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7. Section 155(1) DPA provides that, if the Commissioner is satisfied that a person has failed, or is failing, as described in section 149(2) DPA, the Commissioner may, by written penalty notice, require the person to pay to the Commissioner an amount in sterling specified in the penalty notice.
| legal framework | dpp-law-ltd-monetary-penalty-notice |
8. The types of failure described in section 149(2) DPA include, at section 149(2)(a), "where a controller or processor has failed, or is failing, to comply with... a provision of Chapter II of the UK GDPR... (principles of processing)" and at section 149(2)(c), "where a controller or processor has failed, or is failin... | legal framework | dpp-law-ltd-monetary-penalty-notice |
9. Chapter II UK GDPR sets out the principles relating to the processing of personal data that controllers must comply with. Article 5(1) UK GDPR lists these principles and includes the requirement at Article 5(1)(f) UK GDPR that "personal data shall be... processed in a manner that ensures appropriate security of the ... | legal framework | dpp-law-ltd-monetary-penalty-notice |
10. Article 32 UK GDPR (security of processing) materially provides:
"(1) Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, the controller... | legal framework | dpp-law-ltd-monetary-penalty-notice |
11. Article 33(1) UK GDPR (notification of a personal data breach) provides:
"In the case of a personal data breach, the controller shall without undue delay and, where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the Commissioner, unless the personal data breac... | legal framework | dpp-law-ltd-monetary-penalty-notice |
12. Article 4(1) UK GDPR defines a personal data breach as:
"a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed".
| legal framework | dpp-law-ltd-monetary-penalty-notice |
13. The legal framework for setting penalties is set out in Section V: 'Decision to impose a penalty' below.
| legal framework | dpp-law-ltd-monetary-penalty-notice |
14. This section summarises the relevant background to the findings of infringement. It does not seek to provide an exhaustive account of all the details of the events that have led to the issue of this Penalty Notice.
| background | dpp-law-ltd-monetary-penalty-notice |
15. DPP is a law firm, headquartered in Bootle, England. It employs fewer than 250 staff and has offices in Birmingham, Bootle, Liverpool, London and Tolworth. It specialises in the practice of law related to crime, military, family fraud, sexual offences and actions against the police.3
For Public Release
| background | dpp-law-ltd-monetary-penalty-notice |
16. On 4 June 2022 at approximately 11:30, DPP's email server stopped working and staff had no access to DPP's IT network.4 DPP's in-house IT manager established that all files across its servers had been corrupted.5 DPP's external IT supplier believed that DPP had suffered a ransomware incident, despite not receiving ... | background | dpp-law-ltd-monetary-penalty-notice |
17. The timeline of events leading up to (and following) the Cyber Incident was as follows:
| background | dpp-law-ltd-monetary-penalty-notice |
18. DPP told the Commissioner that, following an analysis of log files by a third party consulting firm, there was evidence to suggest brute force attempts on its network as early as 19 February 2022.7 This occurred a further 12 times and there were in total 400 attempts to gain access to the network.8 The brute force ... | background | dpp-law-ltd-monetary-penalty-notice |
19. An administrator account, sqluser, authenticated onto
10 It is considered likely that an end- user laptop was compromised by the threat actor and subsequently authenticated onto the network. It was this compromise that allowed the threat actor to access sqluser.11 Following this login, there are indicators
that C... | background | dpp-law-ltd-monetary-penalty-notice |
20. DPP's email server stopped working but incoming emails remained available through its firewall. $^{15,16}$ In the early hours, logs show Windows Defender being disabled on and a Virtual Machine backup service stopping on. $^{17}$ Forensic investigators believe at this point the threat actor deployed ransomware. $... | background | dpp-law-ltd-monetary-penalty-notice |
21. During the incident MegaSync and Rclone software were installed on. $^{19}$ The threat actor utilised tools to perform the exfiltration of data from the network. Towards the end of the incident the threat actor utilised the administrator account, sqluser, to download and run an anti-virus which acted as a form of ... | background | dpp-law-ltd-monetary-penalty-notice |
22. DPP reviewed firewall and server logs and it assessed that no data had been exfiltrated. $^{21}$ At the time of the Cyber Incident, DPP's firewall logs did not record egress data flows, it would therefore not have been possible for DPP to ascertain if data had in fact been exfiltrated. DPP established that data wa... | background | dpp-law-ltd-monetary-penalty-notice |
23. The National Crime Agency ("NCA") contacted DPP to advise them that three folders of DPP's data, totalling 32.4Gb, had been published on the dark web. This included court bundles, PDFs, Word documents, photos and video (including police body cam footage) relating to DPP's clients and experts instructed to give evid... | background | dpp-law-ltd-monetary-penalty-notice |
24. 43 days after the Cyber Incident, DPP reported the personal data breach to the Commissioner. DPP were unaware that the loss of access to personal data constituted a personal data breach and therefore that they were required to notify the Commissioner about the Cyber Incident.
