The Office of the Australian Information Commissioner (OAIC) began an investigation of Multicard last February when it was informed by the Office of Transport Security that personal information concerning people who had applied for Maritime Security Identity Cards (MSIC) through Multicard was available online.
An MSIC identifies a person who has met the minimum security requirements to work unescorted or unmonitored in a maritime security zone. It does not authorise access to the zones.
The problem stemmed from the way Multicard stored the personal information on a publicly accessible web server that was incorrectly configured to allow directory browsing of the relevant folder and that did not use the robots.txt file to instruct search engines to not index the folder.
It is not possible to determine from the OAIC report the number of individuals whose information was disclosed, but the data included around 8,800 first and last names and dates of birth, and more than 7,300 addresses.
More than 28,800 photographs were also accessible, and the entire set of files stored in the folder "was accessed and downloaded in its entirety by at least one unidentified unauthorised third party," according to the OAIC report.
The Australian Privacy Commissioner concluded that Multicard had contravened National Privacy Principles 2.1 (disclosure of personal information) and 4.1 (taking reasonable steps to secure personal information). The National Privacy Principles have since been replaced by the Australian Privacy Principles.
The company has already taken a number of rectification steps, including disabling directory browsing, implementing access controls, penetration testing, regular security scans and audits, and engaging a privacy consultancy firm. Further steps are under way.
The Commissioner expressed concern that Multicard did not investigate who accessed the folder and why, and recommended that the company undertake such an investigation.
Another request was that the company's independent auditor certify that the planned remediation steps have been implemented.
"The OAIC's investigation found that Multicard failed to implement a number of basic security measures which resulted in a large amount of personal information being exposed. This was a data breach that could have easily been avoided," said Australian Privacy Commissioner Timothy Pilgrim.
"I urge all organisations to carefully consider what security safeguards they have in place to protect the personal information they hold.
"It was disappointing to find that, amongst other issues, there was no requirement for a password, username or other authenticator to establish the identity of the user before the information could be accessed."