pdpc_undertakings_version: 18

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_id _item _version _commit id organisation url timestamp description pdf-url pdf-content _item_full_hash
18 18 1 1002 18 HSL Constructor Pte Ltd https://www.pdpc.gov.sg/Undertakings/Undertaking%20by%20HSL%20Constructor%20Pte%20Ltd 2022-07-14 Background  The Personal Data Protection Commission (the “Commission”) was notified by HSL Constructor Pte Ltd (“HSL”) on 7 October 2021 that it was subject to ransomware attack on 30 September 2021. As a result of the attack, 3 of its servers and a Network Attached Storage (“NAS”) were encrypted by ransomware. Personal data of 758 current and former HSL employees were encrypted. The personal data included their name, NRIC number, residential address, email address, family information, salary information and medical information. The Commission noted that there was no evidence of exfiltration of the data. It was established that the threat actor(s) had likely gained access to HSL’s network by exploiting the vulnerabilities present in the outdated software used on 2 of its servers, or using compromised credentials. Remedial Actions After the incident, as part of a remediation plan, HSL: (a) Implemented multifactor authentication for all administrator access, for users with administrative privileges, and for accounts with access to sensitive data/ systems; (b) Supplemented existing email reminders on cybersecurity best practices with regimented user awareness training; (c) Decommissioned all servers running Windows Server 2008 R2 and below; (d) Installed endpoint protection on all servers; (e) Patched all servers and firewall; (f) Reset all admin account passwords; and (g) Closed unused ports on its firewall. Undertaking  Having considered the circumstances of the case, including the remedial steps taken by HSL to improve its data protection practices, the Commission accepted an undertaking from HSL to improve its compliance with the Personal Data Protection Act 2012. The undertaking was executed on 31 March 2022 (the “Undertaking”). HSL has since updated the Commission that it has completed the implementation of its remediation plan. The Commission has reviewed the matter and determined that HSL 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---HSL-Constructor-Pte-Ltd.pdf WRITTEN VOLUNTARY 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: HSL Constructor Pte Ltd UEN: 199405996K Registered Address: 42D Penjuru Road, HSL Waterfront @ Penjuru, Singapore 609162 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 and ; (b) Relevant Provisions 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, 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 1 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 duly executed Undertaking. 5. 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 3 above, and if necessary, will exercise its powers under the Ninth Schedule of the PDPA to do so. 5.3 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. 2 5.4 Nothing in this Undertaking Undertaking, is intended to, or shall, fetter or constrain the 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. SIGNED, for and on behalf of ) HSL Constructor Pte Ltd ) By the following: ) Name: ______________________________________ ) Designation: _________________________________ ) Date: _______________________________________ ) ACCEPTED by ) ) Name: ______________________________________ ) Designation: Deputy Commissioner Personal Data Protection ) Date: _______________________________________ ) 3 SCHEDULE A 4 SUMMARY OF FACTS 1. On 30 September 2021, the Organisation was subject to a ransomware attack in which 3 of its servers and a Network Attached Storage (NAS) were encrypted. exploiting the vulnerabilities in the outdated server software used on 2 of its server, or through the use of compromised credentials. 2. 758 current and former employees were encrypted by ransomware. The personal data including their name, NRIC number, residential address, email address, family information, salary information and medical information. There was no evidence of exfiltration of data. 5 SCHEDULE B 6 7 8 e25e24fa4ddf72cadda7e560f55c76fcda0bf9f7

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