| background | dpp-law-ltd-monetary-penalty-notice |
25. Sqluser was an administrator account for a legacy case management system. The account was setup by FWBS Ltd (subsequently acquired by Thomson Reuters) in 2001 for the purposes of automating communication between DPP's servers.\[23\] Despite having a limited role on the network, it had full administrator rights (i.e... | background | dpp-law-ltd-monetary-penalty-notice |
26. DPP stated that they did not conduct a risk assessment to understand the risks associated with the sqluser account because FWBS Ltd told them that the sqluser account was "critical to the data replication of the servers" and because DPP was "reliant on our suppliers for the correct functioning and protection of our... | background | dpp-law-ltd-monetary-penalty-notice |
27. The legacy case management system was taken out of service on 30 April 2019 as DPP changed case management systems to DPS Software Ltd.<sup>29</sup> DPP's service agreement for the sqluser account later came to an end in 2021. However, due to DPP's data retention policy of six years, this system was still operation... | background | dpp-law-ltd-monetary-penalty-notice |
28. The threat actor used sqluser to authenticate onto a remote desktop machine that facilitated access to the legacy case management system (as outlined above in paragraph 19). By compromising the sqluser account the threat actor was able to perform lateral movement across DPP's network.
| background | dpp-law-ltd-monetary-penalty-notice |
29. DPP subsequently moved its complete case management, accounts and email system to a managed hosted environment operated by its case
management software suppliers, The Access Group. $^{31}$ This supplier controls all security aspects including the use of Microsoft 365 MFA.
| background | dpp-law-ltd-monetary-penalty-notice |
30. DPP suspended sqluser from the DPP network and it is now only accessible \(\square\) \(\square\) \(\square\) \(\square\) \(\square\) \(\square\) \(\square\) \(\square\) \(\square\) \(\square\) \(\square\) \(\square\) \(\square\) \(\square\) \(\square\) \(\square\) \(\square\) \(\square\) \(\square\) \(\square\) \(\... | background | dpp-law-ltd-monetary-penalty-notice |
31. In the months following the Cyber Incident, DPP sent notifications to affected data subjects, in line with its obligations under Article 34 UK GDPR.
| background | dpp-law-ltd-monetary-penalty-notice |
2.1. On 25 May 2018, the GDPR entered into force, replacing the previous EU law data protection regime that applied under Directive 95/46/EC ("Data Protection Directive"). The GDPR seeks to harmonise the protection of fundamental rights in respect of personal data across EU Member States and, unlike the Data Protection... | legal framework | marriott-international-inc-mpn-20201030 |
2.2. The GDPR was developed and enacted in the context of challenges to the protection of personal data posed by, in particular:
a. the substantial increase in cross-border flows of personal data resulting from the functioning of the internal market;4 and
b. the rapid technological developments which have occurred du... | legal framework | marriott-international-inc-mpn-20201030 |
2.3. Such developments made it necessary for "a strong and more coherent data protection framework in the Union, backed by strong enforcement, given the importance of creating the trust that will allow the digital economy to develop across the internal market..."6
| legal framework | marriott-international-inc-mpn-20201030 |
2.4. Against that background, the GDPR imposed more stringent duties on controllers and significantly increased the penalties that could be imposed for a breach of the obligations imposed on controllers (amongst others).7
The relevant obligations
| legal framework | marriott-international-inc-mpn-20201030 |
2.6. Chapter 1 GDPR sets out the general provisions. Article 5 of Chapter II GDPR sets out the principles relating to the processing of personal data. Article 5(1) lists the six basic principles that controllers must comply with in processing personal data, including:
| legal framework | marriott-international-inc-mpn-20201030 |
2.6. Article 5(2) GDPR makes it clear that the "controller shall be responsible for, and be able to demonstrate compliance with, paragraph 1 ('accountability')".
