No company, big or small, is immune to a data breach. Many small employers falsely believe they can elude the
attention of a hacker, yet studies have shown the opposite is true. According to the Symantec SMB Threat
Awareness Poll Global Results, 40 per cent of the data breaches in 2011 were at small to mid-sized companies.
Data breach response policies are essential for organizations of any size. A response policy should
outline how your company will respond in the event of a data breach, and lay out an action plan that will be used
to investigate potential breaches to mitigate damage should a breach occur.
Defining a Data Breach
A data breach is an incident where Personal Identifying Information (PII) is accessed and/or stolen by an
unauthorized individual. Examples of PII include:
• Social insurance numbers
• Credit card information (credit card numbers – whole or part; credit card expiration dates; cardholder
names; cardholder addresses)
• Tax identification information numbers (social insurance numbers; business identification numbers;
employer identification numbers)
• Biometric records (fingerprints; DNA; retinal patterns and other measurements of physical characteristics
for use in verifying the identity of individuals)
• Payroll information (paycheques; paystubs)
• Medical information for any employee or customer (doctor names and claims; insurance claims;
prescriptions; any related personal medical information)
• Other personal information of a customer, employee or contractor (dates of birth; addresses; phone
numbers; maiden names; names; customer numbers)
Data breaches can be costly. According to the Ponemon Institute’s Cost of a Data Breach Survey, the average
per record cost of a data breach was $194 in 2011; the average organizational cost of a data breach was $5.5
Breach Containment and Preliminary Assessment A breach or a suspected breach of PII must be
immediately investigated and contained. Since all PII is of a highly confidential nature, only personnel necessary
for the data breach investigation should be informed of the breach. The following information must be reported
to appropriate management personnel:
• When (date and time) did the breach happen?
• How did the breach happen?
• What types of PII were possibly compromised? (Be as detailed as possible: name; name and social
insurance number; name, account and password; etc.)
• How many customers may be affected?
Evaluation of the Risks Associated with the Breach
Once basic information about the breach has been established, management should make a record of
events and people involved, as well as any discoveries made over the course of the investigation to determine
whether or not a breach has occurred. After the breach has been verified and contained, perform a risk assessment that rates the:
• Sensitivity of the PII lost (customer contact information by itself may present much less of a threat than financial information)
• Amount of PII lost and number of individuals affected
• Likelihood PII is usable or may cause harm
• Likelihood the PII was intentionally targeted