pdpc_undertakings: 55

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_id	_item_id	id	organisation	url	timestamp	description	pdf-url	pdf-content	_commit
55	4645cfe245e8b1962cc53697dbdcb6ddace8b58b	30	Employment and Employability Institute Pte Ltd	https://www.pdpc.gov.sg/undertakings/undertaking-by-employment-and-employability-institute-pte-ltd	2023-07-20	Background The Personal Data Protection Commission (the “Commission”) was notified by Employment and Employability Institute Pte. Ltd. on 25 March 2021 of a personal data breach involving its contact centre and data intermediary, i-vic International Pte. Ltd. (“i-vic). Investigations revealed that an employee of i-vic had most likely fallen prey to a phishing attack. As a result, a malicious actor successfully downloaded the personal data belonging to 31,002 individuals, from 2 email accounts belonging to the i-vic employee (the “Incident”).The personal data affected included the individuals’ partial or full NRIC, date of birth, telephone number, email address, residential address, highest qualification, and employment details. Further investigations found that i-vic had reasonable security measures in place to protect the personal data that it processes on behalf of e2i. i-vic had anti-virus protection, anti-phishing protection, regular anti-virus scans, security audits and conducted regular patches for its IT system. In fact, i-vic had existing anti-malware software which should have been able to detect the particular malware used in the Incident, but somehow failed to do so. After the Incident, i-vic purchased and deployed additional anti-malware software. Finally, the Commission found that i-vic had comprehensive policies and guidelines in place to protect personal data. While i-vic had reasonable security arrangements in place to protect the personal data it processes, the Commission established that this was entirely on i-vic’s account and not because of e2i’s bidding. e2i had failed to stipulate any specific data protection requirements on i-vic in their contract. e2i also lacked sufficiently robust processes to protect the personal data in its possession or control. i-vic produced evidence of several occasions where e2i’s employees had sent personal data to i-vic without any encryption or protection, which was against e2i’s standard operating procedures. Case No. DP-2106-B8424 A complainant alerted the Commission of a personal data breach involving e2i’s website on 21 June 2021. e2i's website had been designed in such a way that it would automatically populate and display all the data fields e2i had of an individual in its possession without the need for further authentication once an individual's NRIC number is keyed in to access e2i's website and register for a course, talk, or event. As a result, the personal data of 102,151 individuals was at risk of being disclosed. The personal data affected included the individuals’ name, citizenship, union membership status, gender, race, education, employment information, work experience, background, health records, and other partially masked personal data including NRIC number, date of birth, email address, postal code and contact number. As this personal data breach involving e2i's website occurred when the Commission was investing Case No. DP-2103-B8132, the Commission considered both cases involving e2i together. Remedial Actions After the incidents, as part of a remediation plan, e2i put in place the following measures which included: (a) Strengthening its data protection governance with the assistance of an independent vendor; (b) Engaging a professional company to conduct IT risk assessment audits on third-party vendors; (c) Implementing a one-time password ("OTP") authentication for individuals using its website; (d) Ensuring that i-vic has the necessary systems and processes in place to protect personal data; (e) Tightening its vendor selection process' (f) Enhancing its password protection policy; (g) Enhancing its outlook system security; (h) Made continuous effort to conduct regular staff training; and (i) Masking personal data on its website The Commission was also satisfied with the additional remedial actions undertaken by i-vic. Undertaking Having considered the circumstances of both cases, the Commission accepted an undertaking from e2i to improve its compliance with the Personal Data Protection Act 2012. The undertaking was executed on 10 March 2022 (the Undertaking). The Commission accepted the Undertaking as it was satisfied that notwithstanding e2i’s failure to stipulate personal data protection requirements in its contract with i-vic, e2i had engaged i-vic on account of i-vic’s good personal data protection policies and processes. For the personal data breach that affected e2i’s website, while the personal data of 102,151 individuals was at risk of being disclosed, the impact of the personal data breach was limited as e2i promptly took remediation action after being alerted by the Commission of the complaint received. e2i worked with its vendor to ensure that save for the last 4 digits of an individual’s contact number, the website no longer displayed any of the personal data fields of an individual. As part of the Undertaking, e2i eventually implemented an OTP authentication for individuals using its website. The Commission accepted the Undertaking as this is consistent with the Commission’s practice with respect to other personal data breaches similar to the one that affected e2i’s website, where there is no evidence to suggest that there has been unauthorised access or data exfiltration. e2i has since updated the Commission that it has completed the implementation of its remediation plan. The Commission has reviewed the matter and is satisfied that e2i has complied with the terms of the Undertaking. Please click here to view the Undertaking.	