Broker Faces Backlash After Exposure of Client Files Triggers Privacy Investigation

The Challenge

In early 2025, Liberty One Brokerage, a midsize insurance firm in British Columbia, became the focus of national headlines after a client discovered their insurance application publicly accessible online. A misconfigured document-sharing tool had left hundreds of client files which included IDs, medical information, and policy documents, which was open to public access for more than six weeks. The exposure went unnoticed due to a lack of automated monitoring or configuration auditing.

The incident quickly escalated when the affected client reported it to the media, drawing scrutiny from the Office of the Privacy Commissioner of Canada (OPC). Regulators launched an investigation under PIPEDA, demanding proof of privacy safeguards and notification procedures. Internally, Liberty One had no formal record of system access reviews, no defined data retention schedule, and no staff training on secure file sharing. The company’s reliance on manual processes left it unprepared for the speed and transparency demanded in a public privacy event.

Executives initially viewed the breach as a technical misstep, but it soon became clear that governance, not technology, was the root cause. The lack of documented procedures, oversight, and accountability allowed preventable exposure to persist.

Our Solution

Our privacy advisory team was retained to contain the fallout and implement structural reforms. We began with an immediate privacy audit to identify all exposure points and misconfigured sharing platforms. Access permissions were tightened, encryption defaults were applied across all systems, and sensitive files were migrated to a secured, monitored environment. We introduced a privacy-by-design framework requiring all digital tools to include built-in controls for access management, auditing, and encryption.

We then assisted Liberty One in developing formal breach response protocols and incident communication plans aligned with OPC expectations. Comprehensive staff training was launched to reinforce responsible data handling, supported by interactive simulations on configuration hygiene and client data protection. Procurement processes were also rewritten to ensure that any third-party tools met mandatory security certification standards before deployment.

Finally, leadership accountability was established through a cross-functional privacy council tasked with maintaining oversight, policy review, and ongoing compliance monitoring.

The Value

Within months, Liberty One’s transparency and cooperation earned positive recognition from regulators and clients alike. Affected individuals received prompt communication, credit monitoring, and updates on remediation steps. Internally, a renewed culture of privacy awareness took root. Staff began viewing client information as a trust asset rather than a routine administrative responsibility.

The company’s new governance model introduced sustainable safeguards against recurrence. Privacy risk management became embedded in daily operations, and executives committed to annual privacy audits as a board-level priority. What began as a damaging exposure transformed into a lesson in accountability and trust restoration.

Implementation Roadmap

1. Conduct enterprise-wide privacy audit to identify exposed data and misconfigurations

2. Reconfigure sharing tools and apply encryption defaults

3. Establish privacy-by-design framework for all new tools

4. Launch staff training and incident simulation programs

5. Form a cross-functional privacy and compliance council

Info Sheet