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Tag: data protection

A DPO’s Guide to Password Protection

by Parama Bose

On World Password Day 2025, observed on May 1st, let’s reflect on one of our most basic yet crucial lines of defence…..the password protection. And let’s be honest, we’ve all been there… “Password123”, “pet’s name” or even default credentials such as “admin.” These practices significantly weaken your security posture and expose your organisation’s sensitive systems to data breaches and regulatory risks.

This article explores how passwords are commonly compromised, outlines essential tips for strengthening password security, and explains why these practices are not just good IT hygiene—but a legal requirement.

Common Ways Passwords Are Compromised

Understanding how passwords are exposed is key to building better security habits:

Phishing Attacks: Cybercriminals impersonate legitimate organisations to trick users into disclosing their login credentials.

Credential Stuffing: Attackers use previously stolen username/password combinations from data breaches to access other accounts, taking advantage of reused credentials.

Data Breaches: When organisations suffer breaches, vast amounts of user data—including passwords—can be leaked or sold on the dark web.

 

5 Tips to Strengthen Password Protection

Enhancing password security doesn’t have to be complicated. Follow these best practices:

1. Go Long and Strong: Use at least 12 characters, including a mix of uppercase, lowercase, numbers, and special characters.

2. Enable Multi-Factor Authentication (MFA): MFA adds a second verification step, significantly reducing the risk of unauthorised access.

3. Use Unique Passwords: Each account should have its own distinct password. Avoid reusing passwords across services.

4. Change Passwords Regularly: Set reminders to update critical account passwords to minimise the risk of long-term exposure.

5. Use a Password Manager: These tools securely store and generate complex passwords, reducing the temptation to reuse simple ones.

 

The Risks of Neglecting Password Security 

Using a weak password can be the equivalent of leaving your front door wide open with a sign saying, “Come on in, take what you want!” Data protection regulations such as GDPR require businesses to implement robust security measures to protect personal data, and passwords are one of the simplest ways to prevent unwanted guests from getting in.

Weak password practices can have severe consequences for organisations:

a) Data Breaches: Inadequate password protection can result in unauthorised access and the exposure of personal or corporate data.

b) Regulatory Penalties: Under laws such as the UK GDPR and UAE PDPL, organisations must implement “appropriate technical and organisational measures” to safeguard data. Failing to do so can lead ICO to fine of up to €20 million or 4% of annual global turnover.

c) Reputational Damage: Once trust is broken due to a data incident, it can be difficult—and costly—to rebuild.

 

TenIntelligence Thoughts

This World Password Day, let’s stop making our data an easy target for cybercriminals. Secure your passwords, enable MFA, review password policies, and most importantly, train your team to strengthen your organisation’s data protection.

 

Written by

Lynsey HansonLynsey Hanson | Global Data Protection Officer

lynsey.hanson@tenintel.com

 

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Data Protection in Finance: Lessons from the ESL Fine

by Parama Bose

Why is Data Protection in Finance non-negotiable?

The recent £200,000 fine imposed by the ICO on ESL Consultancy Services Ltd for sending unlawful loan promotion texts is a wake-up call, highlighting the urgent attention for data protection in the finance industry. Nearly 38,000 complaints flooded in—proof that cutting corners on data protection isn’t just risky, it is costly. So, the big question is: Is your organisation’s data protected? 

In banking and lending, investments & wealth management, insurance and fintech companies- data is everything. The industry operates under intense scrutiny, with overlapping regulations such as UK GDPR, FCA rules, Anti-Money Laundering (AML) requirements, and Lending Standards Board (LSB) guidelines. Ensuring financial data security isn’t just about legal compliance or necessity—it is a critical trust factor for customers and stakeholders alike.

 

How can Financial organisations protect data?

Companies in the financial industry handle vast amounts of sensitive personal and financial data every day. Ensuring compliance with financial data protection regulations isn’t optional—it’s essential to avoid enforcement action, reputational damage, and potential financial losses. 

Key areas to focus on: 

  • Lawful Processing: Are you collecting and using personal data lawfully? Marketing activities must comply with the Privacy and Electronic Communications Regulations (PECR) and UK GDPR. Consent must be clear, specific, and recorded. 
  • Transparency and Accountability: Are you upfront with customers about how their data is used? Privacy notices should be clear, and records of processing activities (RoPA) must be maintained to demonstrate compliance. 
  • Third-Party Due Diligence: Do you truly know your affiliates and partners? As seen in the ESL case, lead generators and affiliate marketers must be closely monitored to ensure they comply with data protection laws. 
  • Security Measures: Are your systems robust enough to prevent breaches? Implement strong security controls to protect against unauthorised access and data loss. 
  • Individual Rights: Are you prepared to handle data subject requests efficiently? Individuals have rights to access, erase, and object to their data usage, and these must be respected without delay. 