https://www.pdpc.gov.sg/-/media/files/pdpc/pdf-files/undertakings/undertaking---e2i-2023.pdf	WRITTEN VOLUNTARY UNDERTAKING (“Undertaking”) TO THE PERSONAL DATA PROTECTION COMMISSION This Undertaking is given to the Personal Data Protection Commission or its delegates pursuant to section 48L(1) of the PDPA, by: Employment and Employability Pte. Ltd. UEN: 200704772C Registered Address: 30 Cecil Street, #19-08, Prudential Tower, Singapore 049712 (hereinafter referred to as the “Organisation”). By signing this Undertaking, the above-named Organisation acknowledges the matters stated herein and undertakes to the Commission in the terms set out herein. 1. DEFINITIONS 1.1 In this Undertaking: (a) “PDPA” means the Personal Data Protection Act 2012 (No. 26 of 2012); and (b) “Relevant Provisions” means the provisions in Parts III, IV, V, VI, VIA and IX, and section 48B(1) of the PDPA. 2. ACKNOWLEDGEMENTS 2.1 The Organisation hereby acknowledges the following matters: (a) The Commission has carried out investigations into certain acts and practices of the Organisation, and has reason to believe that the Organisation has not complied, is not complying, or is likely not to comply with one or more of the Relevant Provisions. The relevant facts and circumstances are summarised at Schedule A. (b) As a result of any non-compliance with the PDPA by an organisation, the Commission has a number of enforcement options under the PDPA, 1 including the option to issue directions under sections 48I or 48J of the PDPA. (c) The Commission recognises that the Organisation has made efforts to address the concerns raised in this case and to improve its personal data protection practices. In addition, the Organisation was cooperative in the course of the investigation and was responsive to requests for information. The Commission further recognises that the Organisation appears ready to implement or is in the midst of implementing the steps set out in Schedule B. (d) Having carefully considered all the relevant facts and circumstances, the Commission takes the view that this is an appropriate case in which an Undertaking may be accepted. 2.2 The Organisation also acknowledges and agrees that the Commission may publish and make publicly available this Undertaking, and without limitation to the foregoing, the Commission may issue public statements referring to this Undertaking and/or its contents in whole or in part. 3. UNDERTAKINGS 3.1 The Organisation undertakes that it has taken, or will take all necessary steps, to carry out the actions or refrain from carrying out the actions referred to in Schedule B, and where applicable, in accordance with the stipulated timelines. 4. COMMENCEMENT 4.1 This Undertaking shall take effect upon the acceptance by the Commission of the Organisation’s duly executed Undertaking. 5. THE COMMISSION’S STATUTORY POWERS 5.1 In order to provide the Organisation with an opportunity to complete all necessary steps to implement its undertakings set out in clause 3 above, the Commission will exercise its powers under section 50(3)(ca) of the PDPA to suspend the investigations referred to in clause 2 on the date the Undertaking takes effect as set out in clause 4.1. 5.2 The Organisation acknowledges that the Commission will verify the Organisation’s compliance with its undertakings set out in clause 3 above, and 2 if necessary, will exercise its powers under the Ninth Schedule of the PDPA to do so. 5.3 Clause 5.1 above shall be without prejudice to the Commission’s statutory powers to conduct or resume, at any time, the investigations referred to in clause 2 above if it thinks fit, including but not limited to the situation where the Organisation fails to comply with this Undertaking or part thereof in relation to any matter. 5.4 Nothing in this Undertaking, including the Commission’s acceptance of the Undertaking, is intended to, or shall, fetter or constrain the Commission’s rights and statutory powers (including but not limited to those under sections 48I, 48J, 48L(4) and 50 of the PDPA) in any manner. Neither shall be construed as creating any anticipation or expectation that the Commission will take or not take any particular course of action in the future (whether in the present case or in respect of any other case concerning a breach or suspected breach of the PDPA). The acceptance of this Undertaking is strictly confined to the particular facts of the present case, and is made on the basis of the representations and information provided by the Organisation. The acceptance of an Undertaking in this case shall not be construed as establishing any precedent. 6. VARIATION 6.1 This Undertaking may be varied only with the express written agreement of the Commission. This document has been electronically signed. The Parties hereby affirm that the electronic signatures have been affixed with the due authorisation of each Party and that Parties intend for the electronic signatures to carry the same weight, effect and meaning as hand-signed wet-ink signatures. 