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breach-risk-assessment

breach-risk-assessment

github.com/mukul975Security32338 installsUpdated 32w ago
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About breach-risk-assessment

This skill provides a GDPR- and EDPB-guided method for assessing personal data breaches. It helps teams determine whether supervisory authorities or data subjects need notification, using breach classification, scoring, thresholds, and documentation.

Key features

  1. 01Classify confidentiality, integrity, and availability breaches
  2. 02Assess data sensitivity and affected population
  3. 03Score risk across six factors
  4. 04Determine notification duties using thresholds
  5. 05Document assessment evidence and decisions

Use cases

  1. 01Assess notification duties after a personal data breach
  2. 02Compare risks across breach scenarios
  3. 03Record DPO recommendations and management decisions
  4. 04Reassess risk when new information emerges

Install

Copy the command and run it in a terminal.

$npx skills add https://github.com/mukul975/privacy-data-protection-skills --skill breach-risk-assessment

After installing, type/breach-risk-assessmentin Claude Code to confirm it loaded.

Bundled files

References and scripts installed along with SKILL.md.

assets/
template.md
references/
standards.md
workflows.md
scripts/
process.py

Details

From the project README

Conducting Breach Risk Assessment

Overview

When a personal data breach occurs, the controller must assess whether the breach is "likely to result in a risk to the rights and freedoms of natural persons" (Art. 33(1)) to determine whether supervisory authority notification is required, and whether it is "likely to result in a high risk" (Art. 34(1)) to determine whether data subject notification is required. This skill provides a structured, repeatable methodology based on EDPB Guidelines 9/2022 and Guidelines 01/2021.

Breach Type Classification (CIA Triad)

Every breach must first be classified according to the type of security compromise:

Confidentiality Breach

Unauthorized or accidental disclosure of, or access to, personal data.

ScenarioSeverity Indicator
Email containing 50 customer records sent to wrong internal departmentLow — limited exposure, same organization
Database export of 200,000 records posted on public file-sharing serviceSevere — mass exposure, publicly accessible
Employee accesses medical records of a colleague without authorizationMedium — limited scope but sensitive data
Backup tape containing unencrypted payroll data lost during transportHigh — financial data, unknown accessor
Integrity Breach

Unauthorized or accidental alteration of personal data.

ScenarioSeverity Indicator
Malware modifies patient medication dosages in a clinical databaseSevere — potential physical harm
Software bug overwrites postal codes in 5,000 customer recordsLow — non-sensitive field, reversible from backup
Unauthorized modification of employee performance review scoresMedium — potential employment consequences
SQL injection alters financial transaction recordsHigh — financial integrity compromised
Availability Breach

Accidental or unauthorized loss of access to, or destruction of, personal data.

ScenarioSeverity Indicator
Ransomware encrypts the HR system for 48 hours; clean backup restoredMedium — temporary unavailability, data recovered
Fire destroys the only copy of archived patient recordsSevere — permanent loss, healthcare impact
DDoS attack renders the customer portal unavailable for 6 hoursLow — temporary, no data loss or compromise
Cryptographic key destruction makes encrypted dataset permanently unreadableSevere — irreversible data loss

Risk Assessment Methodology

Factor 1: Data Sensitivity (Weight: High)
ScoreCriteriaExamples
1 — LowNon-sensitive data already in the public domain or easily obtainableBusiness contact details, publicly listed addresses
2 — MediumPersonal data that could cause minor inconvenience if disclosedEmail addresses, phone numbers, purchase history
3 — HighSensitive personal data or data with significant impact potentialFinancial account details, government ID numbers, employment records
4 — SevereSpecial category data (Art. 9), criminal conviction data (Art. 10), or data enabling significant harmHealth records, biometric data, genetic data, sexual orientation, political opinions
Factor 2: Volume of Affected Data Subjects
ScoreData Subject CountRationale
1Fewer than 100Limited scale — individual assessment feasible
2100 to 1,000Moderate scale — structured response required
31,000 to 100,000Large scale — significant organizational impact
4More than 100,000Mass scale — potential for widespread societal impact
Factor 3: Ease of Identification
ScoreCriteria
1Data is pseudonymized or encrypted; re-identification requires additional data held separately and securely
2Data contains indirect identifiers only; re-identification possible with moderate effort
3Data contains direct identifiers (name + one other element); individuals readily identifiable
4Data contains multiple direct identifiers, photographs, or biometric data; immediate identification possible
Factor 4: Consequence Severity
ScorePotential Consequences
1Minor inconvenience — e.g., receiving unsolicited marketing, needing to change a password
2Moderate impact — e.g., targeted phishing risk, minor financial exposure, reputational inconvenience
3Significant impact — e.g., identity theft risk, substantial financial loss, employment consequences, discrimination risk
4Severe impact — e.g., physical safety threat, significant financial fraud, denial of essential services, threat to life
Factor 5: Individual Characteristics
ScoreCriteria
1General adult population with no heightened vulnerability
2Population includes some individuals in dependent relationships (employees, tenants)
3Population includes elderly, financially vulnerable, or individuals in unequal power dynamics
4Population includes minors, patients, asylum seekers, or individuals whose safety depends on data confidentiality
Factor 6: Controller-Specific Factors
ScoreCriteria
1Controller processes personal data as an ancillary activity (e.g., office administration)
2Controller processes personal data as a core activity for service delivery
3Controller is in a position of trust (financial institution, healthcare provider, education)
4Controller processes data at scale as a core business (data broker, payment processor, social media platform)