 

The DPO’s Role in the Finance Industry

A Data Protection Officer (DPO) plays a crucial role in organisations dealing in the financial sector. They are the bridge between compliance and operational efficiency, ensuring that the business meets regulatory demands without disrupting customer service. 

Key responsibilities of a DPO in finance: 

  • Aligning data protection efforts with UK GDPR, FCA, AML, and LSB requirements. 
  • Educating staff to embed data protection into everyday practices. 
  • Overseeing data breach management and reporting to the ICO and FCA when necessary. 
  • Ensuring vendor compliance through rigorous assessments and contractual safeguards. 

Organisations in finance industries can no longer afford to see data protection as a secondary concern. The consequences of failing to prioritise compliance extend beyond fines to loss of customer trust and regulatory scrutiny. 

 

Compliance: What You Must Get Right

Compliance is more than ticking boxes; it’s about embedding a culture of responsibility and vigilance. Financial organisations must align their data protection efforts with the following key frameworks: 

  1. UK GDPR:
  • Ensure lawful, fair, and transparent processing of customer data. 
  • Obtain clear, valid consent for marketing and data sharing. 
  • Keep detailed records of processing activities. 
  1. Financial Conduct Authority (FCA):
  • Treat customers fairly by ensuring transparency in data use. 
  • Monitor and mitigate financial crime risks linked to personal data. 
  • Maintain a customer-first approach when handling data. 
  1. Anti-Money Laundering (AML):
  • Conduct thorough customer due diligence (CDD). 
  • Store financial data securely to support fraud detection. 
  • Report suspicious activity without breaching data protection rights. 
  1. Lending Standards Board (LSB):
  • Ensure fair treatment of customers in all lending practices. 
  • Be transparent about how personal data is used to assess affordability. 
  • Handle data responsibly, particularly for vulnerable customers. 

 

How to Stay Compliant: A Practical Approach 

  1. Audit Your Data: Know what data you hold, where it’s stored, and how it’s used.
  2. Review Consent Mechanisms: Ensure customers have genuinely opted in to receive marketing.
  3. Implement Strong Policies: Data retention, processing, and security policies should be clear and enforced.
  4. Train Your Teams: Make data protection a part of daily operations.
  5. Regularly Assess Risks: Conduct internal audits to spot compliance gaps before regulators do.

 

TenIntelligence Thoughts

The ESL case serves as a stark reminder: failing to prioritise data protection in finance can have serious consequences. For banks, lenders, and financial organisations, the stakes are even higher. Now is the time to assess your compliance, tighten controls, and seek guidance from a DPO. 

Data protection is no longer just a regulatory burden; it’s a competitive advantage. What are your next steps to get it right? 

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Written by

Lynsey Hanson | Global Data Protection Officer

Lynsey Hanson

ICO announces new data protection fining guidance March’24

by Parama Bose

The Information Commissioner’s Office unveils new data protection fining guidelines, offering clarity on penalty issuance and fine calculation, enhancing transparency for organizations. The new guidance is issued to replace sections of the ICO Regulatory Action Policy, published in November 2018.

With data breaches and privacy infringements increasingly making headlines, regulatory authorities worldwide have bolstered their oversight to ensure strict adherence to data protection laws. Thus, understanding the ICO’s stance on fines is essential for organizations to ensure compliance and mitigate risks effectively. Read this article to explore the new data protection fining guidance  from the Information Commissioner’s Office (ICO) issued in March 2024, shedding light on its approach to fines and enforcement strategies. 

 

Deciphering ICO’s latest data protection fines

In the United Kingdom, the Information Commissioner’s Office (ICO) holds a pivotal role in enforcing regulations such as the General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA), wielding the authority to levy fines for any infringements.

Under the UK GDPR and DPA, the ICO possesses the ability to impose fines for infringements, ranging from failures to implement adequate security measures to unauthorised data processing. These fines serve the dual purpose of penalising non-compliance and deterring future violations. Consequently, simplifying the navigation of legislation.

At the core of the ICO’s enforcement strategy lies the concept of an ‘undertaking,’ which encompasses any entity engaged in economic activities. This expansive definition ensures the accurate calculation of fines. Thus, uniformly applying it across organizations of varying sizes and legal structures.

 

The five fundamental steps for effective enforcement and compliance

The ICO adheres to a structured approach outlined in its Data Protection Fining Guidance. The steps are as follows : 

  1. Assessment of the seriousness of the infringement: For instance, in the scenario where a healthcare provider inadvertently exposes sensitive patient data due to weak internal access control procedures, the ICO evaluates the severity of the breach. It considers factors such as the volume of data compromised, the sensitivity of the information, and the potential harm to individuals. 
  2. Consideration of turnover: In assessing fines, the ICO factors in the turnover of larger organizations, ensuring fines are commensurate with their financial capacity while serving as an effective deterrent. 
  3. Calculation of the starting point: For instance, if a major corporation engages in systemic data misuse for financial gain, the ICO may impose a substantial fine to deter similar misconduct by other entities operating within the same sector.
  4. Assessment of aggravating or mitigating factors: The ICO takes into account various factors, such as the organisation’s response to the breach and its cooperation during investigations, which may warrant an increase or decrease in the fine.
  5. Adjustment to ensure effectiveness: Finally, the ICO evaluates fines to strike the right balance between deterrence and proportionality, ensuring they are sufficient to achieve their intended objectives without exceeding the statutory maximum amount. 

