Is your firm violating the Data Protection Act or begging for a hack of its Twitter account? (updated)
ThreeUK, who claim to have a 45% share of all mobile traffic in the UK, has a social media presence on Facebook and Twitter. They also have a dangerous practice of requesting customers provide personal details such as full name, phone number, postcode, and date of birth via direct messages (DM) to their support team, e.g., this tweet to a customer:
@ThreeUK Is it taken directly from your bank account? Can you DM over the name, number, DOB, postcode for the account so I can check this. B
— ThreeUKSupport (@ThreeUKSupport) August 19, 2014
Yesterday, Quentyn Taylor tried to educate them that this practice was risky and might even violate Principle 7 of the UK’s Data Protection Act. Principle 7 states:
Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data.
The UK’s Information Commissioner’s Office explains what that means in a guidance on their site. Given how often we have seen corporate Twitter accounts hacked, can ThreeUK or any other corporate Twitter account really provide adequate security for personal information provided by DMs? Or as Quentyn notes, is ThreeUK inviting problems with its practice:
If you request your customers send you pii / passwords via twitter DM you had better hope your acct doesn’t get hacked… #databreach — Quentyn Taylor (@quentynblog) August 19, 2014
In fact I would be surprised if #badguys aren’t looking for corp twitter accts that have requested pii from customers as takeover targets. — Quentyn Taylor (@quentynblog) August 19, 2014
I wouldn’t be surprised, either.
When neither @ThreeUK nor @ThreeUKSupport responded to Quentyn’s tweets, I tweeted:
@ThreeUKSupport I report on breaches. Please let me know when you’re hacked so I can report on stupidity of requesting #PII by DM. @ICOnews
— Dissent Doe (@PogoWasRight) August 19, 2014
So far, though, nothing’s changed, as this tweet to a customer from this morning illustrates:
@AndrewAyr …However if you DM your name, number, DOB and postcode – we can change this for you. >AM — ThreeUKSupport (@ThreeUKSupport) August 20, 2014
Obviously, I’m no expert on the UK’s Data Protection Act, but I do hope the ICO offers some comments on this issue – and that American corporations with Twitter social media teams also think long and hard about the risks here.
Thanks to Quentyn for making me aware of this matter.
UPDATE: @ThreeUKSupport did answer Quentyn later today:
@quentynblog Hi Quentyn – We’ve been assured this is acceptable by our DPA team. Please let us know if you’ve any more questions. >RW
— ThreeUKSupport (@ThreeUKSupport) August 20, 2014
I wonder if the DPA team consulted with the ICO. In any event, even if it is legal (and I’m still not sure it is), it’s a risky behavior that I would recommend avoiding.