Data Misuse

Threats relating to the mishandling of sensitive customer data

Affected entity: MNO

Risk: Unauthorized access to user data and interception of data in transit.

• Vulnerability: Weak encryption practices or sending sensitive information in clear text over insecure traffic channels like SMS and USSD (SD: communication security)

  • Control 5.1: Ensure all sensitive consumer data such as PINs and passwords are encrypted, when traversing the network and while at the data is at rest

Affected entity: DFS Provider and Third-party providers

Risk: Exposure of Sensitive data

• Vulnerability: Inadequate data protection controls (SD: privacy)

  • Control 5.2: Remove customer sensitive data from trace logs. Examples of data that should be removed include cash retrieval voucher codes, bank account numbers, credentials. Instead, use place holders, where possible, to represent this data in logs

Risk: Exposure of customer sensitive information during transactions or through APIs (SD: privacy)

• Control 5.3: DFS providers should restrict the sharing of information to be only the minimum amount required for transactions with third parties and service providers

• Vulnerability: Weak encryption on the API interfaces (SD: privacy)

  • Control 5.4: Monitor the use of APIs and encrypt all data shared with third parties. Additionally, put into place data management procedures and controls such as signed non-disclosure agreements with payment service providers to avoid information/data leakage |