Zurich Insurance UK not only lost 46,000 customer records, it took one year to discover the loss. The fact that the loss took place during what should have been a routine outsourcing operation just makes the matter worse. At £2.27m (reduced from £3.25m by agreeing to early settlement), the Zurich Insurance UK data loss works out to have cost the company nearly £50 per record – and that’s without the management time spent on dealing with the FSA investigation and the undoubted negative publicity which the report will generate.

The basics of data protection are still obvious: first, you have to be aware of the fact that you are in possession of personal data, and you have to be aware of how and where it is being processed. Then you have to take some basic steps: apply encryption, apply access control policies, apply secure transmission and receipt procedures (surely, after the HMRC CD-Rom fiasco most organisations would have got to grips with this idea?) and don’t allow personal data to be downloaded to USBs or other portable devices.

I covered exactly these basics at the most recent Data Privacy & Laws conference (video due out shortly, apparently) and the general response was: wouldn’t it be nice if we could get top management to understand that this is what we need to do? Well, perhaps £2.27m will help financial companies focus (although the long history of fines on financial sector companies for failing to protect personal data argues otherwise) better on this key responsibility of theirs.