GDPR Exploited to Expose Personal Data
Approximately one in four businesses disclosed personal information to a man who had made a bogus data access demand by citing Europe's General Data Protection Regulation (GDPR).
Under the GDPR, EU residents have a “right of access” to their personal information. If an individual demands all the information a company has on them, the company concerned must comply.
But what happens when the individual is a fraudster, pretending to be someone they’re not?
In this particular case, the woman's partner was a security expert, who approached dozens of British and American companies to test how they would respond a "right of access" request made in someone else's name.
In each case, he requested all of the data that was held on his fiancee.
In one particular case, a company's response included the results of a criminal activity check.
In other replies. credit card information was provided, along with travel details, account logins and passwords, as well as the data subject's US Social Security number.
James Pavur, a University of Oxford researcher, presented his findings at the recent Black Hat conference, which took place in Las Vegas. The test is the first of its kind designed to exploit the GDPR.
The Information Commissioner’s Office (ICO) shortened the time organizations had to respond to data requests. It added new types of information businesses must provide, and increased the potential penalty for non-compliance.
Some knowledge but no cigar
Pavur told the BBC:
Generally if it was an extremely large company - especially tech ones - they tended to do really well. ...Small companies tended to ignore me, but the kind of mid-sized businesses that knew about GDPR, but maybe didn't have much of a specialized process [to handle requests], failed.
Pavur declined to identify the organizations that had mishandled the requests, but said they had included:
a UK hotel chain that shared a complete record of his partner's overnight stays;
two UK rail companies that provided records of all the journeys she had taken with them over several years; and
a US-based educational company that handed over her high school grades, mother's maiden name and the results of a criminal background check survey
Mr Pavur has, however, named some of the companies that he said had performed well.
He said they included:
the supermarket Tesco, which had demanded a photo ID;
the domestic retail chain Bed Bath and Beyond, which had insisted on a telephone interview; and
American Airlines, which had spotted that he had uploaded a blank image to the passport field of its online form.
An independent expert, Dr Steven Murdoch, from University College London. said the findings were a "real concern";
Sending someone's personal information to the wrong person is as much a data breach as leaving an unencrypted USB drive lying around, or forgetting to shred confidential papers.
Mr Pavur's bride-to-be gave him permission to carry out the tests and helped write up the findings, but otherwise did not participate in the operation. So for correspondence, the researcher created a fake email address for his partner, in the format "first name-middle initial-last firstname.lastname@example.org".
An accompanying letter said that under GDPR, the recipient had one month to respond.
It added that he could provide additional identity documents via a "secure online portal" if required. This was a deliberate deception since he believed many businesses lacked such a facility and would not have time to create one.
The data access requests were carried out in two waves.
For the first half of those contacted, he used only the information detailed above. But for the second batch, he drew on personal details revealed by the first group to answer follow-up questions.
The idea, he said, was to replicate the kind of attack that could be carried out by someone starting with just the details found on a basic LinkedIn page or other online public profile.
If the organization asked for a "strong" type of ID - such as a passport or driver's license scan - Mr Pavur declined.
He also decided not to create forgeries of more easily faked documents.
So, for example, he would not sign documents saying he was the data subject. Nor would he send emails with spoofed headers when asked to write from the victim's registered account.
But he did try to convince the companies to accept documents that would theoretically be easy to mock up, but in this case could be sourced from his fiancee.
So, when one train operator asked for a photocopy of a passport, he convinced it instead to accept a postmarked envelope addressed to the "victim".
In another case, a cyber-security company agreed to accept a photograph of a bank statement, which had been blacked out so that the only information left on view was the target's name and address.
Image caption Mr Pavur says that in one case he a heavily redacted bank statement was accepted. Sometimes such subterfuge was unnecessary.
One online gaming company asked for the applicant's account password. But on being told that it had been forgotten, Mr Pavur said it disclosed his fiancee's personal data anyway without asking for alternative verification.
Mr Pavur said that a total of 60 distinct pieces of personal information about his girlfriend were ultimately exposed. These included a list of past purchases, 10 digits of her credit card number, its expiry date and issuer, and her past and present addresses.
In addition, one threat intelligence firm provided a record of breached usernames and passwords it held on his partner. These still worked on at least 10 online services as she had used the same logins for multiple sites.
In one case, the GDPR request letter was posted to the internet after being sent to an advertising company, constituting a data breach in itself. It contained the fiancee's name, address, email and phone number. "Luckily it only had very simple data," said Mr Pavur. "But you could imagine someone sending a letter with more detailed information."
Overall, of the 83 firms known to have held data about his partner, Mr Pavur said:
24% supplied personal information without verifying the requestor's identity
16% requested an easily forged type of ID that he did not provide
39% asked for a "strong" type of ID
5% said they had no data to share, even though the fiancee had an account controlled by them
3% misinterpreted the request and said they had deleted all her data
13% ignored the request altogether