3 SIGNED, for and on behalf of ) Employment and Employability Institute Pte. Ltd. ) By the following: ) Name: ______________________________________ ) Designation: _________________________________ ) Date: _______________________________________ ) ACCEPTED by ) ) Name: ______________________________________ ) Designation: Deputy Commissioner Personal Data Protection ) Date: _______________________________________ ) 4 SCHEDULE A 5 SUMMARY OF FACTS DP-2106-B8424 1. On 2 June 2021, the PDPC received feedback of a personal data breach incident by Employment and Employability Institute Pte. Ltd. ("e2i"). When an individual registers for a course, talk or event organised by e2i on e2i’s website, the website would automatically populate and display an individual’s personal data once an individual’s NRIC number is inserted into the website. If an individual uses the person’s NRIC number on e2i’s website, there would be the risk of unauthorised disclosure of personal data by e2i if such use had not been duly authorised. 2. As a result, the personal data of 102,151 individuals’ was at risk of a potential personal data breach. The types of personal data affected included the following: i) Name ii) Citizenship iii) Union member status iv) Gender v) Race vi) Highest education level vii) Unemployed since viii) Unemployment duration (months) ix) Reason for unemployment x) Education level detail (field of study, qualification name/title, institution, date of completion) xi) Work experience (From, to, company name, industry, job title, job duties, masked last drawn salary/month) xii) Background and health (Ex-offender, bankruptcy, color blindness, medical illness, drug abuse) xiii) Partially masked NRIC xiv) Partially masked date of birth xv) Partially masked email address xvi) Partially masked postal code xvii) Partially masked contact number (Home/HP) 3. The PDPC notes that there was no evidence of exfiltration of the personal data. 6 DP-2103-B8132 1. On 25 March 2021, the PDPC received a data breach notification from e2i, which involved its outsourced contact centre, i-vic International Pte. Ltd. (“ivic”). Personal data from 2 email accounts of an i-vic employee was downloaded by a malicious actor. It was found that i-vic had put in place reasonable security arrangements despite the data breach. 2. However, it was found that e2i had failed to stipulate reasonable data protection requirements when selecting i-vic as its data intermediary, and in its contract with i-vic. It was also found that e2i lacked sufficiently robust processes to protect personal data during transmission. There were at least 18 occasions where e2i’s employees had sent large volumes of personal data to i-vic without protection. 3. The personal data of 31,002 individuals’ was downloaded by a malicious actor in the incident. The types of personal data affected included the following: i) NRIC ii) Partial NRIC Number iii) Date of Birth iv) Mobile Number v) Landline vi) Email Address vii) Residential Address viii) Highest Qualification ix) Employment Details – containing salary, employment status, occupation or company name 7 SCHEDULE B 8 REMEDIATION PLAN A. In Progress S/N 1 Remedial Steps/Measures How does this measure address Target Completion date the issue Strengthen e2i’s data protection governance This will ensure our Data Protection Management Programme (DPMP) is relevant and optimised for operations and continuous improvements: e2i will appoint an independent vendor to conduct a professional review of our organisation's data protection practices through a comprehensive health check. The scope of engagement will include: • • • • Assessment of our existing data protection policies and practices, and recommend solutions to close gaps; Conduct a table-top exercise to test the data breach response plan; Managing our data intermediaries by putting in place governance and risk assessment; policies and practices; service management, and exit management. After the above review has been implemented, the vendor will continue to review our data protection policies and practices through regular health checks. This will enable us to continually 9 • • Status 16 Feb 2023 - we are looking In progress at a 1-year timeframe to complete the exercise with the following breakdown: 4 months: Confirming review specifications and Data collected is adequate, relevant and appointment of an limited to what is independent vendor to assess necessary and processed our existing policies, with the intended guidelines, and SOPs. purpose. Interview business units to Ensure appropriate controls are in place to identify relevant work secure data and processes and gaps. procedures in place for staff to recognise and respond to potential data breach incidences. 5 months: Review and implement recommendations Ensure there is a framework and process to bridge all gaps. Conduct identify and address risks and gaps and implement solutions to close them. to govern our data intermediaries table-top exercise to test data breach response plan. 3 months: Produce reports on the reviews and table top exercises that were carried out. Setup proactive monitoring such as regular audit period and inspection exercises for our practices and data intermediaries. 10 2 Professional IT security review and tightening of vendor selection process This will ensure better governance on Jun 2022 our third-party vendors' IT security and data protection capability. e2i has engaged a professional company to conduct IT Risk Assessment Audits on third-party vendors to ensure our vendors have the necessary cybersecurity frameworks and systems in place for data protection. Criteria(s) are put in place to tighten our vendor selection process. This ensures that the vendor has frameworks and procedures in place to manage and protect data, such as its storage security and access rights by different types of users; how does the vendor ensure compliance with PDPA such as training of staff and the IT system’s robustness. 