Central government agency
Central government / information governance
The context
A government agency found that sensitive personal data relating to approximately 90,000 people, including vulnerable individuals, had been accessible through a misconfigured cloud environment for at least seven months. There was no evidence of exfiltration, but the agency could not establish that access had not occurred. The response had to combine containment, regulatory engagement, appropriate communication with affected people and ministerial briefing. A possible supplier deployment error and weaknesses in the agency's own assurance also required investigation.
The work undertaken
- A gold-command structure brought legal input into containment, forensic investigation and the initial regulatory notification, alongside coordinated briefing for ministers.
- Clinical and safeguarding specialists helped design differentiated notifications: individual contact and support for the highest-risk people, with letters and a staffed helpline for the wider cohort.
- An independent security review, a remediation plan with verifiable milestones and monthly progress evidence supported regulatory engagement. Supplier responsibility was pursued separately.
- The wider programme reviewed cloud configurations, introduced a security sign-off gateway, revised processor-contract audit arrangements and trained staff with administrative access to production systems.
The outcome
- The ICO closed its investigation without a monetary penalty or enforcement notice.
- Fewer than 200 of the 90,000 notified individuals contacted the helpline with concerns, and no compensation claims materialised.
- A negotiated supplier settlement recovered a substantial portion of the remediation costs.
- The deployment gateway was subsequently adopted as a template across the agency's parent department.