 

Hints and Tips for Organisations: 

  • Prioritize Data Protection: Allocate adequate resources and establish clear policies to prioritise data protection within your organisation. 
  • Stay Informed: Keep track of updates on developments in data protection regulations. Especially, issued by authorities such as the ICO to ensure ongoing compliance with evolving requirements. 
  • Conduct Regular Risk Assessments: Regularly assess your organisation’s data processing activities and associated risks. The assessments will help identify potential compliance gaps and take corrective action proactively. 
  • Invest in Training: Provide comprehensive training and awareness programs for employees. This step will ensure their responsibilities and obligations under data protection laws. 
  • Implement Robust Security Measures: Prevent data breaches and unauthorised access to sensitive information by deploying advanced security measures.
  • Engage Legal Counsel: Seek guidance from legal experts specializing in data protection. It is essential to obtain advice tailored to your organisation’s specific circumstances and compliance needs. 
  • Maintain Documentation: Keep detailed records of your organisation’s data processing activities, risk assessments, and compliance efforts. This process will help demonstrate accountability and transparency to regulatory authorities. 

 

Examples of Fines: 

  1. In 2023, the ICO imposed a fine of £20 million on a telecommunications company. The company had unlawfully sent millions of marketing messages, reflecting both the severity of the breach and the company’s significant turnover.
  2. A healthcare provider faced a £10 million fine by ICO. The organisation was accused of exposing patient records due to inadequate security measures.

This highlights the ICO’s commitment to enforcing data protection laws across diverse sectors. 

Summary

The ICO’s latest guidance on Data Protection Fining offers a comprehensive roadmap for organisations abiding by GDPR and DPA compliance. Adhering to the structured approach outlined can ensure robust data protection measures, mitigation of risks, and maintenance of trust. 

Seeking guidance from a Data Protection Officer (DPO) provides invaluable insights and assistance in implementing effective compliance strategies. DPOs offer practical advice on risk assessments, policy formulation, and staff training. 

Have questions on compliance and ICO fines? Submit your query at  info@tenintel.com and let our seasoned DPO experts help you.

UK’s New Data Protection Bill

by Inesh Perera

The UK’s legislative landscape is evolving with the introduction of the Data Protection and Digital Information (No. 2) Bill. This bill, currently progressing through the parliamentary process, aims to modernize data laws for the digital era. Spearheaded by Data Minister Julia Lopez, it’s slated for a parliamentary debate in August 2023 and is expected to have a significant impact. 

The bill carries a two-part objective: enhancing privacy and efficiency for the public. Annoyances like frequent cookie pop-ups during online browsing and nuisance calls are squarely addressed. The proposed legislation aims to reduce the frequency of consent pop-ups and impose more substantial fines on organizations behind unwanted calls, all in a bid to gain public trust in data handling practices. 

The bill’s timing aligns with the Global Cross-Border Privacy Rules Forum, a gathering of data experts focusing on global privacy strategies. As this event unfolds over four days, discussions and workshops are set to shape the future of data privacy approaches. 

Key features of the Data Protection and Digital Information Bill: 

  • Reducing Annoyances: Consent pop-ups that repeatedly ask for permission to collect user data online will be curbed. 
  • Increased Fines: Fines for nuisance calls and texts could increase to £17.5 million or four percent of global turnover, discouraging unsolicited communications. 
  • Digital Identity Verification: Secure digital verification services will be established, streamlining online identity verification.
  • Boosting Data Trade: Legal changes will enhance the UK’s capability to create secure global data deals, particularly important for UK businesses post-Brexit. 
  • Aligned with GDPR: The bill seeks to modernize the Information Commissioner’s Office and align with the European Union’s GDPR to ensure robust data protection. 
  • Data Minister Julia Lopez emphasizes that the bill bridges data protection standards with industry advancements, addressing real-world scenarios through collaborative input. 
  • The bill’s introduction coincides with the Global Cross-Border Privacy Rules Forum, where the UK aims to lead conversations among officials, regulators, and privacy experts. 

  

In conclusion,

The Data Protection Bill is set to reshape the UK’s data regulation landscape by tackling practical issues, imposing stricter penalties, and fostering strong international relationships.  

Need help navigating the Data Protection Bill? For expert advice and consultation from our Data Protection Officer, contact us on dpo@tenintel.com.

 

Lynsey Hanson

Written by

Lynsey Hanson | Data Protection Officer

lynsey.hanson@tenintel.com