| legal framework | marriott-international-inc-mpn-20201030 |
2.7. Chapter IV, Section 1 addresses the general obligations of controllers and processors. Article 24 sets out the responsibility of controllers for taking appropriate steps to ensure and be able to demonstrate that processing is compatible with the GDPR. Articles 28- 29 make separate provision for the processing of d... | legal framework | marriott-international-inc-mpn-20201030 |
2.8. Chapter IV, Section 2 addresses security of personal data. Article 32 GDPR provides:
| legal framework | marriott-international-inc-mpn-20201030 |
1. Taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, the controller and the processor shall implement appropriate technical and organisatio... | legal framework | marriott-international-inc-mpn-20201030 |
2. In assessing the appropriate level of security, account shall be taken in particular of the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
| legal framework | marriott-international-inc-mpn-20201030 |
2.9. Article 32 GDPR applies to both controllers and processors.
Penalties
| legal framework | marriott-international-inc-mpn-20201030 |
2.4.0. Article 83(1) GDPR requires supervisory authorities to ensure that any penalty imposed in each individual case is "effective, proportionate and dissuasive".
| legal framework | marriott-international-inc-mpn-20201030 |
2.11. The principle that penalties ought to be effective, proportionate and dissuasive is a longstanding principle of EU law. The Commissioner is under an EU law obligation to ensure that infringements of the GDPR are penalised in a manner that is effective, proportionate and dissuasive.
| legal framework | marriott-international-inc-mpn-20201030 |
2.4.2. Further, Recital 148 emphasises, inter alia, that "in order to strengthen the enforcement of the rules of this Regulation, penalties including administrative fines should be imposed for any infringement of this Regulation, in addition to, or instead of appropriate measures imposed by the supervisory authority pu... | legal framework | marriott-international-inc-mpn-20201030 |
2.13. Recital 150 provides as follows:
In order to strengthen and harmonise administrative penalties for infringements of this Regulation, each supervisory authority should have the power to impose
administrative fines. This Regulation should indicate infringements and the upper limit and criteria for setting the rel... | legal framework | marriott-international-inc-mpn-20201030 |
2.14. In line with the above, when deciding whether to impose a fine and the appropriate amount of any such fine, Article 83(2) GDPR requires the Commissioner to have regard to the following matters:
(a) the nature, gravity and duration of the infringement taking into account the nature scope or purpose of the process... | legal framework | marriott-international-inc-mpn-20201030 |
2.4.5. Article 83(5) GDPR provides that infringements of the basic principles for processing imposed pursuant to Article 5 GDPR will, in accordance with Article 83(2) GDPR, be subject to administrative fines of up to €20 million or, in the case of an undertaking, up to 4% of its total worldwide annual turnover of the p... | legal framework | marriott-international-inc-mpn-20201030 |
2.4.6. Article 83(4) GDPR provides, inter alia, that infringements of the obligations imposed by Article 32 GDPR on the controller and processer will, in accordance with Article 83(2) GDPR, be subject to administrative fines of up to €10 million or, in the case of an
undertaking, up to $2\%$ of its total worldwide a... | legal framework | marriott-international-inc-mpn-20201030 |
2.17. Article 83(3) GDPR addresses the circumstances in which the same or linked processing operations give rise to infringements of several provisions of the GDPR. It provides that "... the total amount of the administrative fine shall not exceed the amount specified for the gravest infringement".
| legal framework | marriott-international-inc-mpn-20201030 |
2.18. Article 83(8) GDPR provides that the exercise by any supervisory authority of its powers to fine undertakings will be subject to procedural safeguards, including an effective judicial remedy and due process.
