Consider an incident involving unauthorized access to draft corporate loan agreements, underscoring the critical need to strengthen internal information governance and align it with the Cybersecurity Framework (CSF).
To illustrate, the incident stemmed from a misconfiguration in a shared drive that inadvertently granted view access to a junior staff group. This access should have been restricted exclusively to legal and compliance teams, highlighting vulnerabilities in access control practices.
The breach occurred when a junior staff member, under the impression that the document was finalized, forwarded a sensitive draft loan agreement with an international borrower to an external consultant. This led to premature exposure of confidential terms. The borrower, taken aback by the disclosure, raised concerns—delaying negotiations and putting the organization’s credibility at risk.
This scenario can be effectively understood through the five pillars of the CSF:
Identify
The organization failed to accurately identify the appropriate access roles and sensitivity of the documents stored on the shared drive. There was no clear inventory or classification of critical assets, such as draft legal agreements, nor a documented understanding of user access requirements. This oversight emphasizes the need for asset management, risk assessments, and role-based access mapping. The organisation does not have an established change management process for providing access to sensitive information.                                                                                                    Â
Protect
Under the protect function, this incident reveals a lapse in access control. Permissions were not enforced based on job function, and a lack of internal data classification allowed sensitive documents to remain accessible to unauthorized groups. Stronger enforcement of role-based access control (RBAC) and automated access provisioning could have prevented this. Regular staff awareness training would also ensure users understand the importance of verifying document status before sharing externally. Proper implementation of IDAM (Identity and Access Management) could have prevented this incident.Â
Detect
The organization had no apparent mechanism to detect unauthorized internal access or unusual document sharing behaviour. This shows that the organisation does not have a Data Classification in place. DLP (Data Leakage Prevention) frameworks advocate for user activity monitoring and audit trails that alerts the security team, when sensitive files are accessed or shared beyond designated groups. In this case, the organisation failed to implement DLP framework. Proper data classification and DLP implementation could have triggered an internal review before the document reached external parties. Another detection point would be user access review, this may be a delayed detection process but should be part of continuous monitoring.
Respond
Once the breach was discovered, communication and clarification with the affected borrower were delayed. A defined incident response plan—specific to internal data exposures—would have enabled a faster and more coordinated reaction. Transparency, rapid clarification, and immediate damage control are key to minimizing reputational harm and restoring confidence.Â
Recover
Under the recover pillar, the organization must not only restore trust with the borrower but also strengthen its governance policies to prevent recurrence. This includes conducting a root cause analysis, updating access controls, retraining staff, and implementing continuous access reviews and audits. Recovery also involves learning from the incident and integrating those lessons into broader data governance and cybersecurity strategy.
