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."
ENB 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.Q.3.1 The Capability Maturity Model (CMM) is an additional benefit to organisations
that invest in information risk management programs.
Arrange each level of CMM for the FNB case study above to enjoy additional.Write the answer for 15 marks

1 answer

The Capability Maturity Model (CMM) provides a structured framework for organizations to evaluate and improve their processes, including information risk management. In the case of First National Bank (FNB), moving through the CMM levels can help the organization enhance its information protection measures and reduce the risk of future breaches.

Let's arrange each level of the CMM according to the relevant aspects of FNB’s case study:

Level 1: Initial (Ad-hoc)

  • Characteristics: Processes are unpredictable, poorly controlled, and reactive.
  • FNB’s Situation: The reported data exposure incident indicates that there may have been ad-hoc practices related to data security and application management. The absence of robust testing or controls allowed for the personal information of applicants to be accessed.

Level 2: Managed

  • Characteristics: Basic project management practices are established. There are some processes in place, but they may not be tailored or institutionalized.
  • FNB’s Situation: FNB has acknowledged the data breach and temporarily disabled the affected app functionality. This represents a step towards managing the incident, demonstrating that there are some basic processes to handle immediate breaches. However, the lack of systematic controls highlights the need for more reliable practices.

Level 3: Defined

  • Characteristics: Processes are documented and standardized across the organization but may not be monitored as consistently as needed.
  • FNB’s Situation: As FNB develops its risk management program, it should move towards defining clear processes for data protection, privacy, and incident response. Implementing comprehensive training and documentation around the protection of personal information will help improve consistency and assurance.

Level 4: Quantified

  • Characteristics: Metrics are established to measure process performance, enabling proactive management.
  • FNB’s Situation: FNB can implement a metrics system to regularly monitor the performance of its data protection processes. This could include tracking the number of data access attempts, incidents of unauthorized access, and outcomes of training programs for staff in recognizing data privacy risks.

Level 5: Optimizing

  • Characteristics: Focus on continuous process improvement through feedback, innovation, and learning.
  • FNB’s Situation: As FNB matures in its risk management practices, it should emphasize a culture of continuous improvement. Regular audits, feedback loops from customers on data privacy, and innovation in security technologies (e.g., robust encryption, real-time monitoring) would position them at this level.

Conclusion:

By moving through these CMM levels, FNB can strengthen its information risk management practices. The data exposure incident serves as a crucial learning opportunity to advance from reactive to proactive data privacy measures, ultimately aiming for an optimized environment where customer information is consistently protected. Investing in the necessary processes and culture change throughout these levels will not only help FNB comply with the Protection of Personal Information Act (POPIA) but also mitigate reputational and financial risks associated with data breaches. The goal should be to achieve a maturity level that minimizes vulnerabilities and increases customer trust.