data is stored and that this is retained only for as long as a relevant business need exists;
3) Computer systems storing customer personal data must be subject of regular penetration testing , with activity logs retained for an appropriate period of time and frequently interrogated for evidence of malicious attack;
4) The processing of customer credit card data is conducted by a PCI compliant external service provider;
5) The data controller shall implement such other security measures as it deems appropriate to ensure that personal data is protected against unauthorised and unlawful processing, accidental loss, destruction, and/or damage.
The ICO issued a companion press release on this breach, here.