FIRST RESPONSE.docx - FIRST RESPONSE The first step was to...

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FIRST RESPONSE The first step was to validate the threat. We found a discussion on a hacker site in the dark-net that revealed personal information of 150,000 account holders of our client was available for sale, with the same 500 customers' details provided as a "sample". At the same time, and within a few hours, we had also preserved the relevant server logs and quickly identified and neutralised malware found on our client's network. During that time we had to assume that internal communications were subject to eavesdropping so secure channels were used between the client, lawyers and forensic investigators. A careful review of the sample compromised data ensued to confirm if in fact sensitive personal information of our client's customer base had indeed been taken. Due to the international nature of this investigation we were careful not to export data across borders without appropriate safeguards in place e.g. the US is not a safe harbour for the purposes of the EU data protection regime unless the entities concerned were signed up to the US Department of Commerce Safe Harbour Scheme. The investigations confirmed that the information for the 500 customers was genuine. Server logs revealed that it had been extracted a few days' earlier. In this case, fortunately, it was only UK customers that were affected. However, scrutiny of the server logs revealed no evidence that 150,000 customers' details had been taken: the evidence pointed only to the 500 customers' details attached to the original ransom email having been taken. Consideration was therefore given to whether or not the hackers were actually bluffing, both as to the suggestion that they had 150,000 customers' details but also as to the merger plans. There had been speculation in the press anyway about the potential deal, and there was no evidence from a
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