Friday, August 08, 2008

If all companies disclosed data breaches...

If all companies disclosed data breaches of any kind I wonder how many of these types of letters I'd get? Care to guess?

I noticed that Nishant over at Oracle blogged about this and he cited Slashdot's article on the same. I actually own a Clear card - and I registered at the San Francisco airport location...

(Emphasis below is Clear's - not mine, but I sure hope it is true!)

Dear Jackson Shaw,

We take the protection of your privacy extremely seriously at Clear. That's why we announced on Tuesday that a laptop from our office at the San Francisco Airport containing a small part of some applicants' pre-enrollment information (but not Social Security numbers or credit card information) recently went missing. None of your information was in any way implicated. However, we were prepared to send those applicants and members who were affected the appropriate notice on Tuesday detailing that situation.

Before we could send out that notice, the laptop was recovered. And, we have determined from a preliminary investigation that no one logged into the computer from the time it went missing in the office until the time it was found. Therefore, no unauthorized person has obtained any personal information.

Again, none of your personal information was on the computer in any form, but we nonetheless wanted to give you details of the incident that could have affected others applying for Clear memberships because the incident involves Clear's privacy and security practices and policies.

We are sorry that this theft of a computer containing a limited amount of applicant information occurred, and we apologize for the concern that the publicity surrounding our public announcement might have caused. But in an abundance of caution, both we and the Transportation Security Administration treated this unaccounted-for laptop as a serious potential breach. We have learned from this incident, and we have suspended enrollment processes temporarily until all pre-enrollment information is encrypted for further protection. The personal information on the enrollment system was protected by two separate passwords, but Clear is in the process of completing a software fix - and other security enhancements - to encrypt the data, which is what we should have done all along, just the way we encrypt all of the other data submitted by applicants. Clear now expects that the fix will be in place within days. Meantime, all airport Clear lane operations continue as normal.

As you may know, our Privacy Policy states that we will notify you of any compromise of your personal information regardless of whether any state statute requires it. This letter is a good example of our policy: no law requires that we notify you of this incident because our investigation of the recovered laptop revealed no breach and because in any event none of your own information was affected. But we think it's good practice to err on the side of good communication with all Clear members, especially when, in this case, we did make a mistake by not making sure that limited portion of information was encrypted.

Please call us toll-free with any questions at (866) 848-2415. Again, we apologize for the confusion.

Sincerely,

Steven Brill
Clear CEO

P.S. A reminder: One of Clears unique privacy features is that all members and applicants are given an identity theft protection warranty which provides that, in the unlikely event you become a victim of identity theft as a result of any unauthorized dissemination of your private information by - or theft from - Clear or its subcontractors, we will reimburse you for any otherwise unreimbursable monetary costs directly resulting from the identity theft. In addition, Clear will, at its own expense, offer you assistance in restoring the integrity of your financial or other accounts. So had there been any actual compromise of your personal information, you would have been additionally protected.


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1 comment:

Joe said...

How can they be sure no-one has the data? Just because the event logs say no-one logged in???

Did they never hear of disk imaging?

I assume from the fact they they are now implementing encryption that it was not encrypted...