Anxiety UK has signed an undertaking with the Information Commissioner’s Office after personal data held within a password protected area of Anxiety UK’s website, was publically available for approximately 12 months via an internet search engine.
The ICO was notified of the breach in February 2015 by Anxiety UK. Investigation revealed that the information had been cached due to a coding error, and personal data – including the names, addresses, email addresses and anxiety condition of members who had agreed to share their information with other members of Anxiety UK only – was made available on the internet as a result.
The Commissioner’s investigation revealed that Anxiety UK had failed to ensure that the data processor had sufficient technical measures in place to properly secure its systems:
Whilst there was a contract in place between Anxiety UK and the third party company appointed to build the website, the data protection provisions were extremely limited. The Commissioner’s investigation revealed that the data controller had failed to ensure that the data processor had sufficient technical measures in place to properly secure its systems. For example, appropriate penetration tests were not conducted prior to the website launch. Had this been done it is likely that the code error would have been detected prior to the launch of the website.
In addition, it appears that out of date membership details were available on the website. The Commissioner’s investigation therefore determined that the data controller’s quality assurance controls were inadequate. In particular, there was a lack of robust review mechanisms in place.
You can read the terms of the undertaking here (pdf).