Background

Singapore University of Social Sciences (the “Organisation”) notified the Personal Data Protection Commission (the “Commission”) on 2 January 2024 of a data security incident where the Organisation discovered suspicious activities on a server, including the creation of unauthorised admin accounts and the installation of unauthorised software (the “Incident”).

Investigations revealed that the Threat Actor (“TA”) had exploited a vulnerability in the Capstone Project Portal web application, which was designed to facilitate selection and archival of students’ independent research projects.

As a result of the Incident, the personal data of 1,823 individuals, who were the Organisation’s current students, terminated/withdrawal students, graduated alumni, project supervisor/tutor, current staff, and ex-staff, was affected. The types of personal data affected included a combination of the name, email address, contact number, matriculation number, tutor’s ID number, name of programme enrolled/supervised, password of Capstone Project Portal, photograph.

Upon discovery of the Incident, the Organisation took prompt remedial actions including isolating the Affected Servers and blocking bad reputation IP addresses and enforcing account lockout after six failed attempts. Additionally, the Organisation assessed the potential vulnerability and cybersecurity risks of its applications and devices, implemented continuous live scanning, reviewed, and tightened firewall rules to prohibit access to internal IPs from unknown or untrusted IP addresses and block any known potential web exploitation attempts.

Voluntary Undertaking

Having considered the circumstances of the case, the Commission accepted a voluntary undertaking (the “Undertaking”) from the Organisation to improve its compliance with the Personal Data Protection Act 2012 (the “PDPA”). The Undertaking was executed on 11 June 2024.

As part of the Undertaking, Singapore University of Social Sciences will be implementing the following:

(a) Review and assessment of its IT application and asset inventory;

(b) Implementation of web application firewall;

(c) Review and strengthening backup according to 3-2-1 backup rule;

(d) Optimisation of SIEM alert rules;

(e) Enhancement of network segmentation and restriction; and

(f) Independent review and strengthening of firewall rules.

The Commission will verify the Organisation’s compliance with the Undertaking. If the Organisation fails to comply with any terms of the Undertaking, the Commission may issue a direction so as to ensure the Organisation’s compliance with the Undertaking.