Key points to take from the reprimand are:
- Lack of multi-factor authentication
- Inadequate account lockout policy
- No clear Bring your own device policy
- Implementing a comprehensive set of policies
The report also notes that the company held personal data for longer than was necessary and that there were not appropriate organisational measures in place to ensure confidentiality and integrity of their systems.
View the full reprimand details here: ICO Reprimand Optionis Group Limited
We would advise all organisations however large or small to have these security measures in place as a step to being cyber resilient.
Our Knowledge Bank covers all of the above and more:
October is Cyber Security Awareness Month: 14. Access Control (MFA)
Records Management Best Practice Area
pdf DPE Model Bring Your Own Device Policy
(15 KB) Information & Cyber Security Best Practice Area
Review our Cyber Security Checklist (you will need a DPE subscription to be able to view):
What to do in the event of a Cyber Attack
Incidents or attacks where any security breaches may have taken place, or other damage was caused, should be reported to an external body.
The SLT digital lead will be responsible for assigning someone to report any suspicious cyber incidents or attacks. This person will need to report this to:
- Action Fraud on 0300 123 2040, or the Action Fraud website
- the DfE sector cyber team at
This email address is being protected from spambots. You need JavaScript enabled to view it.
You may also need to report to:
- the NCSC website if the incident or attack causes long term school closure, the closure of more than one school, or serious financial damage
- the ICO website within 72 hours, where a high risk data breach has or may have occurred
- your cyber insurance provider (if you have one), such as risk protection arrangement (RPA)
- Jisc, if you are a part of a further education institution
You must act in accordance with:
- Action Fraud guidance for reporting fraud and cyber crime
- Academy Trust Handbook Part 6, if you are part of an academy trust
- ICO requirements for reporting personal data breaches
Police investigations may find out if any compromised data has been published or sold and identify the perpetrator.
m. Preserving evidence is as important as recovering from the crime.
Forward suspicious emails to