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It was a low-key announcement last week from the UK ICO (Information Commissioner Office) that caught my eye, but an important one for the socialhousing sector.
They issued a reprimand to the Clyde Valley Housing Association in Lanarkshire, Scotland after personal information was accessible to other residents on an online customer portal. In fairness CVH are not the only provider in the news recently. Lets not forget that digital self-service for residents is essential.
It was stated that it was a resident user on the first day of use, that discovered they could easily access other tenant data, including documents and personal information.
Other residents reported the same issue and due to lack of escalation, the situation continued for five days. The danger of criminals (or just optimists) obtaining personal information for nefarious purposes is real and can easily lead to identity theft.
This situation was most likely caused by a number of factors, all of which could have easily been detected and mitigated quite easily.
More attention to secure design would have been a start. By the looks of the login it uses a relatively standard turnkey resident portal with a design layer from a third party web partner over the top. This is a very popular strategy and can be executed very securely in most cases. It does however need good design considerations.
User Acceptance Testing (UAT) is an essential stage, one that often has scant attention for many implementations. It often needs to be lengthy and detailed which puts many organisations off. Also, it should not be ignored that most staff have never had to thoroughly test software before. Some coaching is needed with inexperienced staff, where skilled testing staff (or staff that have tested before) are not involved.
I have worked with many organisations to build UAT plans for them and produce some training materials to help them understand the process and execute it well, creating audit for each test.
Lastly, engaging a third party security organisation to look at access, do some penetration testing and other probing of the solution, to determine any flaws and means of accessing inappropriate data, is recommended. Browser based solutions open many more vulnerabilities than many older legacy applications and are best checked over more frequently, at least annually.
The above precautions should also be repeated at each upgrade or application of patches. While this all sounds like hard work, its all about keeping secure. Applying upgrades is also part of that. Leaving too long between upgrades potentially introduces new vulnerabilities and may also violate your contract with suppliers. As for the latter, make best use of their help desk services if you are paying annual maintenance for them. Often working as a Critical Friend, not enough is made of this and relationships with suppliers can be poor (& get poorer!).
Where you may have built portals internally and they are home-grown by your ICT team, remember they then need to take on these responsibilities, as essentially what they have built will be one of a kind.
I hope my notes here provide some takeaways and help you avoid anything similar happening in your organisation.
Full ICO article text here.
Related Post: After Covid, are we embracing the New Normal ?
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Metronomy – Insecurity.
(c) Tony Smith, Acutance Consulting www.acutanceconsulting.co.uk 07854-655009
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