GDPR and financial advice: Personal data breach classification

Under the GDPR, a personal data breach is defined very broadly as "a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed". The working group discussed a three stage process regarding a breach: * First, understanding whether the incident constituted a breach, taking into account the broad definition  under the GDPR; * Second, where the incident did constitute a breach, considering whether this posed a risk to the rights and freedoms of data subjects....