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September 20, 2022

Modern Extortion: Detecting Data Theft From the Cloud

Darktrace highlights a handful of data theft incidents on shared cloud platforms, showing that cloud computing can be a vulnerable place for modern extortion.
Inside the SOC
Darktrace cyber analysts are world-class experts in threat intelligence, threat hunting and incident response, and provide 24/7 SOC support to thousands of Darktrace customers around the globe. Inside the SOC is exclusively authored by these experts, providing analysis of cyber incidents and threat trends, based on real-world experience in the field.
Written by
Adrianne Marques
Senior Research Analyst
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20
Sep 2022

Ransomware Industry

The ransomware industry has benefitted from a number of factors in recent years: inadequate cyber defenses, poorly regulated cryptocurrency markets, and geopolitical tensions have allowed gangs to extort increasingly large ransoms while remaining sheltered from western law enforcement [1]. However, one of the biggest success stories of the ransomware industry has been the adaptability and evolution of attacker TTPs (tactics, techniques and procedures). The WannaCry and NotPetya attacks of 2017 popularized a form of ransomware which used encryption algorithms to hold data to ransom in exchange for a decryption key. Last year in 2021, almost all ransomware strains evolved to use double extortion tactics: holding stolen data to ransom as well as encrypted data [2]. Now, some ransomware gangs have dropped encryption entirely, and are using data theft as their sole means of extortion. 

Using data theft for extortion is not new. In 2020 the Finnish psychotherapy center Vastaamo had over 40,000 patient records stolen. Impacted patients were told that their psychiatric transcripts would be published online if they failed to pay a Bitcoin ransom. [3]. A later report by BlackFog in May 2021 predicted data theft extortion would become one of the key emerging cybersecurity trends that year [4]. Adoption of offline back-ups and endpoint detection had made encryption harder, while a large-scale move to Cloud and SaaS platforms offered new vectors for data theft. By moving from data encryption to data exfiltration, ransomware attackers pivoted from targeting data availability within the CIA triad (Confidentiality, Integrity, Availability) to threatening data confidentiality.

In November 2021, Darktrace detected a data theft incident following the compromise of two SaaS accounts within an American tech customer’s Office365 environment. The client was a longstanding user of Darktrace DETECT/Network, and was in the process of expanding their coverage by trialing Darktrace DETECT+RESPOND/ Apps + Cloud.

Attack Overview

On November 23rd 2021, an Ask the Expert (ATE) ticket was raised prompting investigation into a breached SaaS model, ‘SaaS / Access / Unusual External Source for SaaS Credential Use’, and the activities of a user (censored as UserA) over the prior week.

1. Office365: UserA 

The account UserA had been logging in from an unusual location in Nigeria on November 21st. At the time of the incident there were no flags of malicious activity from this IP in widely used OSINT sources. It is also highly probable the attacker was not located in Nigeria but using Nigerian infrastructure in order to hide their true location. Regardless, the location of the login from this IP and ASN was considered highly unusual for users within the customer’s digital estate. The specific user in question most commonly accessed their account from IP ranges located in the US.

Figure 1: In the Geolocation tab of the External Sites Summary on the SaaS Console, UserA was seen logging in from Nigeria when previous logins were exclusively from USA

Further investigation revealed an additional anomaly in the Outlook Web activity of UserA. The account was using the Firefox browser to access their account for the first time in at least 4 weeks (the maximum period for which the customer stored such data). SaaS logs detailing the access of confidential folders and other suspicious actions were identified using the Advanced Search (AS) query:

@fields.saas_actor:"UserA@[REDACTED]" AND @fields.saas_software:"Firefox"

Most actions were ‘MailItemsAccessed’ events originating from IPs located in Nigeria [5,6] and one other potentially malicious IP located in the US [7].

‘MailItemsAccessed’ is part of the new Advanced Audit functionality from Microsoft and can be used to determine when email data is accessed by mail protocols and clients. A bind mail access type denotes an individual access to an email message [8]. 

