How To React To A Data Breach

Joe Welker (originally posted August 2nd, 2016)

 Would you be able to effectively manage the fallout of a data breach? If you aren’t sure, keep reading.

It was 2013 when a medium-sized library in Ohio found itself in the midst of a data breach that would later serve as a powerful case study warning against the very real threat of electronic fraud. While originally developed by the Ohio Auditor of State’s office as a tool for government entities throughout the state, Cash Management 240: Financial Fraud – A Case Study, has found usefulness beyond just the government sphere.

Leaders of not-for-profit organizations and for-profit business owners would also find value in this resource, which outlines:

  • the events that resulted in the occurrence of the data breach,
  • the reaction of entity officials during and after the breach was detected, and
  • the short- and long-term outcomes that resulted from the breach.

While I strongly recommend that you read the entire case study, I provide a brief overview of the story below.

How would you respond to a data breach?

Library officials were notified of the occurrence of fraudulent activity impacting the entity’s checking account in March of 2013. According to the bank, the fraudulent activity appeared to be limited to three transactions, totaling $144,743. Fortunately, bank officials were proactive in their efforts to recall the transactions.

In an effort to avoid further fraudulent activity, library officials decided to disconnect the accounting workstations from the entity’s network and proceeded to contact their technology vendor, who advised the library proceed with reformatting both accounting workstations immediately. Soon thereafter, library officials contacted the local police station to report the incident, closed the entity’s existing bank accounts and opened new ones, and notified employees of the data breach as well as the board of directors.

Due to the nature of the breach, it didn’t take long before the Ohio Auditor of State’s office and the FBI were notified of the incident as well. And, in an effort to try and reclaim some of the money that was stolen, a claim was filed with the entity’s insurance carrier. Finally, the library’s bank was able to successfully recover $54,910 of the amount that was stolen. In 2014, when the case study was released, the library was still in the process of negotiating with the bank regarding $89,833 that was still missing.

So, what do you think? Would you say that the library officials were effective in their management of the data breach? What would you do if your company or nonprofit found itself in a similar situation?

Well, according to the FBI, the library could have handled the situation better. For example, the library should have not reformatted the workstations. The FBI and local police force should have been contacted immediately. And finally, the entity should have followed all instructions mandated by the bank to eliminate the possibility of such fraudulent activity.

Since it’s 2013 data breach, the library:

  • Is now required by the bank to follow the ACH Originator Agreement.
  • Has designated one stand-alone PC to be used for online banking.
  • Has requested online access from only one IP address
  • Has purchased a cybercrime policy.
  • Revisited its banking RFP to include a section regarding online banking security minimums.

Do you have a plan to help deter cybercrime?

The above scenario is just one of the countless cybercrimes that occur every day and every type of businesses, entity and organizations are being impacted. If you don’t have a plan in place to help prevent cybercriminals from infiltrating your network and stealing your data for financial gain, or a strategy to recover once a breach has been identified, you are in a very vulnerable position.

In todays business environment it is essential to have a Breach Incident Response Plan in place to be able to respond quickly and effectively to a breach of sensitive data. Not only are there client confidentiality issues but also state and federal laws to keep in mind. If your entity has no such plan in place act today to get one started and get a head start on the breach process. 

By Joe Welker, CISA

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