Undertaking by Jet Aviation (Asia Pacific) Pte Ltd
On 26 July 2024, Jet Aviation (Asia Pacific) Pte Ltd ("Jet Aviation") reported unauthorized access to five email accounts containing personal data to the PDPC. The breach was caused by spear phishing emails that appeared as legitimate requests for e-signatures from trusted sources. These emails bypassed security scans, leading employees to a phishing website mimicking the Microsoft Office logon page. The threat actor intercepted primary refresh tokens, bypassing multifactor authentication, and obtained access to email accounts. Approximately 37,623 individuals' personal data, including names, addresses, identification numbers, and health information, were compromised.
The threat actor focused on email accounts containing invoices, accessing these 18 times and manually forwarding five emails with unpaid invoices. It diverted a payment of USD 139,000. Following the incident, Jet Aviation took remedial actions such as resetting passwords and engaging forensic investigators. Jet Aviation enhanced phishing training, updated email filtering configurations, and implemented stricter access requirements. As part of its voluntary undertaking, Jet Aviation committed to improving compliance with the Personal Data Protection Act 2012 by implementing sensitive data identification systems, updating data retention policies, and enhancing its incident response procedure. The full summary of the undertaking can be found here.
Undertaking by C. Melchers GmbH & Co. KG Singapore Branch
On 31 July 2024, C. Melchers GmbH & Co. KG Singapore Branch ("C. Melchers") reported to the PDPC a ransomware attack that led to unauthorized disclosure of personal data. The threat actor had obtained access through a domain administrator account and extracted files containing the personal data of 10,417 employees and customers, including names, addresses, telephone numbers, email addresses, NRIC and passport numbers. After discovering the incident, C. Melchers took prompt remedial actions such as implementing multifactor authentication for all accounts, requiring password changes, blocking internet connections, and enforcing strong password complexity requirements.
C. Melchers also agreed to a voluntary undertaking to improve compliance with the Personal Data Protection Act 2012. As part of the undertaking, C. Melchers undertook to, among other things, review its incident response plan, security policies, and operational procedures; train employees on cybersecurity and data protection; enforce multifactor authentication across all accounts; conduct periodic vulnerability assessments and penetration testing; and conduct incident simulations for employees. The full summary of the undertaking can be found here.
Undertaking by Singapore United Estates (Private) Limited
On 12 August 2024, Singapore United Estates (Private) Limited ("SUE") reported a ransomware attack to the PDPC. The threat actor encrypted and deleted data, including personal data, on systems belonging to SUE and related entities. The threat actor gained access through compromised user and administrative accounts and navigated the network with ease, encrypting files containing the personal data of 1,327 individuals, including names, NRIC numbers, contact information, passport numbers, dates of birth, and bank account numbers. After discovering the incident, the SUE entities promptly isolated affected systems and enforced password changes and multifactor authentication, among other things.
The SUE entities agreed to a voluntary undertaking to improve compliance with the Personal Data Protection Act 2012. Among other things, it enforced multifactor authentication for VPN accounts, adopted stronger password controls, set encryption on backup copies, and engaged third-party cybersecurity audits. The full summary of the undertaking can be found here.
Key takeaways
These cases are a good reminder for organizations and individuals to uphold preventive data protection practices in relation to third-party threat actors and to ensure proactive responses to data incidents. At the same time, the cases highlight the PDPC's willingness to accept voluntary undertakings as an enforcement outcome and to monitor ongoing compliance with the terms of such undertakings.
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