Figure 2: AS logs shows UserA had not used Firefox to access Office365 for at least 4 weeks prior to the unusual login on the 21st November

Below are details of the main suspicious SaaS activities: 

·      Time: 2021-11-21 09:05:25 - 2021-11-22 16:57:39 UTC

·      SaaS Actor: UserA@[REDACTED]

·      SaaS Service: Office365

·      SaaS Service Product: Exchange

·      SaaS Software: Firefox

·      SaaS Office365 Parent Folders:

          o   \Accounts/Passwords
          o   \Invoices
          o   \Sent Items
          o   \Inbox
          o   \Recoverable Items\Deletions

·      SaaS Event:

          o   MailItemsAccessed
          o   UserLoggedIn
          o   Update

·      SaaS Office365 Mail Access Type: Bind (47 times)

·      Source IP addresses:

          o   105.112.59[.]83
          o   105.112.36[.]212
          o   154.6.17[.]16
          o   45.130.83[.]129

·      SaaS User Agents: 

          o   Client=OWA;Mozilla/5.0 (Windows NT 10.0; Win64; x64; rv:80.0) Gecko/20100101 Firefox/80.0;
          o   Mozilla/5.0 (Windows NT 10.0; Win64; x64; rv:80.0) Gecko/20100101 Firefox/80.0

·      Total SaaS logs: 57 

At the start of the month on the 5th November, the user had also been seen logging in from a potentially malicious endpoint [9] in Europe, performing ‘MailItemsAccessed’ and ‘Updates’ events with subjects and a resource location related to invoices and wire transfers from the Sent items folder. This suggests the initial compromise had been earlier in the month, giving the threat actor time to make preparations for the final stages of the attack.

Figure 3: Event log showing the activity of UserA from IP 45.135.187[.]108 

2. Office365: UserB 

Looking into the model breach ‘SaaS / Access / Suspicious Credential Use And Login User-Agent’, it was seen that a second account, UserB, was also observed logging in from a rare and potentially malicious location in Bangladesh [7]. Similar to UserA, this user had previously logged in exclusively from the USA, and no other accounts within the digital estate had been observed interacting with the Bangladeshi IP address. The login event appeared to bypass MFA (Multi-factor Authentication) and a suspicious user agent, BAV2ROPC, was used. Against misconfigured accounts, this Microsoft user agent is commonly used by attackers to bypass MFA on Office365. It targets Exchange’s Basic Authentication (normally used in POP3/IMAP4 conditions) and results in an OAuth flow which circumvents the additional password security brought by MFA [10].  

During the session, additional resources were accessed which appear to be associated with bill and invoice payments. In addition, on the 4th November, two new suspicious email rules named “..” were created from rare IPs (107.10.56[.]48 and 76.189.202[.]66). This type of behavior is commonly seen during SaaS compromises to delete or forward emails. Typically, an email rule created by a human user will be named to reflect the change being made, such as ‘Move emails from Legal to Urgent’. In contrast, malicious email rules are often short and undescriptive. The rule “..” is likely to blend in without arousing suspicion, while also being easy for the attacker to create and remember. 

Details of these rule changes are as follows:

·      Time: 2021-11-04 13:25:06, 2021-11-05 15:50:00 [UTC]
·      SaaS Service: Office365
·      SaaS Service Product: Exchange
·      SaaS Status Message: True
·      SaaS Source IP addresses: 107.10.56[.]48, 76.189.202[.]66
·      SaaS Account Name: O365
·      SaaS Actor: UserB@[REDACTED]
·      SaaS Event: SetInboxRule
·      SaaS Office365 Modified Property Names:
          o   AlwaysDeleteOutlookRulesBlob, Force, Identity, MoveToFolder, Name, FromAddressContainsWords, StopProcessingRules
          o   AlwaysDeleteOutlookRulesBlob, Force, Identity, Name, FromAddressContainsWords, StopProcessingRules
·      SaaS Resource Name: .. 

During cloud account compromises, attackers will often use sync operations to download emails to their local email client. During the operations, these clients typically download a large set of mail items from the cloud to a local computer. If the attacker is able to sync all mail items to their mail client, the entire mailbox can be compromised. The attacker is able to disconnect from the account and review and search the email without generating additional event logs. 

Both accounts UserA and UserB were observed using ‘MailItemsAccessed’ sync operations between the 1st and 23rd November when this attack occurred. However, based on the originating IP of the sync operations, the activity is likely to have been initiated by the legitimate, US-based users. Once the security team were able to confirm the events were expected and legitimate, they could establish that the contents of the mailbox were not a part of the data breach. 

Accomplish Mission

After gaining access to the Office365 accounts, sensitive data was downloaded by the attackers to their local system. Either on or before 14th December, the attacker had seemingly uploaded the documents onto a data leak website. In total, 130MB of data had been made available for download in two separate packages. The packages included audit and accounting financial documents, with file extensions such as DB, XLSX, and PDF.

Figure 4: The two data packages uploaded by the attacker and the extracted contents

In a sample of past SaaS activity of UserA, the subject and attachments appear related to the ‘OUTSTANDING PREPAY WIRES 2021’ excel document found from the data leak website in Figure 4, suggesting a further possibility that the account was associated with the leaked data. 

Historic SaaS activity associated with UserA: 

·      Time: 2021-11-05 21:21:18 [UTC]
·      SaaS Office365 Logon Type: Owner
·      Protocol: OFFICE365
·      SaaS Account Name: O365
·      SaaS Actor: UserA@[REDACTED].com
·      SaaS Event: Send
·      SaaS Service: Office365
·      SaaS Service Product: Exchange
·      SaaS Status Message: Succeeded
·      SaaS Office365 Attachment: WIRE 2021.xlsx (92406b); image.png (9084b); image.png (1454b); image.png (1648b); image.png (1691b); image.png (1909b); image.png (2094b)
·      SaaS Office365 Subject: Wires 11/8/21
·      SaaS Resource Location: \Drafts
·      SaaS User Agent: Client=OWA;Action=ViaProxy 

Based on the available evidence, it is highly likely that the data packages contain the data stolen during the account compromise the previous month.  

Once the credentials of an Office365 account are stolen, an attacker can not only access the user's mailbox, but also a full range of Office365 applications such as SharePoint folders, Teams Chat, or files in the user's OneDrive [11]. For example, files shared in Teams chat are stored in OneDrive for Business in a folder named Microsoft Teams Chat Files in the default Document library on SharePoint. One of the files visible on the data leak website, called ‘[REDACTED] CONTRACT.3.1.2020.pdf’, was also observed in the default document folder of a third user account (UserC) within the victim organization, suggesting the compromised accounts may have been able to access shared files stored on other accounts by moving laterally via other O365 applications such as Teams. 

One example can be seen in the below AS logs: 

·      Time: 2021-11-11 01:58:35 [UTC]
·      SaaS Resource Type: File
·      Protocol: OFFICE365
·      SaaS Account Name: 0365
·      SaaS Actor: UserC@[REDACTED]
·      SaaS Event: FilePreviewed
·      SaaS Service Product: OneDrive
·      SaaS Metric: ResourceViewed
·      SaaS Office365 Application Name: Media Analysis and Transformation Service
·      SaaS Office365 File Extension: pdf
·      SaaS Resource Location: https://[REDACTED]-my.sharepoint.com/personal/userC_[REDACTED]_com/Documents/Microsoft Teams Chat Files/[REDACTED] CONTRACT 3.1.2020.pdf
·      SaaS Resource Name: [REDACTED] CONTRACT 3.1.2020.pdf
·      SaaS Service: Office365
·      SaaS Service Product: OneDrive
·      SaaS User Agent: OneDriveMpc-Transform_Thumbnail/1.0 

In the period between the 1st and 30th November, the customer’s Darktrace DETECT/Apps trial had raised multiple high-level alerts associated with SaaS account compromise, but there was no evidence of file encryption.  

Establish Foothold 

Looking back at the start of the attack, it is unclear exactly how the attacker evaded the customer’s pre-existing security stack. At the time of the incident, the victim was using a Barracuda email gateway and Microsoft 365 Threat Management for their cloud environment. 

Darktrace detected no indication the accounts were compromised via credential bruteforcing, which would have enabled the attacker to bypass the Azure Active Directory smart lockout (if enabled). The credentials may have been harvested via a phishing campaign which successfully evaded the list of known ‘bad’ domains maintained by their email gateway.  

Upon gaining access to the account, the Microsoft Defender for Cloud Apps anomaly detection policies would have been expected to raise an alert [12]. In this instance, the unusual login from Nigeria occurred over 16 hours after the previous login from the US, potentially evading anomaly detection policies such as the ‘Impossible Travel’ rule. 

Figure 5: Event log showing the user accessing mail from USA a day before the suspicious usage from Nigeria 

Darktrace Coverage

Darktrace DETECT 

Throughout this event, high scoring model breaches associated with the attack were visible in the customer’s SaaS Console. In addition, there were two Cyber AI Analyst incidents for ‘Possible Account Hijack’ associated with the two compromised SaaS Office365 accounts, UserA and UserB. The visibility given by Darktrace DETECT also enabled the security team to confirm which files had been accessed and were likely part of the data leak.