Cooperation and consistency
| legal framework | marriott-international-inc-mpn-20201030 |
2.19. Where, as here, the processing in issue is cross- border, Article 56 GDPR makes provision for the designation of a lead supervisory authority. In this case, the Commissioner is acting as the lead supervisory authority. Chapter VII GDPR establishes the regime for ensuring cooperation between lead and other concern... | legal framework | marriott-international-inc-mpn-20201030 |
2.20. Article 60 GDPR provides:
| legal framework | marriott-international-inc-mpn-20201030 |
1. The lead supervisory authority shall cooperate with the other supervisory authorities concerned in accordance with this Article in an endeavour to reach consensus. The lead supervisory authority and the supervisory authorities concerned shall exchange all relevant information with each other.
| legal framework | marriott-international-inc-mpn-20201030 |
2. The lead supervisory authority may request at any time other supervisory authorities concerned to provide mutual assistance pursuant to Article 61 and may conduct joint operations pursuant to Article 62, in particular for carrying out investigations or for monitoring the implementation of a measure concerning a cont... | legal framework | marriott-international-inc-mpn-20201030 |
3. The lead supervisory authority shall, without delay, communicate the relevant information on the matter to the other supervisory authorities concerned. It shall without
delay submit a draft decision to the other supervisory authorities concerned for their opinion and take due account of their views.
| legal framework | marriott-international-inc-mpn-20201030 |
4. Where any of the other supervisory authorities concerned within a period of four weeks after having been consulted in accordance with paragraph 3 of this Article, expresses a relevant and reasoned objection to the draft decision, the lead supervisory authority shall, if it does not follow the relevant and reasoned o... | legal framework | marriott-international-inc-mpn-20201030 |
5. Where the lead supervisory authority intends to follow the relevant and reasoned objection made, it shall submit to the other supervisory authorities concerned a revised draft decision for their opinion. That revised draft decision shall be subject to the procedure referred to in paragraph 4 within a period of two w... | legal framework | marriott-international-inc-mpn-20201030 |
6. Where none of the other supervisory authorities concerned has objected to the draft decision submitted by the lead supervisory authority within the period referred to in paragraphs 4 and 5, the lead supervisory authority and the supervisory authorities concerned shall be deemed to be in agreement with that draft dec... | legal framework | marriott-international-inc-mpn-20201030 |
7. The lead supervisory authority shall adopt and notify the decision to the main establishment or single establishment of the controller or processor, as the case may be and inform the other supervisory authorities concerned and the Board of the decision in question, including a summary of the relevant facts and groun... | legal framework | marriott-international-inc-mpn-20201030 |
8. By derogation from paragraph 7, where a complaint is dismissed or rejected, the supervisory authority with which the complaint was lodged shall adopt the decision and notify it to the complainant and shall inform the controller thereof.
| legal framework | marriott-international-inc-mpn-20201030 |
9. Where the lead supervisory authority and the supervisory authorities concerned agree to dismiss or reject parts of a complaint and to act on other parts of that complaint, a separate decision shall be adopted for each of those parts of the matter. The lead supervisory authority shall adopt the decision for the part ... | legal framework | marriott-international-inc-mpn-20201030 |
10. After being notified of the decision of the lead supervisory authority pursuant to paragraphs 7 and 9, the controller or processor shall take the necessary measures to ensure compliance with the decision as regards processing activities in the context of all its establishments in the Union. The controller or proces... | legal framework | marriott-international-inc-mpn-20201030 |
2.2.1. Article 60(4) refers to the consistency mechanism, which is in Section 2 of Chapter VII GDPR. Article 63 provides that: "In order to contribute to the consistent application of this Regulation throughout the Union, the supervisory authorities shall cooperate with each other and, where relevant, with the Commissi... | legal framework | marriott-international-inc-mpn-20201030 |
1. In order to ensure the correct and consistent application of this Regulation in individual cases, the Board shall adopt a binding decision in the following cases:
(a) where, in a case referred to in Article 60(4), a supervisory authority concerned has raised a relevant and reasoned objection to a draft decision of ... | legal framework | marriott-international-inc-mpn-20201030 |
2. The decision referred to in paragraph 1 shall be adopted within one month from the referral of the subject-matter by a two-thirds majority of the members of the Board. That period may be extended by a further month on account of the complexity of the subject-matter. The decision referred to in paragraph 1 shall be r... | legal framework | marriott-international-inc-mpn-20201030 |
3. Where the Board has been unable to adopt a decision within the periods referred to in paragraph 2, it shall adopt its decision within two weeks following the expiration of the second month referred to in paragraph 2 by a simple majority of the members of the Board. Where the members of the Board are split, the decis... | legal framework | marriott-international-inc-mpn-20201030 |
4. The supervisory authorities concerned shall not adopt a decision on the subject matter submitted to the Board under paragraph 1 during the periods referred to in paragraphs 2 and 3.
