In May 2019, First American Financial Corporation—a leading provider of title insurance and settlement services in the United States—found itself at the center of a massive data exposure scandal. A vulnerability in the company’s website configuration allowed unauthorized access to more than 885 million sensitive records. These records, some dating back over 16 years, contained highly personal financial information including bank account numbers, Social Security numbers, mortgage and tax documents, wire transaction receipts, and more. The exposure wasn’t the result of a sophisticated cyberattack. Instead, it stemmed from a glaring security oversight: documents stored on the site could be accessed simply by changing the numbers in the URL. No authentication, no login, no barriers.
This incident didn’t just affect a small segment of users or present a theoretical risk—it exposed a trove of critical personal data across nearly two decades of customer history. What makes the First American breach particularly alarming is its simplicity. There was no malware, no advanced persistent threat actor, no exploitation of a zero-day vulnerability. The root cause was a basic web application misconfiguration that was discoverable by anyone who thought to alter a single digit in a browser address bar.
For CISOs today, this breach serves as a potent reminder: the biggest threats to your organization might not come from nation-state hackers or zero-day exploits—but from overlooked fundamentals and gaps in day-to-day security hygiene. In a time when security teams are busy defending against AI-driven phishing, ransomware-as-a-service, and increasingly complex cloud environments, the First American breach forces a re-centering around the basics. If the perimeter is secure but the inside is misconfigured, your organization is still exposed.
The First American case also highlights the evolving nature of “data breaches.” In this instance, there was no indication that the data was stolen or misused, but that doesn’t change the severity of the exposure. Regulatory bodies, customers, and stakeholders increasingly view unauthorized access—even if accidental—as a breach of trust. This shift in perception has major implications for how CISOs approach both risk assessment and breach response. It’s not just about keeping bad actors out; it’s about making sure the data inside your walls isn’t left sitting unguarded in plain sight.
Further complicating matters, the data exposed by First American wasn’t just sensitive—it was systematically exposed. The sequential document structure made it easy to view other users’ information by simply iterating through the document numbers in the URL. This isn’t just a user experience flaw; it’s a security anti-pattern known as Insecure Direct Object Reference (IDOR), and it’s one of the most easily exploited vulnerabilities on the web. This form of exposure could have been picked up through basic web application testing. That it wasn’t suggests a deeper issue with how security practices were prioritized—or not prioritized—within the organization.
Beyond the technical flaws, the breach also exposed cracks in how organizations communicate and respond to security incidents. Public reports suggested that the vulnerability had been flagged by a real estate professional and passed along to journalists before action was taken. That timeline raises concerns about internal escalation processes and the speed at which critical security issues are handled once discovered. For CISOs, it’s a lesson in responsiveness, transparency, and the importance of clear internal communication channels that prioritize security reports—no matter their source.
The First American case also underscores a risk that many organizations underestimate: legacy systems and long-term data retention. With over 16 years of records exposed, this incident reflects how outdated platforms and weak historical controls can create compounding vulnerabilities. Many enterprises maintain old systems because they “still work”—but in doing so, they carry decades of accumulated technical debt and security gaps. This should prompt any CISO to question: how old is the data in your systems, and how secure are the platforms storing it?
The breach didn’t result in large-scale identity theft or financial loss—at least none that were reported—but that shouldn’t lull security leaders into complacency. Regulatory scrutiny, reputational damage, and loss of customer trust are outcomes that can linger far longer than the headlines. As regulators and privacy laws become more aggressive in holding organizations accountable for data protection, even “harmless” exposures like this one can lead to major consequences.
And while this was a 2019 incident, its lessons are arguably more relevant in 2025. Today’s enterprise environments are more complex, hybridized, and exposed than ever before. With generative AI, cloud-native apps, edge computing, and increasing data volumes across distributed systems, the margin for error has never been smaller. CISOs now operate in a world where public trust hinges not just on stopping cyberattacks, but on ensuring the fundamentals of digital infrastructure are airtight. In that light, the First American breach isn’t just a story from the past—it’s a case study for the present.
In this article, we’ll walk through seven key lessons every CISO can take away from the First American Financial data breach—lessons that speak to the importance of foundational security, proactive governance, and a modern understanding of what “breach readiness” really means.
Let’s get into them.
Breach Overview: What Went Wrong
In May 2019, First American Financial Corporation—one of the largest title insurance companies in the United States—was thrust into the cybersecurity spotlight for all the wrong reasons. The company had unintentionally exposed an estimated 885 million records containing highly sensitive customer information.
Unlike many data breaches involving hackers and malware, this incident stemmed from a basic and preventable web application vulnerability: the company’s document management system allowed public access to confidential files through predictable URLs and no authentication requirements.
The breach was discovered by a real estate professional who stumbled upon the issue while accessing transaction documents through First American’s website. Upon examining the URL, they noticed that the document reference number was numeric and sequential. Curious, they changed the number by a small increment and found that they could easily access other unrelated customers’ records. Each document was accessible simply by entering a different number at the end of the URL. No credentials, login process, or security check stood in the way.
