Bible Society fined £100,000 after security failings put supporters’ personal data at risk

The British and Foreign Bible Society, based in Swindon, has been fined £100,000 by the Information Commissioner’s Office, after their computer network was compromised as the result of a cyber-attack in 2016.

Between November and December 2016, the intruders exploited a weakness in the Society’s network to access the personal data of 417,000 of the Society’s supporters. For a subset of these supporters some payment card and bank account details were placed at risk.

The Society, which translates and distributes the Bible in the UK and around the world, relies on card donations from its UK supporters.

Supporter details were kept on an insufficiently secured internal network, and in 2009 the Society created a service account on the same network.

This account, which was configured in such a way as to provide inappropriate remote access rights to the network, was only secured with an easy-to-guess password.

The attackers deployed ransomware, and whilst the society’s data was not permanently damaged or rendered inaccessible by the encryption, the attackers were able to transfer some files out of the network

The ICO’s Head of Enforcement, Steve Eckersley, said:

“The Bible Society failed to protect a significant amount of personal data, and exposed its supporters to possible financial or identity fraud.

“Our investigation determined that it is likely that the religious belief of the 417,000 supporters could be inferred, and the distress this kind of breach can cause cannot be underestimated.

“Cyber-attacks will happen, that’s just a fact, and we fully accept that they are a criminal act. But organisations need to have strong security measures in place to make it as difficult as possible for intruders.”

The Commissioner found that, although the Society was the victim of a criminal act, it failed to take appropriate technical and organisational steps to protect its supporters’ personal data.

The ICO considered this to be a serious contravention of Principle 7 of the Data Protection Act 1998, which states that appropriate technical and organisational measures must be taken against unauthorised or unlawful processing of personal data.

The Society has taken substantial remedial action since it became aware of the attack and has fully co-operated with the ICO’s investigation.

Notes to Editors

1. The Information Commissioner’s Office upholds information rights in the public interest, promoting openness by public bodies and data privacy for individuals.
2. The ICO has specific responsibilities set out in the Data Protection Act 2018, the Freedom of Information Act 2000, Environmental Information Regulations 2004 and Privacy and Electronic Communications Regulations 2003.                        
3. The European Union’s General Data Protection Regulation (GDPR) is a new law which applies in the UK from 25 May 2018. Its provisions are included in the Data Protection Act 2018. The Act also includes measures related to wider data protection reforms in areas not covered by GDPR, such as law enforcement and security. The UK’s decision to leave the EU will not affect the commencement of the GDPR.
4. The ICO can take action to change the behaviour of organisations and individuals that collect, use and keep personal information. This includes criminal prosecution, non-criminal enforcement and audit. The ICO has the power under the Data Protection Act 2018 to impose a civil monetary penalty on a data controller of up to £17million (20m Euro) or 4% of global turnover. Under the 1998 Act, the maximum financial penalty is £500,000.
5. Under the GDPR, the data protection principles set out the main responsibilities for organisations. Article 5 of the GDPR requires that personal data shall be:
   • Processed lawfully, fairly and in a transparent manner in relation to individuals;
   • Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
   • Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
   • Accurate and, where necessary, kept up to date
   • Kept in a form which permits identification of data subjects for no longer than is necessary; and
   • Processed using appropriate technical or organisational measures in a manner that ensures appropriate security of the personal data.

     Article 5(2) requires that “the controller shall be responsible for, and be able to demonstrate, compliance with the principles.”

6. A limited number of civil and criminal enforcement cases – including this case – are still being dealt with under the provisions of the Data Protection Act 1998 because of the date the breach occurred. The maximum financial penalty in these cases is £500,000.
7. Civil Monetary Penalties (CMPs) are subject to a right of appeal to the (First-tier Tribunal) General Regulatory Chamber against the imposition of the monetary penalty and/or the amount of the penalty specified in the monetary penalty notice.
8. Any monetary penalty is paid into the Treasury’s Consolidated Fund and is not kept by ICO.
9. To report a concern to the ICO telephone our helpline 0303 123 1113 or go to ico.org.uk/concerns.

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