| legal framework | marriott-international-inc-mpn-20201030 |
5. The Chair of the Board shall notify, without undue delay, the decision referred to in paragraph 1 to the supervisory authorities concerned. It shall inform the Commission thereof. The decision shall be published on the website of the Board without delay after the supervisory authority has notified the final decision... | legal framework | marriott-international-inc-mpn-20201030 |
6. The lead supervisory authority or, as the case may be, the supervisory authority with which the complaint has been lodged shall adopt its final decision on the basis of the decision referred to in paragraph 1 of this Article, without undue delay and at the latest by one month after the Board has notified its decisio... | legal framework | marriott-international-inc-mpn-20201030 |
2.2.3. Section 115 DPA establishes that the Commissioner is the UK's supervisory authority for the purposes of the GDPR. Section 115 DPA
provides, inter alia, that the Commissioner's powers under Articles 58(2)(i) (the power to impose administrative fines) and 83 GDPR are exercisable only by giving a penalty notice un... | legal framework | marriott-international-inc-mpn-20201030 |
2.24. Section 155(1) DPA provides that, if the Commissioner is satisfied that a person has failed or is failing as described in section 149(2) DPA, the Commissioner may, by written notice (a "penalty notice"), require the person to pay to the Commissioner an amount in sterling specified in the notice.
| legal framework | marriott-international-inc-mpn-20201030 |
2.25. Section 149(2) DPA provides:
(1) The first type of failure is where a controller or processor has failed, or is failing, to comply with any of the following -
(a) a provision of Chapter II of the GDPR or Chapter 2 of Part 3 or Chapter 2 of Part 4 of this Act (principles of processing);
(b) ...
(c) a provision... | legal framework | marriott-international-inc-mpn-20201030 |
2.26. Section 155 DPA sets out the matters to which the Commissioner must have regard when deciding whether to issue a penalty notice and when determining the amount of the penalty.
| legal framework | marriott-international-inc-mpn-20201030 |
2.27. Section 155(2) DPA provides that, subject to subsection (4), when deciding whether to give a penalty notice to a person and determining the amount of the penalty, the Commissioner must have regard to the matters listed in Article 83(1) and (2) GDPR.
| legal framework | marriott-international-inc-mpn-20201030 |
2.28. Schedule 16 includes provisions relevant to the imposition of penalties. Paragraph 2 makes provision for the issuing of notices of intent to impose a penalty, as follows:
(1) Before giving a person a penalty notice, the Commissioner must, by written notice (a "notice of intent") inform the person that the Commis... | legal framework | marriott-international-inc-mpn-20201030 |
2.89. Paragraph 5 sets out the required contents of a penalty notice, in accordance with which this Penalty Notice has been prepared.