This type of vulnerability is technically known as Insecure Direct Object Reference (IDOR). In IDOR scenarios, the system fails to properly validate whether a user is authorized to access a given object—in this case, a document—before returning it. This creates a serious security flaw: if users can guess or modify identifiers, they can potentially access any resource on the system. In First American’s case, the identifiers were not just guessable—they were strictly sequential, making mass exposure easy even for a non-technical user.
The scale of exposed data was staggering. Reports indicated that files dating as far back as 2003 were publicly accessible. The documents included:
- Bank account numbers and statements
- Mortgage records
- Tax documents
- Wire transaction receipts
- Social Security numbers
- Driver’s license images
- Names, addresses, and other personal identifiers
This wasn’t just any data—it was a goldmine for identity thieves, fraudsters, and cybercriminals. Even though there were no confirmed reports that the data was downloaded or misused, the potential risk was monumental. Given the sensitivity of the exposed information, even one malicious actor stumbling upon the flaw could have weaponized it to catastrophic effect.
What made this breach especially damaging from a reputational standpoint was the fact that the vulnerability was so easy to detect. A basic security audit or penetration test would have likely flagged it immediately. Even a rudimentary manual inspection of the document portal could have exposed the flaw. The absence of proper access control checks, combined with the lack of URL obfuscation or non-sequential document identifiers, made the system wide open for anyone to exploit.
There were also serious questions raised about the timeline of discovery and disclosure. The flaw was first flagged to a journalist at KrebsOnSecurity, who then verified the issue and notified First American. The company responded by disabling external access to the affected system on the same day, but the fact that such a serious vulnerability was discovered externally—rather than internally through proactive security monitoring—was troubling. It suggested either a lack of regular security testing or the ineffectiveness of existing controls.
From a regulatory perspective, the consequences were real. In 2020, the New York State Department of Financial Services (NYDFS) filed charges against First American, citing violations of the state’s cybersecurity regulations. The NYDFS alleged that the company failed to properly remediate known vulnerabilities, did not conduct adequate risk assessments, and lacked robust data protection controls. Although the case was eventually settled, it marked a significant moment in cybersecurity enforcement—demonstrating that even breaches without confirmed exploitation could result in regulatory action.
The First American breach also brought attention to another often overlooked issue: legacy systems and data sprawl. The company had stored documents dating back over 16 years. While there are business reasons to retain such information, long-term data retention without modern security controls creates serious risk. Legacy systems are often exempt from modern security practices, making them attractive targets and easy points of failure.
Another critical takeaway was the absence of real-time detection. There was no indication that First American’s security team had visibility into the unauthorized access before it was reported externally. In modern cybersecurity environments, real-time monitoring and alerting for abnormal access patterns are essential. The ability to detect unauthorized document access—even from a legitimate-looking IP—can be the difference between early containment and massive exposure.
Despite the scale of the breach, some defenders of the company pointed out that there was no evidence that the data had been harvested or used for malicious purposes. However, that defense doesn’t hold up under modern cybersecurity expectations. Organizations are now judged not just on whether a breach occurred, but how it could have happened, whether the risk was foreseeable, and what actions were taken to prevent it. The bar has shifted from reaction to prevention—and First American fell short.
For CISOs, the First American breach illustrates what can happen when basic application security is overlooked. It’s a cautionary tale about assuming that “quiet” systems—like a document portal—don’t need strong access controls. It’s also a reminder that you don’t need a sophisticated attacker to suffer a catastrophic breach. Sometimes, all it takes is one predictable URL and one person willing to look just a little closer.
In a world where organizations are increasingly focused on AI, zero trust, and next-gen security tools, the First American breach brings us back to fundamentals. If your authentication model is broken or nonexistent, no amount of threat intelligence will save you. This incident forces CISOs to ask a basic but essential question: Are we securing the doors and windows, or just the vault?
Lesson 1: Don’t Underestimate Basic Web Application Security
The First American Financial data breach in 2019 is one of the clearest examples in recent history of how overlooking the fundamentals of web application security can lead to massive exposure. There were no advanced attack vectors, no sophisticated malware payloads, and no insider sabotage. What caused the breach? A basic access control failure—a website serving highly sensitive documents without requiring users to authenticate.
This is the kind of flaw most CISOs would expect to find in an under-resourced startup or a forgotten internal tool, not in a publicly available enterprise application at a Fortune 500 company.
At its core, the breach highlighted a foundational security gap: the complete absence of proper access controls on a web-facing document storage system. Users could access documents simply by altering the numbers in the URL, and the system would return the document without checking whether the user was authenticated or authorized to view it. There was no account verification, no token validation, no session check. This is Web Security 101—yet it was missed.
For CISOs, the lesson is clear: do not assume that the basics are covered. Verify. Regularly. Aggressively. With the increasing complexity of cloud environments, containerized infrastructure, and API-first applications, it’s easy to focus on modern security challenges and lose sight of the basics—yet it’s often the simplest flaws that lead to the largest breaches.
Misconfigurations Are the Modern Breach Vector
In the age of automated deployment pipelines, infrastructure-as-code, and frequent releases, configuration drift is a real and growing concern. A system that was secure at deployment can become misconfigured through innocuous changes over time. When teams prioritize features, performance, or speed, security settings can be bypassed, forgotten, or overridden—intentionally or otherwise.
