Response on Unauthorized Data Sharing

Scenario: An insurer partners with third-party brokers and agents to sell policies but fails to enforce strict data-sharing policies.

Overview

In today’s digital age, data protection is paramount. There may emerge a probable cyber scenario where an insurer partners with third-party brokers and agents to sell policies but fails to enforce strict data-sharing policies. This oversight leads to the unauthorized sharing of customer Personally Identifiable Information (PII) and health data with brokers, who then use this data for aggressive cross-selling, violating privacy laws. A regulatory audit exposes this unauthorized data exchange, resulting in fines and public backlash.

Business Impact

The business impact of such a scenario is significant. Beyond reputational damage and loss of customer trust, regulatory non-compliance can lead to lawsuits and multi-million-dollar penalties under GDPR, DPDP Act, and CCPA. Technically, weak data-sharing policies and lack of monitoring heighten the risk of data misuse.

Incident Response Plan

Immediate action is crucial in mitigating the damage. The first step is to identify and isolate the source of the data leak and halt all data-sharing activities with third-parties. A thorough investigation must follow to assess the breach.   Roles must be clearly defined to lead the incident response team, communications with regulatory authorities and customers about the data breach. 

Communication strategy, both Internal & External, is vital in managing the crisis. The insurer must acknowledge the breach and outline the steps being taken to address the issue. Transparency is key to rebuilding trust with customers and stakeholders. Affected customers should be notified directly, and a dedicated helpline should be established to address their concerns. Internal employees also need to be guided to address the situation. The insurer should also engage with regulatory bodies and identify gaps in the existing process and implement necessary approvals. 

Remediation & Future Prevention

Root cause analysis is essential to understand how the breach occurred and to prevent future incidents. The insurer must review and strengthen its data-sharing policies and enforce strict access controls and conduct regular audits. Effective, continuous training programs should be established to educate employees and partners on data privacy and security best practices.

Recovery involves compensating affected customers, the insurer should offer identity theft protection services and financial compensation. 

Future Preventive measures are crucial to avoid similar incidents in the future. The insurer should establish a comprehensive Third-Party Risk Management Program that must monitor how external brokers handle customer data and data privacy regulations with regular audits & assessments.  

Implementing Strict Data Access Controls & data-sharing policies and procedures.

Implement continuous effective Training programs to educate employees and partners on data privacy and security best practices.

Deploy Advanced Cybersecurity Measures like encryption technologies, rights management, perimeter security, micro segmentation, zero trust, with robust monitoring systems to detect and respond to threats in real-time

In conclusion, unauthorized data sharing with third-party brokers can have devastating consequences for insurers. By taking immediate action, conducting thorough investigations, and implementing robust preventive measures, insurers can mitigate the risks and protect their customers’ data. Transparency and communication are key to rebuilding trust and maintaining a positive reputation in the industry.

Vivek Shankar
Vice President – IT Services
Axis Max Life Insurance Company

Disclaimer: The views expressed in this feature article are of the author. This is not meant to be an advisory to purchase or invest in products, services or solutions of a particular type or, those promoted and sold by a particular company, their legal subsidiary in India or their channel partners. No warranty or any other liability is either expressed or implied.
Reproduction or Copying in part or whole is not permitted unless approved by author.
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