Guidance
| legal framework | marriott-international-inc-mpn-20201030 |
2.30. Section 160 DPA requires the Commissioner to produce and publish guidance about how she intends to exercise her functions. With respect to penalty notices, such guidance is required to include:
(a) provision about the circumstances in which the Commissioner would consider it appropriate to issue a penalty notice... | legal framework | marriott-international-inc-mpn-20201030 |
2.81. Pursuant to section 161 DPA, the Commissioner's first guidance documents issued under section 160(1) DPA had to be consulted upon and laid before Parliament by the Secretary of State in accordance with the procedure set out in that section. Thereafter, in issuing any altered or replacement guidance, the Commissio... | legal framework | marriott-international-inc-mpn-20201030 |
2.82. On 4 May 2018, the Commissioner opened a consultation process on how the Commissioner planned to discharge her regulatory powers under the DPA. The consultation attracted responses from across civil society, commentators, and industry (including the finance and insurance, online technology and telecoms, and chari... | legal framework | marriott-international-inc-mpn-20201030 |
2.83. Pursuant to section 160(1) DPA, the Commissioner published her RAP on 7 November 2018. Under the hearing "Aims", the RAP explains that it seeks to:
- "Set out the nature of the Commissioner's various powers in one place and to be clear and consistent about when and how we use them";- "Ensure that we take fair, p... | legal framework | marriott-international-inc-mpn-20201030 |
2.84. The objectives of regulatory action are set out at page 6 of the RAP, including:
- "To respond swiftly and effectively to breaches of legislation which fall within the ICO's remit, focussing on [inter alia] those adversely affecting large groups of individuals".- "To be effective, proportionate, dissuasive and c... | legal framework | marriott-international-inc-mpn-20201030 |
2.85. The RAP explains that the Commissioner will adopt a selective approach to regulatory action.11 When deciding whether and how to respond to breaches of information rights obligations she will consider criteria which include the following:
"the nature and seriousness of the breach or potential breach"; "where rele... | legal framework | marriott-international-inc-mpn-20201030 |
2.86. The RAP explains that, as a general principle, "more serious, high- impact, intentional, wilful, neglectful or repeated breaches can expect stronger regulatory action".13
| legal framework | marriott-international-inc-mpn-20201030 |
2.87. Pages 24- 25 of the RAP identify the circumstances in which the issuing of a Penalty Notice will be appropriate. They explain, inter alia, that in "... considering the degree of harm or damage we may consider that, where there is a lower level of impact across a large number of individuals, the totality of that d... | legal framework | marriott-international-inc-mpn-20201030 |
2.38. The process the Commissioner will follow in deciding the appropriate amount of penalty to be imposed is described from page 27 onwards. In particular, the RAP sets out the following five- step process:
a. Step 1. An 'initial element' removing any financial gain from the breach.
b. Step 2. Adding in an element ... | legal framework | marriott-international-inc-mpn-20201030 |
3.4. Marriott acquired Starwood in September 2016. During the acquisition process, Starwood shareholders received 0.8 shares of Marriott, as well as $21 per Starwood common stock. After the acquisition, the Marriott and Starwood computer systems were kept
separate, and they remained separate throughout the relevant pe... | background | marriott-international-inc-mpn-20201030 |
3.2. Upon acquisition, but prior to decommissioning the Starwood network, Marriott made enhancements to the security of Starwood's existing IT network.
| background | marriott-international-inc-mpn-20201030 |
3.3. During the acquisition process, Marriott states that it was only able to carry out limited due diligence on the Starwood data processing systems and databases. For the avoidance of any doubt, the Commissioner is not making any finding of infringement in respect of the period between Marriott's acquisition of Starw... | background | marriott-international-inc-mpn-20201030 |
3.4. This Penalty Notice concerns the extent to which, after the GDPR came into effect on 25 May 2018, Marriott adequately prepared the Starwood systems to protect personal data. In particular, it is necessary to assess whether the Attack disclosed a failure to ensure compliance with Articles 5.4(f) and 32 of the GDPR ... | background | marriott-international-inc-mpn-20201030 |
3.5. The integration of Starwood into the Marriott hotels group began following the acquisition. While this involved the transferring of data from the Starwood systems to the Marriott network, the systems accessed by the Attacker remained segregated from the Marriott network.
