What if: T-Mobile had used BreachRx?

In a recent settlement with the Federal Communications Commission (FCC), T-Mobile agreed to pay $31.5 million and overhaul its cybersecurity practices following a series of data breaches. And the Committee on Foreign Investment in the U.S. (CFIUS) levied its biggest fine to date of $60 million. These hefty price tags raise an important question: Could T-Mobile have avoided or reduced these fines by using a robust and modern incident management solution like BreachRx? Let’s play “What If?” and explore how the BreachRx incident management software could have made a difference.

The Challenges T-Mobile Faced

T-Mobile’s settlement resolves charges related to data sharing in 2020 and 2021 and multiple data breaches in 2021, 2022, and 2023. These incidents affected millions of current, former, and prospective T-Mobile customers, as well as mobile virtual network operators (MVNOs). The incidents resulted in the leak of sensitive information, including:

• Customer names
• Addresses
• Dates of birth
• Social Security numbers
• Driver’s license numbers
• Customer subscription information

The FCC cited “poor cybersecurity practices” as a key factor in the breaches, highlighting the need for robust security measures in the telecommunications industry at large, not just T-Mobile. And in a separate suit fined T-Mobile, Verizon, Sprint, and AT&T $196 million for illegally sharing customer location data without consent. And the $60 million to CFIUS is tied to violations around information sharing when T-Mobile acquired Sprint for $23 billion over four years ago.

How BreachRx Could Have Helped

• BreachRx’s platform enables companies to create comprehensive, tailored response plans before a consequential incident or breach occurs and practice with customized automated simulations and tabletop exercises.
• T-Mobile could have used this capability to develop a structured approach to handling a broad variety of potential data breaches, ensuring all stakeholders knew their roles and responsibilities in advance.
• Proactive planning would have helped T-Mobile respond more effectively to the initial breach impact, potentially preventing subsequent incidents or at least streamlining those responses and lowering their costs. Additionally, after these incidents T-Mobile would have a record of what was known, when it was known, and who, what, and when each action in the response took place. This is critical when law enforcement and regulators reach out. But more about depositions later…

• During an incident, BreachRx provides a centralized platform for managing all aspects of the response, including real-time privileged out of band communications, workflows to coordinate all aspects of the response across the business, and automated record keeping during and after the incident is resolved.
• This would have helped T-Mobile coordinate their efforts more effectively across multiple breaches internally, including between security, IT, legal., comms, and more. The outcomes would be readily sharable for multiple governments, regions, and agencies, while separating those privileged communications, likely reducing the impact and scope of each incident and hastening a satisfactory resolution without fines or reputation loss.
• A system like BreachRx’s would have facilitated faster containment and resolution, limiting the exposure of customer data which is mandated by various regulations. Unfortunately organizations—for better or worse—have flexibility to determine what pre-incident safeguards and post-incident response actions are “reasonable” under the circumstances.
• Real-time management could have facilitated not just faster containment, notification, and resolution, limiting the exposure of customer data, but greatly reduced regulatory and contractual risk. An SEC Rule from mid-2023 requires that in the event of a data breach, institutions provide clear and conspicuous notice “as soon as practicable,” but not later than 30 days after their discovery of the breach.

• BreachRx’s has curated compliance workflows that satisfy various cybersecurity, privacy, and data breach regulations as they uniquely impact different countries, states, regions, and industries.
• This capability would have ensured that T-Mobile met all necessary regulatory requirements, including timely notifications to affected customers in different countries and regions while ensuring appropriate communications with all relevant government agencies like the Securities and Exchange Commission (SEC) and FCC, with far less cost than relying solely on outside counsel and/or doing a manual regulatory review.
• In addition, BreachRx has compliance workflows that streamline achieving the incident response criteria for major global cybersecurity frameworks like NIST Cybersecurity Framework (CSF), ISO 27001, NIS 2, Sarbanes-Oxley (SOX), and many more.
• By just demonstrating strict adherence to both regulatory and audit compliance standards, T-Mobile would likely have mitigated the severity of the fines imposed.

• The days of “don’t write anything down” are long gone. During litigation, documentation can be your best defense or your worst liability (if it’s inadequate or privilege is poorly protected). The BreachRx platform automatically maintains a detailed audit trail of every action taken during an incident.
• This comprehensive documentation would have helped T-Mobile security executives protected themselves, their teams, and their organizations by demonstrating their depth of diligence to regulators and potentially reduced or eliminated some penalties.
• Detailed reporting could also have aided in identifying and addressing systemic issues across multiple breaches through lessons learned retrospectives, preventing or reducing the impact of recurrence in ‘21, ‘22, or ‘23.
• Incident response records are now audited like financial records so documentation and reporting is key to having these records when you need them next.

• BreachRx facilitates thorough post-incident reviews and helps identify areas for improvement.
• The BreachRx platform can even be used to track follow-up actions as part of each incident, so security leaders can track follow-up tasks against the results of a root-cause analysis to ensure they are completed.
• This could have helped T-Mobile strengthen their security posture after the initial breach, potentially preventing or minimizing the impact of subsequent incidents.

Conclusion

The $31.5 million settlement and mandated cybersecurity overhaul highlight the critical importance of robust incident management and cybersecurity practices in the telecommunications industry. The days of high-level IR policies and a reliance on heroic intervention from our teams relying on ad hoc processes in Teams, Word, and Zoom are well past due to be replaced. By leveraging a modern incident management platform like BreachRx, T-Mobile could have potentially avoided or significantly reduced these fines, better protected their customers’ sensitive data, and strengthened their reputation and reduced customer churn.

BreachRx’s incident management platform offers a proactive, structured approach to cybersecurity that aligns with the FCC’s emphasis on protecting consumers’ data. As FCC Chairwoman Jessica Rosenworcel stated, “Today’s mobile networks are top targets for cybercriminals. Consumers’ data is too important and much too sensitive to receive anything less than the best cybersecurity protections.” And to be clear, the FCC, SEC, and CFIUS have all sent strong messages with heavy fines and will continue to scrutinize cybersecurity best practices for the foreseeable future.

In an era where mobile networks are prime targets for cybercriminals, companies like T-Mobile can’t afford to rely on outdated or inadequate security measures. The BreachRx platform provides the tools and frameworks necessary to stay ahead of threats, manage incidents effectively, and continuously improve cybersecurity practices.