Overview
User data correlation can be a powerful tool to harness the power of large amounts of data to benefit both users and the organizations that service those users. In order to process and use the data in this way, the data of different users must often be processed and/or stored together. The danger of processing data in this way means that a breach into one user’s data compromises the data of the others. This creates a risk of data breaches due to developer coding errors and inadvertent interactions between different applications and software that could expose organizations to investigations or litigation. As such, it is important for organizations that process and store user data in this way to implement proper procedures and safeguards to protect themselves from data breaches.
Facebook discovered such a data breach in 2013 and the Privacy Commissioner of Canada (“the Commissioner”) investigated the cause and aftermath of the breach.[1] While the Commissioner ultimately decided that Facebook’s remedial measures were sufficient, the question remains whether that decision would be upheld if a lawsuit was brought in Court for negligence, and what additional but practical technical measures Facebook could have implemented to avoid being found negligent.
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