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.

Question

"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.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 15 marks.Write two paragraphs for the answers

Answer 1

In addressing the recent data breach, First National Bank (FNB) must implement robust risk treatment criteria at the strategic level to reinforce its commitment to data privacy and protection. One critical component of this strategy is the establishment of a comprehensive risk management framework that emphasizes the identification, evaluation, and monitoring of risks associated with customer data handling. FNB should employ methodologies such as risk assessment workshops, regular audits, and penetration testing to document and analyze both existing vulnerabilities and emerging threats. By classifying risks based on their likelihood and potential impact—ranging from minor incidents to severe data breaches—the bank can prioritize risk mitigation efforts. Furthermore, a continuous monitoring system should be set in place to track technological changes, regulatory shifts, and evolving cyber threats, ensuring that the bank remains proactive in protecting customer information and adheres to the requirements of the Protection of Personal Information Act (POPIA).

Additionally, fostering a culture of accountability and transparency within the organization is paramount for FNB. This includes extensive training programs for employees regarding data protection practices and their roles in safeguarding customer information. Establishing a cross-functional risk management team, comprising members from IT, compliance, legal, and customer service departments, can enhance communication and collaboration when it comes to identifying and responding to potential risks. To further strengthen the bank's public image and restore customer trust following the breach, FNB should prioritize clear and open communication with stakeholders about the measures taken to rectify the situation and prevent future occurrences. By integrating these risk treatment criteria at the strategic level, FNB not only safeguards its operations against current threats but also positions itself to effectively mitigate emerging risks that could have significant long-term consequences.