What happened at First American wasn’t a novel hack. It was likely the result of a misconfigured document storage system that lacked the necessary authentication and authorization logic. Whether this was due to an oversight in initial development or the erosion of security controls over time doesn’t matter. The result was the same: wide-open access to millions of sensitive documents.
Secure by Default, Not by Exception
One of the key principles CISOs need to champion is a “secure by default” design philosophy. Every system, especially those exposed to the internet, should assume adversarial interaction. If a system stores sensitive data, its default posture must be to deny access unless a valid, verified request is made. This means integrating secure authentication protocols, enforcing role-based access control (RBAC), validating permissions, and ensuring logs are generated and reviewed.
The breach at First American demonstrated the danger of assuming trust without verification. This kind of logic—known as implicit trust—is a relic of legacy security models. Modern web application design must reject this entirely. Authentication and authorization should never be optional or assumed.
Why the CISO Must Lead on Web App Security
It’s easy for CISOs to delegate web application security to development or DevOps teams. After all, developers build the systems, so they should secure them, right? The problem is that many development teams are focused on functionality and delivery timelines. Unless security is embedded into their culture and workflow, it becomes a checklist item—or worse, a post-deployment concern.
This is where the CISO’s leadership matters. The security team must provide tools, frameworks, and policies that bake security into the development lifecycle. Application security testing—both static and dynamic—should be integrated into CI/CD pipelines. Developers should be trained to understand threats like IDOR, XSS, and CSRF. Most importantly, security reviews should be required before any new functionality goes live, especially when sensitive data is involved.
A Culture of Continuous Verification
No application should ever go unchecked for long periods of time. Yet that’s exactly what happened in the First American case. For years, the system operated without proper security controls—and no one noticed. This is a failure of governance, process, and visibility.
To prevent this, CISOs must promote a culture of continuous security verification. This means more than just annual penetration tests or biannual audits. Web-facing systems should undergo:
- Frequent automated vulnerability scans
- Manual penetration testing that mimics real-world attacker behavior
- Source code reviews, especially for authentication and access control mechanisms
- Regular security configuration reviews and policy enforcement
Security testing should also include business logic validation—ensuring that the way a system handles data access aligns with security policies. Too often, automated tools miss logic flaws like those seen in First American’s case, which is why manual testing by skilled professionals remains critical.
Actionable Tip: Audit Public-Facing Web Applications Regularly
Every organization should maintain an up-to-date inventory of all public-facing web applications, APIs, portals, and document repositories. For each of these, security teams should:
- Ensure strong access controls are in place (authentication, authorization, token validation).
- Test for IDOR and similar access control vulnerabilities.
- Check for configuration drift or gaps in infrastructure security settings.
- Verify HTTPS enforcement and proper certificate management.
- Log and monitor access to sensitive endpoints for anomaly detection.
Additionally, it’s worth implementing a bug bounty or responsible disclosure program to give ethical hackers a channel to report vulnerabilities safely. In the First American case, it was an external party that discovered the issue—if a formal channel had existed, it might have been reported sooner, without going through journalists.
The First American breach reminds us that sophisticated cybersecurity strategies mean nothing if basic web application security is neglected. When an organization serving millions of customers leaves highly sensitive documents exposed simply due to lack of authentication, it’s a wake-up call for the entire industry.
For CISOs, the breach reinforces the need to prioritize the fundamentals. Before investing in bleeding-edge detection systems or AI-driven analytics, make sure your apps aren’t handing out sensitive data to anyone who types the right URL. Security doesn’t have to be complicated to be effective—but it does have to be deliberate, tested, and maintained.
Lesson 2: Sequence-Based Access Is a Security Red Flag
One of the most glaring technical failures behind the First American Financial data breach was the use of sequential document identifiers in public URLs. While this might seem like an innocuous design decision, it became the key that unlocked access to over 885 million sensitive records. For CISOs, this is a textbook case of why predictable access patterns are inherently dangerous—and why insecure direct object references (IDORs) must be eliminated wherever they exist.
Let’s break down what happened.
The system in question assigned each customer document a numeric ID. For example, if a user accessed a mortgage document via a URL like:
arduinoCopyEdithttps://www.firstam.com/documents/12345678.pdf
They could simply change the last part of the URL—say, to 12345679—and retrieve someone else’s document. The system didn’t authenticate the user or check whether they had permission to view the new document. It simply served whatever matched the requested ID.
This is the essence of an IDOR vulnerability—a failure to enforce object-level access control. And when identifiers are sequential, the problem is magnified dramatically. Instead of needing to guess a complex string or use brute force techniques, an attacker can simply iterate through numbers to pull data at scale. This transforms a one-off issue into a systemic vulnerability with massive exposure potential.
Predictable Identifiers = Easy Targets
Security through obscurity isn’t a defense strategy—but it’s also true that predictable patterns make exploitation trivial. When systems use sequential or guessable identifiers (like document IDs, user IDs, or order numbers), they lower the bar for discovery and abuse. Even someone with no coding skills can find sensitive data by editing the URL in their browser.
