British Airways fined £20m for the 2018 data breach, was acting illegally

The Information Commissioner’s Office has just published its final verdict on the 2018 data breach at British Airways.

The fine has been reduced to £20 million from the initial proposal of £183 million. The ICO makes it clear that this is partly due to the current financial difficulties at the airline – as well as BA’s co-operation and prompt reporting – and it is not a reassessment of the severity of the breach.

The ICO findings are damning. British Airways was found to have been acting illegally in its treatment of customer data.

“An ICO investigation found the airline was processing a significant amount of personal data without adequate security measures in place. This failure broke data protection law and, subsequently, BA was the subject of a cyber-attack during 2018, which it did not detect for more than two months.

ICO investigators found BA ought to have identified weaknesses in its security and resolved them with security measures that were available at the time.

Addressing these security issues would have prevented the 2018 cyber-attack being carried out in this way, investigators concluded.”

How big was the BA data breach?

The ICO says:

“The attacker is believed to have potentially accessed the personal data of approximately 429,612 customers and staff. This included names, addresses, payment card numbers and CVV numbers of 244,000 BA customers.

Other details thought to have been accessed include the combined card and CVV numbers of 77,000 customers and card numbers only for 108,000 customers.

Usernames and passwords of BA employee and administrator accounts as well as usernames and PINs of up to 612 BA Executive Club accounts were also potentially accessed.”

Could BA have prevented the attack?

The ICO says it could – and some of the measures were already available to it via its existing IT plaform. To quote:

“There were numerous measures BA could have used to mitigate or prevent the risk of an attacker being able to access the BA network. These include:

• limiting access to applications, data and tools to only that which are required to fulfil a user’s role
• undertaking rigorous testing, in the form of simulating a cyber-attack, on the business’ systems;
• protecting employee and third party accounts with multi-factor authentication.

None of these measures would have entailed excessive cost or technical barriers, with some available through the Microsoft Operating System used by BA.”

BA didn’t even know it had been hacked ……

“ICO investigators found that BA did not detect the attack on 22 June 2018 themselves but were alerted by a third party more than two months afterwards on 5 September. Once they became aware BA acted promptly and notified the ICO.

It is not clear whether or when BA would have identified the attack themselves. This was considered to be a severe failing because of the number of people affected and because any potential financial harm could have been more significant.”

It isn’t clear if IAG was aware of the contents of this report, including the finding that British Airways had been acting illegally, when Alex Cruz was removed from his role as CEO and Chairman of British Airways on Monday.

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