| background | marriott-international-inc-mpn-20201030 |
3.6. As a result, the Attack did not involve access to the wider Marriott network and the Attacker would not have had access to personal data that was processed only on non- Starwood systems. The planned migration and the decommissioning of the Starwood
systems was expedited by Marriott after discovery of the Attack a... | background | marriott-international-inc-mpn-20201030 |
3.7. What follows is a summary of the key stages of the Attack.
Pre- acquisition infiltration of the Starwood IT systems
| background | marriott-international-inc-mpn-20201030 |
3.8. The Attacker installed a web shell on a device within the Starwood network on 29 July 2014. This device was used to support an Accolade software application. That application was used by Starwood to allow employees to request changes to any content of Starwood's website.
| background | marriott-international-inc-mpn-20201030 |
3.9. The installation of a web shell on the server gave the Attacker the ability to remotely access the system, therefore allowing for the accessing and editing of the contents of that system. This access was exploited in order to install Remote Access Trojans ("RATs") - malware which enables remote administrator contr... | background | marriott-international-inc-mpn-20201030 |
3.4.0. On an undetermined date, the Attacker installed and executed "Mimikatz". This is a post- exploitation tool which allows login credentials temporarily stored in the system memory to be harvested. It scanned the server for all the usernames and passwords stored in this manner in the system and allowed the Attacker... | background | marriott-international-inc-mpn-20201030 |
3.11. On 15 April 2015, a file named "Reservation_Room_sharer.dmp" was created on a Starwood device. This file could have been created
by the Attacker with a view to exfiltrating all the data contained in the table at once. $\mathsf{e}^{6}$
| background | marriott-international-inc-mpn-20201030 |
3.4.2. On 21 April 2015, a file named "Consumption_Roomtype.dmp" was created. This file could have been created by the Attacker with a view to exfiltrating all the data contained in this table at once. $\mathsf{e}^{7}$
| background | marriott-international-inc-mpn-20201030 |
3.4.3. On 17 May 2016, a file named "reservation_Room_Sharer.dmp" was created. This file could have been created by the Attacker with a view to exfiltrating all the data contained in this table at once. $\mathsf{e}^{8}$
| background | marriott-international-inc-mpn-20201030 |
3.4.4. Following Marriott's acquisition of Starwood, on 31 December 2016 or 1 January 2017, $^{19}$ additional malware which searched devices for payment card data, known as "memory- scraping malware", was installed on multiple Starwood Devices. Marriott believes, but cannot be certain, that this action was carried ou... | background | marriott-international-inc-mpn-20201030 |
3.4.5. On 7 September 2018, the Attacker performed a "count" on the "Guest_Master_profile" table, which would have told the Attacker how many rows the table contained.
| background | marriott-international-inc-mpn-20201030 |
3.4.6. This count triggered an alert on the Guardiansystem placed on the database ("the Guardians Alert"). Such alerts were applied to tables which included card details. $\mathsf{e}^{0}$ The other tables mentioned above did not contain payment card information and were not protected by Guardiansoftware. Thus, no alar... | background | marriott-international-inc-mpn-20201030 |
3.4.7. The Attacker also exported the "Guest_Master_profile" table into a "dmp" file (as had previously occurred in relation to the other tables referred to above).
Discovery and reporting of the breach
| background | marriott-international-inc-mpn-20201030 |
3.4.8. On 8 September 2018, Accenture, the company managing the Starwood Guest Reservation Base, contacted Marriott's IT team regarding the Guardium alert of the previous day. This was the first Guardium alert relating to the Attack that Marriott had received since its acquisition of Starwood.
| background | marriott-international-inc-mpn-20201030 |
3.4.9. On 10 September 2018, the "PP_Master" table was exported to a "dmp" file on the Starwood system.
| background | marriott-international-inc-mpn-20201030 |
3.4.10. Following the Guardium alert, on 9/10 September 2018, Marriott instigated its Information Security and Privacy Incident Response Plan. On 12 September 2018, Marriott began to deploy real- time monitoring and forensic tools on 70,000 legacy Starwood devices. The purpose of this measure was to monitor the local s... | background | marriott-international-inc-mpn-20201030 |
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