In the First American case, there was no rate limiting, no session enforcement, and no authorization check. The combination of these factors made sequential access a direct path to mass exposure. The problem wasn’t just that the IDs were sequential—it was that they were not protected by any access validation mechanism.
Why IDORs Are So Common—and So Dangerous
IDOR vulnerabilities are among the most common security flaws in modern web applications, particularly those with complex object models or large data stores. They’re often missed in automated scans because they involve business logic flaws, not just technical ones.
An IDOR vulnerability occurs when:
- A user requests a resource (e.g., a document, invoice, or user profile) via an identifier in the URL or request payload.
- The application uses that identifier to retrieve the object.
- But it fails to check whether the user is authorized to access it.
From an attacker’s perspective, these flaws are easy to find and exploit. From a defender’s perspective, they’re tricky because they require a clear, consistent access control policy across every object and API endpoint.
Modern Security Practice: Use Indirect, Randomized References
To avoid the risk of sequential or guessable identifiers, security-conscious organizations use:
- UUIDs (Universally Unique Identifiers) instead of integers.
- Access tokens tied to authenticated sessions.
- Signed URLs that expire after a short duration.
- Object-level permission checks enforced by the backend, regardless of the identifier’s format.
For example, rather than using:
bashCopyEdit/documents/12345678
Use something like:
bashCopyEdit/documents/f7b97d0e-77a3-4c62-b5df-3c26ef8b712c
This random, unique ID is much harder to guess or brute-force. But more importantly, the system should still check whether the user requesting the document has permission to access it. Obfuscation alone is not enough—it must be paired with proper authorization logic.
CISOs Need Visibility Into URL-Level Logic
This breach underlined something many CISOs already suspect: they don’t always have visibility into how business systems handle resource access. This is especially true when systems are developed in-house or by third-party vendors without rigorous security oversight.
CISOs must push for:
- Design reviews of APIs and URL structures to identify insecure patterns.
- Access control testing during QA cycles, not just during security assessments.
- Inclusion of IDOR checks in pentests and bug bounty programs.
Security teams need to understand how identifiers are generated, how access is validated, and how easily a user can manipulate request parameters.
Real-World Risk: Mass Harvesting of Sensitive Data
Insecure object references are not just theoretical risks. They’ve been behind many high-profile breaches. Attackers can script a loop to crawl through millions of records in minutes. Combine that with financial or personal data, and the stakes skyrocket.
Even when there’s no evidence of malicious exploitation, the potential for mass harvesting is itself a regulatory concern. In First American’s case, regulators didn’t wait for a confirmed leak—they acted based on the exposure risk alone. That’s a key shift in how data security is being judged today.
Actionable Tip: Replace Sequential IDs with Secure Alternatives
Here are practical steps CISOs should take to eliminate risks from sequence-based access:
- Audit all systems that use object references in URLs or APIs.
- Flag any use of sequential or guessable identifiers.
- Replace them with randomized UUIDs or opaque access tokens.
- Enforce object-level authorization checks on every request.
- Implement logging and anomaly detection for access patterns.
- Rate-limit access to endpoints that serve sensitive data.
Also, ensure your SDLC (Software Development Lifecycle) includes a secure design phase where the use of identifiers is reviewed not just for functionality but for exposure risk.
Why This Lesson Matters More Than Ever
As APIs become the backbone of modern digital platforms, the risk of IDOR vulnerabilities has increased. APIs often rely on parameters like user_id, document_id, or transaction_id—and if those are guessable or not properly validated, attackers can use automated tools to extract vast amounts of sensitive data undetected.
The First American breach may have happened through a web interface, but the same logic applies to APIs, mobile apps, and microservices. Anywhere a user requests data using an identifier, that request must be subject to strict access controls.
Predictable document IDs didn’t just make the First American breach possible—they made it dangerously easy. For CISOs, this incident serves as a warning: any system that allows sequential or guessable access to sensitive data without verifying permissions is a breach waiting to happen.
Security isn’t just about stopping intrusions—it’s about stopping exposure. And stopping exposure means eliminating design patterns that put sensitive data within reach of anyone willing to tweak a URL.
Lesson 3: Data Sensitivity Requires Defense-in-Depth
The First American Financial breach stands out not only for how it happened, but also for what was exposed. We’re talking about 885 million documents containing some of the most sensitive personal and financial information imaginable: Social Security numbers, bank account details, mortgage records, tax documents, wire transaction histories, and more. For an attacker, this is gold. And yet, all of it was publicly accessible—no login, no encryption, no access control.
This brings us to one of the most important lessons for CISOs: data sensitivity must directly inform the strength and depth of your security controls. If you’re storing or handling high-value data, a single security layer isn’t enough. You need defense-in-depth—a layered, strategic approach that combines multiple security measures to protect against different types of threats and failure points.
Not All Data Is Equal—So Don’t Treat It That Way
Far too often, organizations apply a flat security model across all systems. They’ll implement firewalls, access logs, and authentication protocols—and assume that’s enough, regardless of what’s behind those controls. But in reality, the more sensitive the data, the more aggressive and redundant your protections should be.
