Coding error causes data breach (2020-10-27)

Summary

This is a published case summary from the Cayman Islands Ombudsman describing an informal resolution of a data protection complaint. A coding error in an insurance company's accounting system caused remittance payments to be sent to the wrong bank, resulting in an unintended disclosure of client payment data.

• What happened: A coding error caused remittance payments to be sent to an incorrect bank; the company identified this after clients reported not receiving funds.
• Remedial action taken: The insurance company investigated internally, remediated the coding error with its third-party IT service provider, and secured an agreement with the unintended recipient to protect the misdirected data.
• Outcome: The Ombudsman found it unlikely that the data subject's rights and freedoms were prejudiced given the commercial context and the controller's remedial actions, and closed the case through informal resolution.

The summary is informational only. It illustrates the Ombudsman's approach to assessing data breaches and controller remediation efforts but does not itself impose new rules or continuing obligations on regulated entities.

Applies to

insurance company, data controller, third-party service provider