pdpc_undertakings_version: 22

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_id _item _version _commit id organisation url timestamp description pdf-url pdf-content _item_full_hash
22 22 1 1002 22 The National University of Singapore Society https://www.pdpc.gov.sg/Undertakings/Undertaking%20by%20The%20National%20University%20of%20Singapore%20Society 2022-08-11 Background  The Personal Data Protection Commission (the “Commission”) received a data breach notification on 8 October 2021 from The National University of Singapore Society (“NUSS”). NUSS stated that its website had been subjected to a SQL injection attack sometime between 6 and 7 October 2021. The personal data of 3,725 individuals was affected. The affected datasets comprised the affected individuals’ name, address, email, NRIC number, contact number, gender, date of birth, membership number, marital status, education details and motor vehicle registration number. It was established that NUSS had (a) inadequate knowledge of the web server hosting its website, (b) inadequate security reviews to identify vulnerabilities within its website, (c) lack of clauses within its contract with its vendors to ensure compliance with the PDPA and (d) there had been an overreliance on its IT vendor to maintain the security of the web server hosting its website. Remedial Actions After the incident, as part of a remediation plan, NUSS had: (a) Ensured that no personal data was stored at its web server; (b) Fixed all vulnerabilities identified in its forensics report; (c) Conducted a penetration test; (d) Established checklists, procedures and templates for 3rd party vendors; (e) Migrated its website to a virtual private server; and (f) Revamped its website. Undertaking  Having considered the circumstances of the case, including the remedial steps taken by NUSS to improve its personal data protection practices, the Commission accepted an undertaking from NUSS to improve its compliance with the Personal Data Protection Act 2012. The undertaking was executed on 14 December 2021 (the “Undertaking”). NUSS has since updated the Commission that it has implemented its remediation plan fully. The Commission has reviewed the matter and determined that NUSS 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---The-National-University-of-Singapore-Society.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: The National University of Singapore Society UEN: S61SS0139H Registered Address: Kent Ridge Guild House, 9 Kent Ridge Drive, #01-00 Singapore 119241 (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, 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 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. SIGNED, for and on behalf of ) The National University of Singapore Society ) By the following: ) Name: ______________________________________ ) Designation: _________________________________ ) Date: _______________________________________ ) ACCEPTED by ) ) Name: _____Yeong Zee Kin______________________ ) Designation: Deputy Commissioner / Commissioner Personal Data Protection ) Date: _______________________________________ ) SCHEDULE A SUMMARY OF FACTS 1. On 8 October 2021, the Organisation was made aware by its IT Security Department that records of members of The National University of Singapore Society (“NUSS”) were put on sale in an internet forum. 2. NUSS identified that a threat actor had conducted an SQL Injection attack on its website and was able to download all the data contained in 51 data tables. As a result of the attack, the personal data of the Organisation’s approximately 3,725 individuals including their name, NRIC numbers, membership number, marital status, gender, date of birth, nationality, email address, telephone numbers, address, education details, motor vehicle registration details were affected. SCHEDULE B S/N Item Status Target Date of Completion (Month-Year) 1 Ensure no personal data is stored at the webserver end Completed Oct 2021 2 Fix all vulnerabilities as identified in Group-IB’s report In Progress Target to complete by 30 Nov 2021 3 Another penetration test after all vulnerabilities fixed In Progress Target to complete by Q1 2022 4 Ensure all 3rd party vendors have In Progress Target to complete by Q1 2022 a. Compliance to the PDPA b. Proper data protection clauses in contract c. SOPs for handling NUSS personal data 5 Migrate web site from the current share hosting server to a Virtual Private Server (VPS), so that more security set up can be done to the server itself In Progress Target to complete by Q2 2022 6 Revamp the website to adhere to the Open Web Application Security Project (OWASP) guidelines. In Progress Target to complete by Q2 2022 7 Periodic Penetration Test Periodic Periodic d629f1064db6febe56753dbba1dcc986f50ba35e

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