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Failure to implement correct processes leads to $80m fine


In the US, Capital One has been fined $80m for failing to implement effective risk assessment processes.

Capital One’s failure to implement effective risk assessment processes occurred before the company migrated significant information technology operations to a public cloud environment. It was also criticised for not correcting the deficiencies in a timely manner.

The fine follows the data breach suffered by Capital One in March 2019, which involved the compromise of personal data belonging to existing credit card customers and applicants for credit card products.

A data protection risk assessment, known as a DPIA (Data Protection Impact Assessment), is required by the GDPR as a way of helping organisations to identify and minimise the data protection risks of a project.

Organisations must conduct a DPIA when processing data that, if disclosed, could represent a high risk to individuals. Something Captial One failed to do.


Although this is not a fine issued as a result of contravening the GDPR, the amount of the fine reflects the need for effective risk assessment practices to be undertaken to ensure appropriate security measures are put in place – which is also a key requirement of the GDPR.

Norm’s lawyer-led data protection team are always on hand to help identify when a DPIA would be appropriate. If this is something your organisation would find useful please click here to find out more about norm’s DPaaS offerings.

Appointing NormCyber as our virtual DPO has given Ferrero the best of both worlds – access to data protection experts who understand what we stand for as a business, without the hefty overheads usually associated with appointing an in-house DPO.

Harpreet Thandi
Regional Counsel, UK & Ireland, Ferrero

We were looking for a virtual DPO service that offered all of the benefits of a fully qualified data protection lawyer, without the overheads of an in-house hire. The DPaaS solution from norm. has been invaluable in helping us to ensure we respect the integrity of our customers’ personal information, while using it to continue to deliver differentiated products and services which support our growing customer base.

Mike Whitfield, Compliance Manager

CSaaS allows me to step away from multi-vendor management as the Security Operations Centre coordinates all of the technology for me.

David Vincent, CTO

We were in the market for an independent Data Protection Officer service that was well versed with both UK and EU regulators. We’re thrilled to have acquired this service knowing that an expert is available 24/7.

Suzanne McCabe, Head of Project Management
James Hambro & Partners

Norm’s penetration testing layer, along with the suite of CSaaS modules has enabled MA to exceed all its audit requirements for its major clients.

Rob Elisha, ICT and CRM Manager
Montreal Associates

The speed of your Data Protection Officer’s response was very impressive – it was far quicker than I would have expected even from an in-house DPO

Will Blake, Director of Technology and Analytics
CRU Group