The Information Commissioner’s Office (ICO) has fined Advanced Computer Software Group Ltd (Advanced) £3.07m for security failings that put the personal information of 79,404 people at risk.
Advanced provides IT and software services to organisations, including the NHS and other healthcare providers, and processes people’s personal information on behalf of these organisations as their data processor.
The fine, which is the regulator’s first to a data processor, relates to a ransomware incident in August 2022. Hackers accessed certain systems of Advanced’s health and care subsidiary via a customer account that did not have multi-factor authentication (MFA).
The cyber-attack was widely reported at the time, with reports of disruption to critical services such as NHS 111, and other healthcare staff unable to access patient records.
The investigation found that personal information belonging to 79,404 people was taken, including details of how to gain entry into the homes of 890 people who were receiving care at home.
The ICO’s investigation concluded that Advanced’s health and care subsidiary did not have the appropriate technical and organisational measures in place to keep its health and care systems fully secure prior to the 2022 incident – including gaps in the deployment of MFA, a lack of comprehensive vulnerability scanning and inadequate patch management.
“The security measures of Advanced’s subsidiary fell seriously short of what we would expect from an organisation processing such a large volume of sensitive information,” John Edwards, Information Commissioner, said.
“While Advanced had installed multi-factor authentication across many of its systems, the lack of complete coverage meant hackers could gain access, putting thousands of people’s sensitive personal information at risk.
“People should never have to think twice about whether their medical records are in safe hands. To use services with confidence, they must be able to trust that every organisation coming into contact with their personal information – whether that’s using it, sharing it or storing it on behalf of others – is meeting its legal obligations to protect it.
“With cyber incidents increasing across all sectors, my decision today is a stark reminder that organisations risk becoming the next target without robust security measures in place.
“I urge all organisations to ensure that every external connection is secured with MFA today to protect the public and their personal information – there is no excuse for leaving any part of your system vulnerable.”
The regulator announced its provisional intention to fine Advanced £6.09m in August 2024. Advanced then submitted representation on the provisional decision, which have been ‘carefully considered by the ICO.’
Several factors from these representations led to a reduction in the fine, including Advanced’s proactive engagement with the NCSC, the NCA, and the NHS in the wake of the attack and other steps taken to mitigate the risk of those impacted.
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The ICO and Advanced have now agreed to a voluntary settlement. Advanced has acknowledged the ICO’s decision to impose a reduced fine and agreed to pay a final penalty of £3,076,320 without appealing.
John Edwards added: “I welcome the settlement with Advanced which concludes our investigation into this incident, providing regulatory certainty to organisations without the delay and cost of an appeals process.”
Organisations must be taking proactive steps to assess and mitigate risks, such as implementing comprehensive MFA (or an equivalent measure), regularly scanning for vulnerabilities and keeping systems up to date with the latest security patches.
The ICO has detailed guidance on protecting systems from ransomware attacks, as well as guidance on the responsibilities of data processors and controllers.
Last year, the ICO shared lessons learnt from common security mistakes and called on organisations to do more to combat the growing cyber threat.
The full monetary penalty notice will be published on the ICO website when the embargo lifts at 00:01 on Thursday 27 March.





