SLIMPAY is a licensed payment institution that provides customers with recurring payment options. Based in Paris, this subscription payment services firm was fined €180,000 by the French CNIL regulatory authority after it was discovered that sensitive client data had been stored on a publicly accessible server for five years by the firm.
The company bills itself as a leader in subscription recurring payments, and it offers an API and processing service to handle such payments on behalf of clients such as Unicef, BP, and OVO Energy, to mention a few. It appears to have conducted an internal research project on an anti-fraud mechanism in 2015, during which it collected personal data from its client databases for testing purposes. Real data is a useful way to confirm that development code is operating as intended before going live, but when dealing with sensitive data like bank account numbers, extreme caution must be exercised to avoid violating data protection requirements.
In 2020, the CNIL conducted an inquiry on the company SLIMPAY and discovered a number of security flaws in their handling of customers' personal data. The restricted committee - the CNIL body in charge of applying fines - effectively concluded that the corporation had failed to comply with several GDPR standards based on these elements. Because the data subjects affected by the incident were spread across many European Union nations, the CNIL collaborated with four supervisory agencies (Germany, Spain, Italy, and the Netherlands).
THE BREAKDOWNS
1. Failure to comply with the requirement to provide a formal legal foundation for a processor's processing operations (Article 28 of the GDPR)
SLIMPAY's agreements with its service providers do not include all of the terms necessary to ensure that these processors agree to process personal data in accordance with the GDPR.
2. Failure to protect personal data from unauthorized access (Article 32 of the GDPR)
Access to the server was not subject to any security controls, according to the restricted committee, and it could be accessed from the Internet between November 2015 and February 2020. More than 12 million people's civil status information, postal and e-mail addresses, phone numbers, and bank account numbers (BIC/IBAN) were all hacked.
3. Failure to protect personal data from unauthorized access (Article 32 of the GDPR)
The CNIL determined that the risk associated with the breach should be considered high due to the nature of the personal data, the number of people affected, the possibility of identifying the people affected by the breach from the accessible data, and the potential consequences for the people concerned.
