Rarely a week goes by without news of a data security breach hitting the headlines, with issues such as the global WannaCry ransomware attack – which crippled parts of the NHS – and our own industry-specific PayAsUGym attack in December 2016 heightening fears for the wider industry.
Unfortunately, this increased awareness isn’t leading to action to improve matters. Furthermore, ignorance about basic data security principles and obligations is placing the industry at significant risk of everything from accidental misadventure to financial fraud, with the repercussions ranging from regulatory fines and brand damage to business failure.
Data vulnerability
Leisure and gym operators are custodians of a huge volume of detailed personal information about members and customers, making our industry not only a soft target, but also an attractive one.
To safeguard valuable information, think about your data assets. What information do you hold on your customers? Where is it stored? Is it up to date? Is it still required? Is it digital, or are paper records still in use? Are your employees accessing information via their own mobile devices?
Data breaches occur in many forms, including password theft, physical attacks and the biggest threat of all – user error.
Common user error breaches include obvious examples, such as incorrect handling of credit card data, and less obvious examples, such as paper-based customer information being stored in unlocked filing cabinets.
Routine tasks undertaken by front of house staff are often conducted without data safeguards in place and in many cases, too little staff training is provided on data security protocols and their importance, leaving operators vulnerable.
This situation is complicated by the nature of the industry. For example, staff turnover makes it challenging to ensure training is given to all staff who are handling customer data. The result is inadequate security, which jeopardises both the customer and the operator.
Better Guidance
In our unregulated industry there has historically been little or no guidance provided to staff regarding the safeguarding of information.
In addition, although existing legislation – such as the Data Protection Act (DPA), and the Payment Card Industry Data Security Standards (PCI DSS) – requires adherence to very specific data security processes and policies, many in the industry would be hard pressed to demonstrate compliance, leaving them in a highly vulnerable position.
The situation will become even more challenging in May 2018, when the EU’s new General Data Protection Regulation (GDPR) comes into effect, bringing with it higher penalties and even more stringent requirements regarding information security, as well as the need to inform any individual affected by a data breach within 72 hours.
In short, GDPR demands the attention of all businesses and operators who hold customer data of any kind.
Business Implications
The UK Payment Card Industry Security Standards Council (PCI SSC) has warned that UK businesses could face up to £122bn in penalties for data breaches when the GDPR comes into effect. It has also stated that fines are likely to be dwarfed by the reputational damage incurred by data breaches.
If customers lose confidence in an establishment’s ability to safeguard personal data, then the online portals and payment processes that have streamlined our businesses so effectively over recent years will be put at risk.
Creating a New Ethos: Confidentiality, Availability & Integrity
So now is the time to take action. Only by considering every piece of information in line with three guiding principles – confidentiality, availability and integrity – can you begin to protect your data.
• Confidentiality
Assurance of data privacy is achieved by ensuring it’s only accessed by authorised individuals and that excellent access controls and good internal processes are in place for the use of paper-based documentation.
• Availability
This demands that data is available whenever it’s needed – a ransomware attack, for example, denies this.
• Integrity
Achieving data integrity is all about ensuring it’s accurate and up to date.
There are two areas of GDPR where focus is needed. One is consent, which imposes robust criteria on you to obtain permission from individuals for the processing of their data. The second is data retention, and the individual’s ‘right to be forgotten’.
These two areas need careful assessment to ensure there’s a clear case for holding data for specific time periods and that consent has been given to do so.
Next steps
The coming of the GDPR is a real opportunity for leisure and health and fitness businesses to embrace the chance to make huge improvements to the way their extremely valuable data is stored and handled.
It's also the time to expand the current view of information beyond that which is held electronically to include all information assets in the business, both digital and paper-based. Finally, it's time to embed best practice into all daily operations. This includes improving physical infrastructure and creating a robust, ethical security culture, that protects customer data, for the long-term.
To learn more about how Legend has helped its customers get ready for the arrival of the fast-approaching GDPR legislation, please visit our website at: www.legendware.co.uk/accreditations