Figure 6: Example Cyber AI Analyst incident of UserB SaaS Office365 account

Darktrace RESPOND

In this incident, the attackers successfully compromised O365 accounts in order to exfiltrate customer data. Whilst Darktrace RESPOND/Apps was being trialed and suggested several actions, it was configured in human confirmation mode. The following RESPOND/Apps actions were advised for these activities:  

·      ‘Antigena [RESPOND] Unusual Access Block’ triggered by the successful login from an unusual IP address, would have actioned the ‘Block IP’ inhibitor, preventing access to the account from the unusual IP for up to 24 hours
·      ‘Suspicious Source Activity Block’, triggered by the suspicious user agent used to bypass MFA, would have actioned the ‘Disable User’ inhibitor, disabling the user account for up to 24 hours 

During this incident, Darktrace RESPOND/Network was being used in fully autonomous mode in order to prevent the threat actor from pivoting into the network. The security team were unable to conclusively say if any attempts by the attacker to do this had been made. 

Concluding Thoughts  

Data theft extortion has become a widely used attack technique, and ransomware gangs may increasingly use this technique alone to target organizations without secure data encryption and storage policies.  

This case study describes a SaaS data theft extortion incident which bypassed MFA and existing security tools. The attacker appeared to compromise credentials without bruteforce activity, possibly with the use of social engineering through phishing. However, from the first new login, Darktrace DETECT identified the unusual credential use in spite of it being an existing account. Had Darktrace RESPOND/Apps been configured, it would have autonomously responded to halt this login and prevent the attacker from accomplishing their data theft mission.

Thanks to Oakley Cox, Brianna Leddy and Shuh Chin Goh for their contributions.

Appendices

References 

[1] https://securelist.com/new-ransomware-trends-in-2022/106457/

[2] https://www.itpro.co.uk/security/ransomware/367624/the-rise-of-double-extortion-ransomware

[3] https://www.malwarebytes.com/blog/news/2020/10/vastaamo-psychotherapy-data-breach-sees-the-most-vulnerable-victims-extorted

[4] https://www.blackfog.com/shift-from-ransomware-to-data-theft-extortion/

[5] https://www.abuseipdb.com/check/105.112.59.83

[6] https://www.abuseipdb.com/check/105.112.36.212

[7] https://www.abuseipdb.com/check/45.130.83.129

[8] https://docs.microsoft.com/en-us/microsoft-365/compliance/mailitemsaccessed-forensics-investigations?view=o365-worldwide

[9] https://www.abuseipdb.com/check/45.135.187.108

[10] https://www.virustotal.com/gui/ip-address/45.137.20.65/details

[11] https://tidorg.com/new-bec-phishing-attack-steals-office-365-credentials-and-bypasses-mfa/

[12] https://docs.microsoft.com/en-us/microsoft-365/security/office-365-security/responding-to-a-compromised-email-account?view=o365-worldwide

Inside the SOC
Darktrace cyber analysts are world-class experts in threat intelligence, threat hunting and incident response, and provide 24/7 SOC support to thousands of Darktrace customers around the globe. Inside the SOC is exclusively authored by these experts, providing analysis of cyber incidents and threat trends, based on real-world experience in the field.
Written by
Adrianne Marques
Senior Research Analyst

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September 23, 2025

It’s Time to Rethink Cloud Investigations

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Cloud Breaches Are Surging

Cloud adoption has revolutionized how businesses operate, offering speed, scalability, and flexibility. But for security teams, this transformation has introduced a new set of challenges, especially when it comes to incident response (IR) and forensic investigations.

Cloud-related breaches are skyrocketing – 82% of breaches now involve cloud-stored data (IBM Cost of a Data Breach, 2023). Yet incidents often go unnoticed for days: according to a 2025 report by Cybersecurity Insiders, of the 65% of organizations experienced a cloud-related incident in the past year, only 9% detected it within the first hour, and 62% took more than 24 hours to remediate it (Cybersecurity Insiders, Cloud Security Report 2025).

Despite the shift to cloud, many investigation practices remain rooted in legacy on-prem approaches. According to a recent report, 65% of organizations spend approximately 3-5 days longer when investigating an incident in the cloud vs. on premises.

Cloud investigations must evolve, or risk falling behind attackers who are already exploiting the cloud’s speed and complexity.

4 Reasons Cloud Investigations Are Broken

The cloud’s dynamic nature – with its ephemeral workloads and distributed architecture – has outpaced traditional incident response methods. What worked in static, on-prem environments simply doesn’t translate.

Here’s why:

  1. Ephemeral workloads
    Containers and serverless functions can spin up and vanish in minutes. Attackers know this as well – they’re exploiting short-lived assets for “hit-and-run” attacks, leaving almost no forensic footprint. If you’re relying on scheduled scans or manual evidence collection, you’re already too late.
  2. Fragmented tooling
    Each cloud provider has its own logs, APIs, and investigation workflows. In addition, not all logs are enabled by default, cloud providers typically limit the scope of their logs (both in terms of what data they collect and how long they retain it), and some logs are only available through undocumented APIs. This creates siloed views of attacker activity, making it difficult to piece together a coherent timeline. Now layer in SaaS apps, Kubernetes clusters, and shadow IT — suddenly you’re stitching together 20+ tools just to find out what happened. Analysts call it the ‘swivel-chair Olympics,’ and it’s burning hours they don’t have.
  3. SOC overload
    Analysts spend the bulk of their time manually gathering evidence and correlating logs rather than responding to threats. This slows down investigations and increases burnout. SOC teams are drowning in noise; they receive thousands of alerts a day, the majority of which never get touched. False positives eat hundreds of hours a month, and consequently burnout is rife.  
  4. Cost of delay
    The longer an investigation takes, the higher its cost. Breaches contained in under 200 days save an average of over $1M compared to those that linger (IBM Cost of a Data Breach 2025).

These challenges create a dangerous gap for threat actors to exploit. By the time evidence is collected, attackers may have already accessed or exfiltrated data, or entrenched themselves deeper into your environment.

What’s Needed: A New Approach to Cloud Investigations

It’s time to ditch the manual, reactive grind and embrace investigations that are automated, proactive, and built for the world you actually defend. Here’s what the next generation of cloud forensics must deliver:

  • Automated evidence acquisition
    Capture forensic-level data the moment a threat is detected and before assets disappear.
  • Unified multi-cloud visibility
    Stitch together logs, timelines, and context across AWS, Azure, GCP, and hybrid environments into a single unified view of the investigation.
  • Accelerated investigation workflows
    Reduce time-to-insight from hours or days to minutes with automated analysis of forensic data, enabling faster containment and recovery.
  • Empowered SOC teams
    Fully contextualised data and collaboration workflows between teams in the SOC ensure seamless handover, freeing up analysts from manual collection tasks so they can focus on what matters: analysis and response.

Attackers are already leveraging the cloud’s agility. Defenders must do the same — adopting solutions that match the speed and scale of modern infrastructure.

Cloud Changed Everything. It’s Time to Change Investigations.  

The cloud fundamentally reshaped how businesses operate. It’s time for security teams to rethink how they investigate threats.

Forensics can no longer be slow, manual, and reactive. It must be instant, automated, and cloud-first — designed to meet the demands of ephemeral infrastructure and multi-cloud complexity.

The future of incident response isn’t just faster. It’s smarter, more scalable, and built for the environments we defend today, not those of ten years ago.  

On October 9th, Darktrace is revealing the next big thing in cloud security. Don’t miss it – sign up for the webinar.

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Kellie Regan
Director, Product Marketing - Cloud Security

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September 22, 2025

Understanding the Canadian Critical Cyber Systems Protection Act

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Introduction: The Canadian Critical Cyber Systems Protection Act

On 18 June 2025, the Canadian federal Government introduced Bill C-8 which, if adopted following completion of the legislative process, will enact the Critical Cyber Systems Protection Act (CCSPA) and give Canada its first federal, cross-sector and legally binding cybersecurity regime for designated critical infrastructure providers. As of August 2025, the Bill has completed first reading and stands at second reading in the Canadian House of Commons.

Political context

The measure revives most of the stalled 2022 Bill C-26 “An Act Respecting Cyber Security” which “died on Paper” when Parliament was prorogued in January 2025, in the wake of former Prime Minister Justin Trudeau’s resignation.

The new government, led by Mark Carney since March 2025, has re-tabled the package with the same two-part structure: (1) amendments to the Telecommunications Act that enable security directions to telecoms; and (2) a new CCSPA setting out mandatory cybersecurity duties for designated operators. This blog focuses on the latter.

If enacted, Canada will join fellow Five Eyes partners such as the United Kingdom and Australia, which already impose statutory cyber-security duties on operators of critical national infrastructure.

The case for new cybersecurity legislation in Canada

The Canadian cyber threat landscape has expanded. The country's national cyber authority, the Canadian Centre for Cybersecurity (Cyber Centre), recently assessed that the number of cyber incidents has “sharply increased” in the last two years, as has the severity of those incidents, with essential services providers among the targets. Likewise, in its 2025-2026 National Cyber Threat Assessment, the Cyber Centre warned that AI technologies are “amplifying cyberspace threats” by lowering barriers to entry, improving the speed and sophistication of social-engineering attacks and enabling more precise operations.

This context mirrors what we are seeing globally: adversaries, including state actors, are taking advantage of the availability and sophistication of AI tools, which they have leverage to amplify the effectiveness of their operations. In this increasingly complex landscape, regulation must keep pace and evolve in step with the risk.

What the Canadian Critical Cyber Systems Protection Act aims to achieve

  • If enacted, the CCSPA will apply to operators in federally regulated critical infrastructure sectors which are vital to national security and public safety, as further defined in “Scope” below (the “Regulated Entities”), to adopt and comply with a minimum standard of cybersecurity duties (further described below)  which align with those its Five Eyes counterparts are already adhering to.

Who does the CCSPA apply to

The CCSPA would apply to designated operators that deliver services or systems within federal jurisdiction in the following priority areas:

  • telecommunications services
  • interprovincial or international pipeline and power line systems, nuclear energy systems, transportation systems
  • banking and clearing  
  • settlement systems

The CCSPA would also grant the Governor in Council (Federal Cabinet) with powers to add or remove entities in scope via regulation.

Scope of the CCSPA

The CCSPA introduces two key instruments:

First, it strengthens cyber threat information sharing between responsible ministers, sector regulators, and the Communications Security Establishment (through the Cyber Centre).

Second, it empowers the Governor in Council (GIC) to issue Cyber Security Directions (CSDs) - binding orders requiring a designated operator to implement specified measures to protect a critical cyber system within defined timeframes.

CSDs may be tailored to an individual operator or applied to a class of operators and can address technology, process, or supplier risks. To safeguard security and commercial confidentiality, the CCSPA restricts disclosure of the existence or content of a CSD except as necessary to carry it out.

Locating decision-making with the GIC ensures that CSDs are made with a cross-government view that weighs national security, economic priorities and international agreement.

New obligations for designated providers

The CCSPA would impose key cybersecurity compliance and obligations on designated providers. As it stands, this includes:

  1. Establishing and maintaining cybersecurity programs: these will need to be comprehensive, proportionate and developed proactively. Once implemented, they will need to be continuously reviewed
  2. Mitigating supply chain risks: Regulated Entities will be required to assess their third-party products and services by conducting a supply chain analysis, and take active steps to mitigate any identified risks
  3. Reporting incidents:  Regulated Entities will need to be more transparent with their reporting, by making the Communications Security Establishment (CSE) aware of any incident which has, or could potentially have, an impact on a critical system. The reports must be made within specific timelines, but in any event within no more than 72 hours;
  4. Compliance with cybersecurity directions:  the government will, under the CCSPA, have the authority to issue cybersecurity directives in an effort to remain responsive to emerging threats, which Regulated Entities will be required to follow once issued
  5. Record keeping: this shouldn’t be a surprise to many of those Regulated Entities which fall in scope, which are already likely to be subject to record keeping requirements. Regulated Entities should expect to be maintaining records and conducting audits of their systems and processes against the requirements of the CCSPA

It should be noted, however, that this may be subject to change, so Regulated Entities should keep an eye on the progress of the Bill as it makes its way through parliament.

Enforcement of the Act would be carried out by sector-specific regulators identified in the Act such as the Office of the Superintendent of Financial Institutions, Minister of Transport, Canada Energy Regulator, Canadian Nuclear Safety Commission and the Ministry of Industry.

What are the penalties for CCSPA non-compliance?

When assessing the penalties associated with non-compliance with the requirements of the CCSPA, it is clear that such non-compliance will be taken seriously, and the severity of the penalties follows the trend of those applied by the European Union to key pieces of EU legislation. The “administrative monetary penalties” (AMPs) set by regulation could see fines being applied of up to C$1 million for individuals and up to C$15 million for organizations.

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