Scoring Matrix and Thresholds

Aggregate ScoreRisk LevelArt. 33 SA NotificationArt. 34 DS NotificationRequired Action
6-8Unlikely to result in riskNot requiredNot requiredDocument in Art. 33(5) breach register only
9-12Risk present but below high thresholdRequired within 72 hoursNot requiredNotify supervisory authority; document fully
13-18Likely to result in risk, approaching highRequired within 72 hoursRecommendedNotify SA; strongly consider DS notification
19-24Likely to result in high riskRequired within 72 hoursRequired without undue delayNotify both SA and data subjects

EDPB Breach Scenario Analysis (Guidelines 01/2021)

Scenario 1: Ransomware with Backup Available
  • Facts: Hospital hit by ransomware. Patient data encrypted. Clean backup restored within 24 hours. No evidence of exfiltration.
  • Classification: Availability breach.
  • Risk assessment: Data sensitivity = 4 (health data), Volume = 3 (2,500 patients), Identifiability = 4, Consequences = 3 (delayed treatment), Vulnerable = 4 (patients), Controller = 3 (healthcare). Total = 21.
  • EDPB conclusion: Notify SA and data subjects. Even though backup was available, the temporary unavailability of health data during the 24-hour restoration window posed high risk to patient safety.
Scenario 2: Ransomware Without Backup
  • Facts: Small manufacturing company hit by ransomware. Employee payroll data permanently lost. No backup exists.
  • Classification: Availability breach (permanent).
  • Risk assessment: Data sensitivity = 3, Volume = 1 (45 employees), Identifiability = 4, Consequences = 3, Vulnerable = 2, Controller = 2. Total = 15.
  • EDPB conclusion: Notify SA and data subjects. Permanent loss of payroll data directly impacts employees' financial interests.
Scenario 3: Data Exfiltration from Website
  • Facts: SQL injection attack extracts usernames, hashed passwords, and email addresses of 1.2 million registered users from an e-commerce platform.
  • Classification: Confidentiality breach.
  • Risk assessment: Data sensitivity = 2, Volume = 4, Identifiability = 3, Consequences = 2, Vulnerable = 1, Controller = 3. Total = 15.
  • EDPB conclusion: Notify SA and data subjects. The combination of email addresses with hashed passwords enables credential-stuffing attacks against other services.
Scenario 4: Misdirected Email (Single Recipient)
  • Facts: HR department sends a single employee's salary slip to the wrong internal colleague by email. Error discovered within 10 minutes. Recipient confirms deletion.
  • Classification: Confidentiality breach.
  • Risk assessment: Data sensitivity = 3, Volume = 1, Identifiability = 4, Consequences = 1, Vulnerable = 2, Controller = 1. Total = 12.
  • EDPB conclusion: Notify SA (marginal). No DS notification required. The breach is contained, the recipient is known and cooperative, and financial data exposure is limited.
Scenario 5: Lost Unencrypted USB Drive
  • Facts: Employee loses an unencrypted USB drive containing names, addresses, and national insurance numbers of 3,500 pension scheme members.
  • Classification: Confidentiality breach.
  • Risk assessment: Data sensitivity = 3, Volume = 3, Identifiability = 4, Consequences = 3, Vulnerable = 3 (elderly/retirees), Controller = 3. Total = 19.
  • EDPB conclusion: Notify SA and data subjects. Government identifiers combined with vulnerable population (retirees) creates high identity theft risk.
Scenario 6: Accidental Publication of Student Grades
  • Facts: University accidentally publishes exam results with student names on a publicly accessible web page for 36 hours before removal.
  • Classification: Confidentiality breach.
  • Risk assessment: Data sensitivity = 2, Volume = 2 (800 students), Identifiability = 4, Consequences = 2, Vulnerable = 2, Controller = 3 (education). Total = 15.
  • EDPB conclusion: Notify SA and data subjects. Academic performance data linked to names, public exposure for 36 hours, potential impact on students' academic and professional prospects.

Assessment Documentation Requirements

Every breach risk assessment must be documented with the following elements:

  1. Assessment metadata: Date, assessor name, breach reference number, version
  2. Breach description: Factual summary of what occurred
  3. CIA classification: Which type(s) of breach
  4. Factor-by-factor scoring: Each factor scored with written justification
  5. Aggregate score and threshold determination: Which notification obligations apply
  6. DPO recommendation: DPO's concurrence or dissent with the assessment
  7. Management decision: Final notification decision with sign-off
  8. Re-assessment trigger: Conditions that would require re-scoring (e.g., exfiltration later confirmed)

Common Assessment Errors

  1. Underscoring consequences because exfiltration is "unconfirmed": The absence of evidence of exfiltration is not evidence of absence. Score consequences based on what could happen if the data is in unauthorized hands.
  2. Treating encrypted data as automatically low-risk: Encryption is only mitigating if the encryption keys were not also compromised and the encryption standard is robust (AES-256 or equivalent).
  3. Aggregating multiple small breaches: Recurrent similar breaches (e.g., repeated misdirected emails) may indicate a systemic issue that elevates the aggregate risk beyond what each individual incident would suggest.
  4. Ignoring availability breaches: Temporary loss of access to health records, financial data, or safety-critical information can cause harm even if confidentiality is not compromised.
  5. Applying the 250-employee exemption to notification: Art. 30(5) provides a limited RoPA exemption for small organizations, but there is no such exemption for Art. 33/34 breach notification obligations.

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