IAPP-GDPR Web Banners-300x250-FINAL

In early January, 2013, over half a million young Canada professionals awoke to discover—via online newspaper or blog most likely—that the personal information they handed over to the government as part of their university student loan application had been compromised.  Human Resources and Skills Development Canada (HRSDC) admitted that anyone who was a client of the Canada Student Loans programs from 2000 to 2006 was at risk. More recently, in April 2013, the Investment Industry Regulatory Organization (IIROC) admitted that the personal information of 52,000 clients from dozens of investment firms had equally been compromised. In both cases massive reputational damage and high-profile lawsuits has ensued.

How did this happen, you might wonder?

Surely, the 2011 Sony data breach, among others, taught organizations about the importance of cybersecurity. Indeed, the problem was not one of cybersecurity—the networks remained secure. Rather, the reason why HRSDC and IIROC are under such scrutiny is for a much simpler, dumber reason. The personal information in question, in both cases, was left on unencrypted, portable hard drives that went missing. Possibly lost, presumably stolen, but I repeat: unencrypted portable hard drives.

These stories are perfect examples of why high-level privacy oversight via policies and procedures are meaningless without appropriate enforcement mechanisms. In this case, the most appropriate enforcement mechanism might have been as easy a thing as proper employee training.

Consider for a moment storing personal information in the cloud via a third-party host. No organization worth its weight in terrabytes would ever contract out such a project without airtight contractual provisions demanding appropriate security measures and permitting monitoring. Such provisions emphasize to third parties the importance of securely hosting information in the cloud to prevent data breaches similar to Sony. If the security is weak and the data is stolen, the third party could be liable.

But when personal information is stored on a physical hard drive, maybe as small as a USB key, who is to blame when it gets lost?

It may very well be that these organizations had weak policies or procedures, which did not call for encrypting devices—another problem altogether—but even taking for granted effective policies and procedures, employees need to build privacy into their daily routines. For that to happen, employers need to train them. Policies and procedures need to be enforced.

To prove that this problem is not isolated to HRSDC and IIROC—if the fact that such high-profile incidents happened so closely together didn’t imply it—one need look no further than Alberta. In Alberta, organizations must report all material privacy breaches to anyone who may have been affected by the breach. The province’s information and privacy commissioner regularly publishes reports concluding whether a privacy breach warrants this type of notification. From the program’s inception in 2010 to early 2013, there were 13 privacy breaches involving a stolen or lost hard drive or laptop. In most cases, the device or laptop in question was not encrypted. In 7 of those cases, the device or laptop was not even password protected.

The bottom line is that organizations that collect personal information need to have mature privacy programs, which includes proper policies and procedures, and also fully functional enforcement mechanisms. It is 2013—we should not be discovering in our local online newspapers or blogs that unencrypted devices with personal information mysteriously went missing.

photo credit: Enokson via photopin cc

Written By

Daniel Horovitz


If you want to comment on this post, you need to login.


Board of Directors

See the esteemed group of leaders shaping the future of the IAPP.

Contact Us

Need someone to talk to? We’re here for you.

IAPP Staff

Looking for someone specific? Visit the staff directory.

Learn more about the IAPP»

Daily Dashboard

The day’s top stories from around the world

Privacy Perspectives

Where the real conversations in privacy happen

The Privacy Advisor

Original reporting and feature articles on the latest privacy developments

Privacy Tracker

Alerts and legal analysis of legislative trends

Privacy Tech

Exploring the technology of privacy

Canada Dashboard Digest

A roundup of the top Canadian privacy news

Europe Data Protection Digest

A roundup of the top European data protection news

Asia-Pacific Dashboard Digest

A roundup of the top privacy news from the Asia-Pacific region

IAPP Westin Research Center

Original works. Groundbreaking research. Emerging scholars.

Advertise in IAPP Publications

Find out how to get your message in front the people you want to reach. Download a media kit now.

Get more News »

Find a KnowledgeNet Chapter Near You

Network and talk privacy at IAPP KnowledgeNet meetings, taking place worldwide.

Women Leading Privacy

Events, volunteer opportunities and more designed to help you give and get career support and expand your network.

IAPP Job Board

Looking for a new challenge, or need to hire your next privacy pro? The IAPP Job Board is the answer.

Join the Privacy List

Have ideas? Need advice? Subscribe to the Privacy List. It’s crowdsourcing, with an exceptional crowd.

Find more ways to Connect »

Find a Privacy Training Class

Two-day privacy training classes are held around the world. See the complete schedule now.

Online Privacy Training

Build your knowledge. The privacy know-how you need is just a click away.

The Training Post—Can’t-Miss Training Updates

Subscribe now to get the latest alerts on training opportunities around the world.

New Web Conferences Added!

See our list of upcoming web conferences. Just log on, listen in and learn!

Train Your Staff

Get your team up to speed on privacy by bringing IAPP training to your organization.

Learn more »

CIPP Certification

The global standard for the go-to person for privacy laws, regulations and frameworks

CIPM Certification

The first and only privacy certification for professionals who manage day-to-day operations

CIPT Certification

The industry benchmark for IT professionals worldwide to validate their knowledge of privacy requirements

Certify Your Staff

Find out how you can bring the world’s only globally recognized privacy certification to a group in your organization.

Learn more about IAPP certification »

Get Close-up

Looking for tools and info on a hot topic? Our close-up pages organize it for you in one easy-to-find place.

Where's Your DPA?

Our interactive DPA locator helps you find data protection authorities and summary of law by country.

IAPP Westin Research Center

See the latest original research from the IAPP Westin fellows.

Looking for Certification Study Resources?

Find out what you need to prepare for your exams

More Resources »

GDPR Comprehensive: Registration Open

New! Intensive two-day GDPR training led by the sharpest minds in the field. It's a can't-miss event.

The Congress Is Cancelled

The IAPP Europe Data Protection Congress 2015 is cancelled. Click through to learn more.

Sponsor an Event

Increase visibility for your organization—check out sponsorship opportunities today.

Exhibit at an Event

Put your brand in front of the largest gatherings of privacy pros in the world. Learn more.

More Conferences »

Become a Member

Start taking advantage of the many IAPP member benefits today

Corporate Members

See our list of high-profile corporate members—and find out why you should become one, too

Renew Your Membership

Don’t miss out for a minute—continue accessing your benefits

Join the IAPP»