In First American’s case, the data exposed wasn’t low-risk metadata or marketing preferences—it was high-value, regulated, personally identifiable information (PII). It included:
- Full names
- Home addresses
- Bank account numbers
- Wire transaction histories
- Social Security numbers
- Mortgage details going back over a decade
This type of data is not only valuable to cybercriminals—it’s highly regulated under laws like GLBA, GDPR, and various state-level consumer protection laws. Exposure can lead to serious financial, legal, and reputational consequences.
So why wasn’t this data encrypted? Why wasn’t it protected by multi-layer access controls? Why was there no alerting mechanism in place to flag mass downloads or URL enumeration? Those are the questions that CISOs must ask—and answer—before a breach occurs.
Defense-in-Depth: What It Looks Like in Practice
Defense-in-depth is about building layers of security that complement and reinforce each other. No single control is foolproof. But when layered properly, these controls create friction for attackers, catch configuration errors early, and limit the blast radius if something does go wrong.
Here’s how a defense-in-depth model might have prevented—or at least greatly mitigated—the First American breach:
- Authentication Layer
Public users shouldn’t be able to access sensitive documents without verifying their identity. Even a basic authentication gateway requiring login credentials could have stopped casual access. - Authorization Checks
Once a user is authenticated, they should only be able to access their own records. Role-based access control (RBAC) or attribute-based access control (ABAC) policies should enforce this. - Tokenized or Signed URLs
URLs leading to sensitive documents should be time-bound and user-specific, generated dynamically after authentication—not based on static, predictable IDs. - Encryption at Rest and in Transit
All sensitive data should be encrypted using strong algorithms (AES-256 or better). This ensures that even if someone accesses the data store directly, the contents are unreadable without the keys. - Anomaly Detection and Logging
Access to sensitive documents should be monitored in real-time. Large-scale access attempts, especially from unauthenticated sources, should trigger alerts and automated lockdown procedures. - Data Segmentation and Least Privilege
Systems storing PII should be segmented from less sensitive systems. Only authorized applications or services should be able to interact with them, and only with the minimal required access.
Had even two or three of these layers been properly enforced at First American, the breach likely wouldn’t have occurred—or would have been limited to isolated incidents rather than a systemic, organization-wide exposure.
Understanding the Business Risk of Sensitive Data
Security controls should not be guided solely by technical architecture—they must be informed by business impact. What is the value of the data if stolen, misused, or leaked? What regulatory penalties could follow? How much brand trust would be lost?
CISOs should maintain a data classification framework that identifies which systems handle sensitive data, how that data flows, and what security standards apply at each touchpoint. This enables:
- Tailored security policies based on data sensitivity
- Prioritization of controls where they matter most
- Easier compliance reporting and audit readiness
Unfortunately, in the absence of clear data classification, sensitive systems often fall through the cracks—especially if they’ve been running quietly for years, like the document management system at First American.
Operationalizing Defense-in-Depth
For defense-in-depth to work, it must be operationalized—baked into the organization’s architecture, development lifecycle, and culture. That means:
- Embedding security engineers in dev teams
- Automating security tests and reviews in CI/CD pipelines
- Monitoring production systems with real-time alerting
- Regularly reviewing and refining controls based on evolving threats
This isn’t a one-and-done checklist—it’s an ongoing strategy that evolves with the business and technology stack.
Actionable Tip: Apply Strict Access Controls and Least Privilege for All Sensitive Systems
CISOs should conduct a full audit of systems that store or process PII, financial data, or other high-sensitivity information. For each, they should:
- Review access control configurations
- Ensure strong authentication and authorization mechanisms are in place
- Enforce least privilege at the user, service, and system levels
- Require encryption both at rest and in transit
- Implement centralized logging and anomaly detection for all data access events
Additionally, CISOs should implement zero trust principles, especially for high-value data systems. Trust nothing by default—verify everything.
Why This Still Matters in 2025 and Beyond
Although the First American breach happened in 2019, the core lesson is timeless: If you don’t protect sensitive data with multiple layers of defense, you’re one mistake away from disaster. As attack surfaces grow with APIs, mobile apps, cloud services, and third-party integrations, the need for defense-in-depth becomes even more critical.
Breaches are no longer just about stolen credentials or malware infections. They’re often the result of exposed systems, misconfigurations, and missing guardrails—exactly what happened in this case. And in an era where regulators are increasing scrutiny, ignorance of data sensitivity is no longer an excuse.
The First American breach wasn’t just a technical failure—it was a failure to match security controls to data value. No matter how sleek the front-end is or how efficient the backend runs, if your security posture doesn’t reflect the sensitivity of your data, your organization is vulnerable.
For CISOs, the mandate is clear: build layered defenses that assume failure will happen somewhere—and make sure it doesn’t cascade into catastrophe. That’s the only way to truly secure critical data in a world where exposure is just one misconfiguration away.
Lesson 4: Security Testing Must Mirror Real-World Exploits
One of the most critical insights from the First American Financial data breach is that security testing must go beyond the basics. This wasn’t a sophisticated attack carried out by a skilled hacker using advanced techniques. Instead, it was the result of a basic, but all-too-common, oversight in security testing: the failure to properly assess how the system would respond to real-world exploits.
