UK: ICO fines HIV support network for repeated e-mail gaffes exposing individuals’ names
The Information Commissioner’s Office has fined the Bloomsbury Patient Network (BPN) after it inadvertently revealed the identities of HIV patients on two occasions due to placing all addresses for a newsletter distribution list in the “to” field instead of the “bcc” field.
BPN was fined £250, which may seem somewhat mild considering the potential embarrassment to individuals.
According to the monetary penalty notice:
On or about 17 February 2014, a Patient Representative sent an e-mail newsletter to between 60 and 200 service users on BPN’s distribution list who all had HIV. The e-mail addresses were entered into the “to” field instead of the blind carbon copy (“bcc”) field. The recipients of the e-mail could therefore see the e-mail addresses of all the other recipients.
The Patient Representative agreed to be more careful when sending future e-mails. However, there was no formal guidance or training to remind the Patient Representative to double check that the group e- mail addresses were entered into the correct field.
Further, BPN did not replace the e-mail account it was using with an account that could send a separate e-mail to each service user on the distribution list.
On 6 May 2014, the same Patient Representative sent an e-mail to 200 service users on BPN’s distribution list. The group e-mail addresses were again entered into the “to” field in error. The Commissioner understands that 56 out of the 200 group e-mail addresses contained the full or partial names of service users.
Five service users filed formal complaints with the ICO about the disclosure.