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A glitch in big-four bank First national Bank's (FNB's) mobile app has exposed personal information of customers applying for home loans using the digital platform. It was discovered that if an FNB client used the mobile app to apply for a home loan, they would easily see the personal details of other home loan applicants. The exposed data includes personal identifiable information, such as names, identity numbers and contact details. An FNB client who discovered the exposed data has since informed the Information Regulator, asking it to take the necessary measures against the big-four bank. "I wish to lodge a complaint against First National Bank in respect to a breach of personal information through their banking application," the client reported to the regulator. "Whilst applying for a home loan through the service, I noticed that I was able to access other individuals' personal information, such as ID numbers, contact details and various financial information, which is visible to other applicants, including my personal information. "I have documented this by way of screenshots and have evidence to support this data breach. I believe my rights in terms of the POPI Act [Protection of Personal Information Act] have been infringed and poses a huge personal security risk," stated the client. "Your e-mail contents have been noted and will be addressed with the responsible party," says a complaints and investigations officer of the Information Regulator in an e-mail.Under South Africa's data privacy law, the Protection of Personal Information Act (POPIA), organisations must inform the Information Regulator if they expose the personal information of data subjects to unauthorised third parties without their approval. FNB has acknowledged exposing the personal information of its clients, saying it is in the process of notifying the relevant authorities, as well as those who have been impacted. While the financial institution has rushed to disable the app functionality in question, it did not disclose how many customers were impacted. Says the bank in a statement: "FNB is aware of a technical error that made the information of certain home loan applicants, such as full names and ID numbers, visible to other home loan applicants who logged in via our digital channels. FNB takes the privacy and protection of customer information very seriously, and the affected functionality has since been temporarily disabled to resolve the root cause of the issue. We are in the process of contacting the affected customers and the appropriate regulator. Customers requiring any assistance can contact us through Secure Chat on the FNB app." FNB recently made sweeping changes to its brand, including a redesign of its popular banking app. The FNB app, introduced more than a decade ago, saw its active transacting base exceed 4.7 million customers, based on results for the year ended 30 June 2022. The data exposure comes at a time the Information Regulator is receiving an unprecedented number of reports about data breaches in South Africa. Speaking during the Governance, Risk and Compliance 2023 conference last week, advocate Pansy Tlakula, chairperson of the Information Regulator, revealed that data breaches are a big problem in this country - much bigger than people think. "Every public body, every private body that has suffered a security compromise or data breach has to notify us - there is no threshold. Even if one person was breached, they still have to notify us. If you look at 500 (it's 564 to be precise), it means that in a month, this country suffers about 56 data breaches - major and minor ones," she revealed. "I think we are one of the highest in the world with data breaches."POPIA sets down firm frameworks that companies have to abide by to avoid fines, criminal persecution and potential reputation loss. Breaching the rules and regulations outlined by this Act can have serious financial implications for the business - repercussions that can cost a fortune and have long-lasting consequences, such as reputational damage. The Act makes provision for fines of up to R10 million and a jail sentence of up to 10 years, depending on the seriousness of the breach.Identify the risk treatment criteria that can be applied at the strategic level by FNB, in the above case, to document all risks, where consequences for the firm could be dire, as well as emerging risks that could cause larger troubles in the future if they are not monitored carefully?Write an answer for 10 marks.Strategic layer,Tactic layer,Operational level ..use only these 3 layers

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To effectively address the data breach experienced by First National Bank (FNB) in relation to their mobile app, the bank needs to establish comprehensive risk treatment criteria across three layers: strategic, tactical, and operational. Below are the suggested criteria focused primarily on the strategic layer:

1. Strategic Layer Risks and Treatment Criteria

Risk Identification and Documentation:

  • Regulatory Compliance Risk: Identify risks related to non-compliance with the Protection of Personal Information Act (POPIA). Document instances of non-compliance and establish a risk register to track potential breaches.
  • Reputational Risk: Assess the potential damage to the bank's reputation stemming from the data breach. Document customer feedback, media coverage, and social media sentiments about the breach to quantify reputational damage.
  • Customer Trust Risk: Track metrics related to customer trust and loyalty, including customer satisfaction scores and retention rates, to understand the financial impact of losing customer confidence.
  • Emerging Cybersecurity Risks: Monitor trends in cybersecurity threats specifically affecting financial institutions. Maintain vigilance on evolving risks that may arise from new technologies or increased cyber-attacks targeting personal data.

Risk Assessment and Prioritization:

  • Impact and Likelihood Analysis: Prioritize identified risks based on their potential impact on operations and the likelihood of occurrence, using a risk matrix to categorize them into high, medium, and low priorities.
  • Scenario Planning: Develop various scenarios that consider worst-case outcomes of data breaches, enabling proactive strategic decisions.

Risk Mitigation Strategies:

  • Policy Development: Create a data governance policy emphasizing the protection of customer data across all platforms and channels. This should include training for employees on data security protocols.
  • Investment in Technology: Allocate budget for advanced cybersecurity measures and technologies that can help prevent future breaches (e.g., real-time monitoring systems, encryption technologies).
  • Crisis Management Preparedness: Develop a comprehensive crisis response and communication plan that outlines procedures to follow in the event of data breaches or cybersecurity incidents. This should include notifying affected customers and regulators promptly.

2. Monitoring and Review:

  • Regular Risk Audits: Establish feedback loops through regular audits of data security measures, compliance status, and risk management practices to include continuous improvement of strategies.
  • Stakeholder Communication: Maintain transparent communication with stakeholders, including customers, regulators, and employees, regarding data protection improvements and open channels for reporting incidents.

3. Integration with Tactical and Operational Layers:

  • Align the findings from the strategic layer with specific tactical actions (e.g., training programs for employees on data protection) and operational protocols (e.g., technical safeguards for customer data) to create a cohesive approach to risk management.

In summary, documenting and managing risks at the strategic level involves identifying, assessing, and prioritizing risks while implementing comprehensive mitigation and monitoring strategies. Such measures will not only address the current breach but also help in preventing future incidents, ultimately safeguarding FNB’s reputation and customer trust.