11 In progress 3 OTP Implementation on e2i’s website With the OTP, users will have the Option 1: Mar 2022 added protection of their personal data from being accessed by anyone Option 2: Oct 2022 using their NRIC number Option 1 To implement an authentication (via OTP) interface before an individual reached the personal data confirmation page using the current Events Management SystHem ("EMS") In progress. e2i will review whether to renew contract with current vendor or explore a new EMS and update PDPC on its decision of implementing Option 1 or Option 2 by Mar 2022. Option 2 As current EMS is due for renewal or change by Oct 2022, e2i may explore a new EMS. In this case, e2i will implement the OTP on the new EMS. However, this means e2i will need a longer timeline as e2i has to evaluate different vendors and the functionalities the vendors can offer. In the meantime, information has been masked such that only the user’s partially masked contact number is left, which is not identifiable. 12 B. Implemented S/N 1 Remedial Steps/Measures How does this measure address the issue Timeframe Status IT and personal data handling checks on Call Centre vendors To prevent further March 2021 (for i-vic) Completed unauthorised access and September 2021 (for Agape due For i-vic International (Contract ended 31 Aug 2021): ensure that our call centre has the necessary IT systems and to change in vendor) • All i-vic staff supporting e2i’s work are processes in place to protect using company-issued desktops and our personal data. laptops. No unmanaged devices, including mobiles, are used for e2i’s work. • Implementation of multi-factor authentication to all user accounts supporting e2i’s work and scanning all staffs’ laptops to ensure no further incidence of malware • Advisory to i-vic to adopt different modes of communication for sharing of passwords. For new call centre Agape Connecting People Pte Ltd (Contract started from 1 September 2021) Checks were made to ensure they had: • Secured data management system 13 • • • • • Safer mail software (Microsoft 365 with 2-factor enabled password authentication) Secured data centre (Managed offsite at Telin, ISO certified vendor (ISO/IEC 27001:2013) Secured network server (Lantone Systems, housed locally, same company serving SingTel) 24/7 IT systems monitoring Overall enhancement in data sharing methods between vendor and e2i • 2 Quarterly review on IT systems Tightened vendor selection process To ensure better governance on our third-party vendors' IT security and data protection Current and future third-party vendors dealing with personal capability. data to complete an Information Security Third-party assessment questionnaire to understand their processes on capturing personal data, IT security controls, and compliance. From April 2021 Completed Incorporate legal clauses on PDPA data management in current and future contracts with vendors 3 Enhancement to password protection policy In addition to previous password policies, we required all newly changed system access passwords to be 12 characters long, comprising English letters with at least one upper case, numbers and special characters. To enhance policies and SOPs May 2021 set in place to guide staff on the password management for systems and documents containing personal information. 14 Completed Staff were also reminded to adhere to password guidelines: i. Staff should send password using a different channel; Staff should set password that are unique, unpredictable and changed on a regular basis ii. 4 Enhanced outlook system security This ensures that IT solutions May to July 2021 are in place to prevent personal data leakage. e2i has implemented the following system security: • • • Secure Web Gateway and Data Leak Prevention solutions in e2i laptop Data Loss Prevention feature to protect sensitive information in Microsoft O365 environment Implemented Geo-location restriction for Microsoft O365 accounts 15 Completed 5 Continuous effort to conduct regular PDPA Staff are equipped with PDPA On-going and cybersecurity awareness training and to knowledge and adequate competencies share good cybersecurity practices with to comply with our SOPs and policies. employees. • • • • • All new staff (including temps) need to complete an e-learning module on PDPA 101 within their 1st week of joining and before they handle personal data Yearly PDPA workshop for all staff Advisory emails sent to staff to remind them about good PDPA and cybersecurity practices Organisation-wide meetings feature a segment on good PDPA practices, reminders on PDPA governance Internal meetings (Risk/Management meetings) – PDPA compliance is regularly highlighted and addressed. 16 Completed 6 Masking of personal information on e2i’s registration page This will avoid any user using October 2021 another NRIC number to access another person's personal data To implement the masking of personal data within the Events after registration for an event due to the auto-population Management System registration confirmation page, only leaving the user’s partially masked contact number within the feature Completed user interface. The individual needs to only verify event details they have signed up for. CONFIDENTIAL Page 1 of 1	1007

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