The breach occurred when a user discovered that by simply changing the document ID in the URL, they could access other sensitive documents—this was a direct object reference vulnerability that was exploited in a simple manner: URL manipulation. This kind of flaw is a textbook example of an issue that should have been caught during testing. However, because security testing didn’t mirror real-world exploit scenarios, the breach went undetected for months.
For CISOs and security teams, the lesson here is clear: security testing cannot be a generic, checklist-based activity. It must actively simulate how attackers would exploit vulnerabilities in ways that reflect real-world tactics, techniques, and procedures (TTPs).
The Gaps in Basic Testing
In many organizations, security testing primarily focuses on automated vulnerability scanners or static code analysis tools. While these are useful, they often miss the human element—how a motivated attacker would probe the system using trial and error or creative techniques. In the case of the First American breach, the vulnerability was exposed by someone who simply manipulated the URL. A typical automated scan would have likely failed to identify this type of risk because it’s not a typical code vulnerability—it’s a logic flaw.
The breach highlights that traditional security testing often overlooks business logic vulnerabilities, like IDORs, that can be easily exploited in production environments.
Why Real-World Testing Matters
Real-world testing is about going beyond static analysis to ensure that applications are resilient against the kinds of attacks seen in the wild. Many breaches today arise not from zero-day vulnerabilities or sophisticated malware but from simple misconfigurations or easily exploited weaknesses that could be identified by someone with little more than curiosity and basic web skills. In the case of First American, it was a simple URL manipulation that exposed hundreds of millions of sensitive documents.
Security tests should mirror these real-world attack patterns to truly assess the security posture of a system. Here’s why this approach matters:
- Attackers are Creative
The First American breach shows that even a relatively low-tech, “low-effort” exploit can lead to a massive breach if the system isn’t adequately tested for such weaknesses. Attackers will always look for creative ways to abuse the system—even seemingly harmless URL manipulation. Therefore, the testing process should replicate this creativity. - Security is Not Just about Coding Errors
Many organizations focus primarily on identifying coding vulnerabilities such as buffer overflows, SQL injection, and cross-site scripting (XSS). While important, these traditional vulnerabilities are not the only risks companies face. Business logic vulnerabilities, like those seen in this breach, require a different testing mindset—one that takes into account the intentional and unintentional ways users and attackers might interact with the system. - Increased Complexity of Modern Environments
As companies adopt cloud services, microservices, APIs, and third-party integrations, security testing becomes exponentially more complex. It’s no longer just about testing a static website—now, security teams must test how different pieces of the system interact across environments and external partners. The failure to account for all possible attack surfaces can leave significant gaps.
Dynamic and Manual Testing: Key to Catching Exploits
In response to these challenges, CISOs should prioritize dynamic testing—the practice of simulating real-world attacks while the application is running. This goes beyond static code scans and includes techniques like:
- Penetration Testing
Pen testing is one of the most effective ways to simulate how a motivated attacker would attempt to exploit a system. Ethical hackers mimic common attack methods, from social engineering to technical exploits, in an attempt to identify weaknesses. In the First American breach, a penetration test focused on URL manipulation or enumeration might have easily detected the vulnerability. - Manual Security Assessments
Automated tools are great at catching certain types of vulnerabilities, but manual security assessments are needed to spot logic flaws and more nuanced vulnerabilities. A trained security expert might have noticed the patterns in the URLs or attempted to manipulate document IDs, recognizing the exposed information early in the process. - Red Teaming
Red team exercises involve simulating full-scale attacks from an adversarial perspective. By going through the motions of a real-world attack—using social engineering, phishing, or technical exploits—red teams provide valuable insight into how attackers will exploit system weaknesses. For a breach like First American’s, red teaming would have been an effective way to uncover weaknesses like the sequential document IDs before they could be exploited.
Testing Business Logic, Not Just Code
A critical takeaway from the First American breach is that traditional security testing methods often fail to address business logic vulnerabilities. These are flaws that stem from how the system is designed to handle transactions, user requests, and data access.
A classic example of business logic vulnerability is Insecure Direct Object Reference (IDOR), as seen in this breach. With IDOR, an attacker can manipulate parameters (such as the document ID) to access data they shouldn’t have access to. The vulnerability arises from an insufficient check on user permissions at the object level, which automated scanners often overlook.
CISOs should ensure that their testing includes manual validation of business logic. This can involve:
- Testing how authentication and authorization are implemented across business workflows.
- Reviewing how data is exposed to end-users, especially with respect to sensitive resources.
- Ensuring that changes in parameters (like a document ID or transaction ID) are adequately controlled by proper access checks.
Actionable Tip: Include Business Logic and Access Control Tests in Security Assessments
The First American breach is a clear reminder that security teams must include business logic testing as part of their security assessments. To improve your testing processes:
- Audit Business Logic: Ensure that sensitive objects (documents, records, or transactions) are subject to authorization checks, regardless of the identifier format.
- Manual Testing: Use manual penetration testing techniques to evaluate potential exploits based on user behavior or URL manipulation.
- Incorporate Threat Modeling: Map out the most likely attack vectors for high-value data and design security tests to simulate those scenarios.
- Include Realistic Attack Simulations: Regularly simulate real-world attack scenarios—whether through red team exercises or threat-hunting activities.
Why This Matters Now and Going Forward
As we move deeper into the age of cloud computing, APIs, and microservices, the attack surface grows ever larger. The First American breach is a reminder that attackers can still exploit basic weaknesses if we don’t properly assess how our systems interact and respond to user requests. Testing must evolve to include realistic attack scenarios, business logic failures, and deep dives into how real-world exploits play out.
The First American breach was a wake-up call for organizations to adjust their security testing strategies. Automated scans and vulnerability assessments alone are insufficient—they must be complemented by dynamic, real-world testing that simulates how attackers exploit systems in the wild.
For CISOs, this means ensuring that penetration testing, red teaming, and manual reviews are all part of the continuous process of securing business-critical systems. When security testing is comprehensive and reflects real-world exploits, the organization is far better prepared to prevent the next breach.
Lesson 5: Third-Party Risk and Legacy Systems
In many ways, the First American Financial breach was a wake-up call about the risks associated with third-party services and legacy systems. The breach exposed over 885 million sensitive documents, many of which were related to mortgages, financial transactions, and other personal data. The exposed data spanned 16 years, which suggests that some of it may have come from outdated systems or platforms that were no longer properly maintained or adequately secured.
When CISOs consider the overall security posture of their organizations, it’s crucial to account for third-party risks and legacy systems, both of which can pose significant vulnerabilities if left unchecked.
The Danger of Legacy Systems
One of the most significant contributors to the First American breach was the legacy nature of the system that hosted the exposed documents. Many of these documents had been stored for years, possibly in a system that wasn’t regularly updated, patched, or configured to current security standards. These legacy systems often have a persistent presence in organizations that continue to operate, even as the rest of the infrastructure moves forward with modern technologies.
Legacy systems refer to older software or hardware systems that are still in use, despite being outdated or no longer supported by vendors. These systems may not receive regular updates or security patches, making them vulnerable to exploitation by attackers. In the case of First American, the exposed documents, some of which dated back 16 years, suggest that the company relied on outdated technology that likely contributed to the security failure.
Here are a few reasons why legacy systems often pose a significant security risk:
- End-of-Life Software and Hardware: Legacy systems typically use outdated operating systems or software that vendors no longer support. This means they no longer receive critical security patches, leaving them vulnerable to attacks.
- Complexity and Lack of Documentation: Over time, systems become more complex, and their documentation becomes sparse or non-existent. This makes it difficult for security teams to assess vulnerabilities and ensure proper security measures are in place.
- Integration with Newer Systems: Legacy systems are often integrated with newer systems, creating an inconsistent security posture across the organization. This can lead to gaps where older systems are not subject to the same level of security scrutiny as newer technologies.
- Obsolescence of Security Features: Older systems might not support modern encryption protocols, multi-factor authentication (MFA), or other advanced security features. As cyber threats evolve, these older systems remain at risk.
In the case of First American, it seems likely that a combination of legacy systems and misconfigurations led to the exposure of highly sensitive data. The fact that the breach involved data spanning 16 years suggests that the company didn’t adequately modernize or retire these outdated systems, leaving them vulnerable to simple exploits like URL manipulation.
Third-Party Risk: A Growing Concern
Alongside legacy systems, the risk posed by third-party vendors is a growing concern for organizations today. Many modern businesses depend on third-party providers for everything from cloud hosting and payment processing to CRM and data storage. However, vendors can introduce their own vulnerabilities into the organization, especially if those vendors don’t follow stringent security protocols or fail to keep their systems up to date.
Third-party vendors can impact your security posture in several ways:
- Unvetted Access: Vendors often have access to sensitive systems and data, and if they don’t follow the same level of security standards, they can become an entry point for attackers.
- Third-Party Software Risks: Many organizations use third-party software or services that can contain vulnerabilities. Without strong oversight or regular assessments, these vulnerabilities can become a weak link in your organization’s security.
- Lack of Vendor Security Audits: Some organizations fail to conduct regular security audits on third-party vendors. Without these audits, it becomes nearly impossible to know whether a vendor is adhering to the necessary security standards to protect your data.
- Supply Chain Attacks: Attackers increasingly target vendors in supply chain attacks. By compromising a trusted third party, they can gain access to your organization’s systems indirectly. The SolarWinds breach in 2020 is an infamous example of how a vendor’s compromised software can spread through an organization’s entire ecosystem.
While there is no evidence that a third-party vendor was involved in the First American breach, the risk is still significant. If the company had a third-party vendor providing document management services, for instance, it would be essential to verify that their security practices were up to date and that their systems were properly configured to ensure data protection.
Risk Mitigation: Managing Legacy Systems and Third-Party Access
For CISOs, managing third-party risk and legacy systems should be a priority in today’s security landscape. Both represent significant exposure points that attackers will readily exploit if they’re left unchecked.
Here are actionable steps to mitigate the risks associated with legacy systems and third-party vendors:
- Modernize Legacy Systems
Organizations must make it a priority to modernize or replace legacy systems that no longer meet security standards. This may involve migrating to cloud-based platforms or updating old software to support the latest security protocols. For legacy systems that can’t be immediately replaced, CISOs should ensure that additional controls are in place, such as network segmentation, to limit access to sensitive data. - Conduct Regular Third-Party Security Audits
A critical part of managing third-party risk is ensuring that vendors adhere to the same level of security standards you apply internally. This means conducting regular security audits of all third-party vendors that have access to sensitive data or systems. Audits should review:- Data access policies
- Compliance with industry regulations
- Penetration testing and vulnerability management practices
- Security incident response plans
- Data encryption and backup policies
- Adopt a Vendor Risk Management Framework
Implementing a formal vendor risk management framework can help ensure that third parties are properly vetted and monitored throughout the relationship. This includes assessing potential risks before onboarding vendors and ensuring that there are contractual obligations for data protection, incident reporting, and security controls. - Implement Strong Access Control and Monitoring
Regardless of whether the system is a legacy platform or a third-party application, it’s critical to implement strong access controls to restrict who can access sensitive data. For example, access should be granted on a need-to-know basis and role-based access controls (RBAC) should be used to ensure that only authorized users can view or modify sensitive documents. - Retire or Segment Obsolete Systems
Organizations should retire outdated systems whenever possible and, where it’s not feasible, segregate them from modern systems. This reduces the risk that a vulnerability in an outdated system could lead to a compromise of newer, more secure applications. - Ensure Data Encryption and Backup
All sensitive data should be encrypted both in transit and at rest. Additionally, organizations should have strong data backup procedures in place to ensure data can be recovered in case of a breach or system failure.
The First American breach serves as a poignant reminder that legacy systems and third-party risks are not just technical concerns—they are fundamental components of an organization’s overall security posture. By ensuring that outdated systems are modernized or properly segmented, and by holding third-party vendors to high security standards, CISOs can significantly reduce the risk of a similar breach occurring in their own organization.
Modernizing legacy systems, regularly auditing third-party vendors, and applying strong access controls are all critical actions that can help mitigate these risks. In today’s increasingly interconnected world, where data is shared across multiple platforms and providers, these practices are essential to maintaining a strong security posture.
Lesson 6: Incident Response Plans Should Cover Non-Hacked Exposures
The First American Financial breach was not the result of a hack, but rather the result of a misconfiguration in the company’s public-facing system. This highlights an important, often overlooked gap in many organizations’ incident response (IR) plans: non-hacked exposures—such as misconfigurations, accidental data leaks, or unsecured access points—are just as dangerous as actual breaches, and they require a tailored response plan.
Many incident response plans are designed primarily with the assumption that a breach will involve malicious actors exploiting vulnerabilities, using tactics like phishing, malware deployment, or unauthorized access. However, in the case of First American, the vulnerability stemmed from a basic misconfiguration—an open system allowing anyone to access sensitive information by simply altering the URL. This type of exposure can be just as damaging as a hacker breaching your system but may be overlooked in traditional IR frameworks.
For CISOs and security teams, the lesson here is simple but crucial: incident response plans should encompass not just active breaches but also situations where sensitive data is exposed due to internal errors or system misconfigurations. This comprehensive approach will help organizations prepare for and respond to a wider array of threats and vulnerabilities.
The Gaps in Traditional Incident Response Plans
Traditional incident response plans are typically built around the concept of a cyber attack—where an external party infiltrates the network or system to steal or compromise data. This model makes sense because most high-profile breaches have been driven by external actors using advanced techniques or leveraging zero-day vulnerabilities.
However, misconfigurations, as seen in the First American breach, fall outside of this typical model. A misconfiguration might involve leaving a system open to public access without proper authentication, failing to apply the latest security patches, or exposing sensitive information through a third-party service. In such cases, there’s no external actor involved, but the organization is still at significant risk because sensitive data is inadvertently made accessible.
When incident response teams are too narrowly focused on traditional breach scenarios, they may fail to identify or prioritize a misconfiguration or unintentional exposure. In the First American breach, the company likely did not perceive the exposure as an urgent security issue because it wasn’t caused by a malicious actor. Consequently, it took months before the vulnerability was addressed—by that time, 885 million records had been exposed.
Broadening the Scope of Incident Response Plans
To ensure that organizations are prepared for non-hacked exposures, incident response plans should be expanded to include the following critical elements:
- Detection of Misconfigurations and Accidental Exposures
The first step in responding to any security incident—be it a breach, misconfiguration, or exposure—is detecting the issue early. Misconfigurations like the one that led to the First American breach are often difficult to spot because they don’t involve active attacks. Detection must focus not just on malicious activities but also on errors, such as:- Publicly accessible endpoints
- Open ports and services not properly secured
- Unrestricted access to sensitive data due to weak authentication mechanisms
- Weak configuration settings for cloud services and third-party platforms
- A Structured Response Process for Misconfigurations
Once an exposure is detected, the next step is to respond effectively. In a breach involving a misconfiguration, the focus should be on mitigating the exposure by promptly closing off the vulnerability. This may involve:- Reversing public access to sensitive data or systems
- Securing misconfigured access points
- