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Data breach·Starter·Mixed audience

A spreadsheet of staff data sent to the wrong person

The prompt — read this to the room

An HR coordinator meant to email a salary review spreadsheet to the payroll provider. Autocomplete picked a similar name at a recruitment agency instead. The file holds names, salaries, home addresses and sickness absence notes for 340 employees. An hour later the recipient replied: 'I think this was meant for someone else.' The coordinator is panicking and has asked a friend in IT to 'just recall it'. It is now 16:30 on a Thursday. What happens next, and who needs to know?

Total duration
1 h
People to involve
5
Best fit
Any sector

Who to involve

Most important first.

  • Privacy officer / DPO
  • HR
  • Legal counsel
  • CISO / Head of security
  • IT operations

What it tests

  • Run a breach risk assessment on an accidental disclosure that includes health data.
  • Decide whether the GDPR Art. 33 72-hour notification applies, and record the reasoning either way.
  • Get a credible deletion confirmation from the recipient, including any onward copies.
  • Fix the process, not just the person, and treat the employee fairly.

Outline of activities

  1. 1Containing the disclosure
  2. 2Assessing the risk to the 340 people
  3. 3To notify or not, and writing it down
  4. 4Telling staff and fixing the process
  5. 5Hot wash

Run sheet (Pro)

The facilitator's timeline of execution, the detailed steps for running the session and the questions to ask each person.

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A spreadsheet of staff data sent to the wrong person — Tabletop Exercise · PlayCISO