The Information Commissioner’s Office (ICO) has fined British Airways (BA) £20 million for failing to protect the personal and financial details of more than 400,000 of its customers.

An ICO investigation found the airline was processing a significant amount of personal data without adequate security measures in place. This failure broke data protection law and, subsequently, BA was the subject of a cyber attack during 2018, which it did not detect for more than two months.

ICO investigators found BA ought to have identified weaknesses in its security and resolved them with security measures that were available at the time.

Addressing these security issues would have prevented the 2018 cyber attack being carried out in this way, investigators concluded.

Information commissioner Elizabeth Denham said: “Their failure to act was unacceptable and affected hundreds of thousands of people, which may have caused some anxiety and distress as a result, that’s why we have issued BA with a £20m fine – our biggest to date.

“When organisations take poor decisions around people’s personal data, that can have a real impact on people’s lives," she continued, adding: "The law now gives us the tools to encourage businesses to make better decisions about data, including investing in up-to-date security.”

Because the BA breach happened in June 2018, before the UK left the EU, the ICO investigated on behalf of all EU authorities as lead supervisory authority under the General Data Protection Regulation (GDPR). The penalty and action have been approved by the other EU data protection authorities through the GDPR’s cooperation process.

In June 2019, the ICO issued BA with a notice of intent to fine. As part of the regulatory process the ICO considered both representations from BA and the economic impact of COVID-19 on their business before setting a final penalty.

The attacker is believed to have potentially accessed the personal data of approximately 429,612 customers and staff. This included names, addresses, payment card numbers and CVV numbers of 244,000 BA customers.

Other details thought to have been accessed include the combined card and CVV numbers of 77,000 customers and card numbers only for 108,000 customers. Usernames and passwords of BA employee and administrator accounts as well as usernames and PINs of up to 612 BA Executive Club accounts were also potentially accessed.

There were numerous measures BA could have used to mitigate or prevent the risk of an attacker being able to access the BA network. These included limiting access to applications, data and tools to only that which are required to fulfil a user’s role; undertaking rigorous testing, in the form of simulating a cyber attack, on the business’ systems; and protecting employee and third party accounts with multi-factor authentication.

None of these measures would have entailed excessive cost or technical barriers, with some available through the Microsoft Operating System used by BA. Since the attack, BA has made considerable improvements to its IT security.

ICO investigators found that BA did not detect the attack on 22 June 2018 themselves, but were alerted by a third party more than two months afterwards, on 5 September. Once they became aware BA acted promptly and notified the ICO.

It is not clear whether or when BA would have identified the attack themselves, noted the ICO. This was considered to be a severe failing because of the number of people affected and because any potential financial harm could have been more significant.

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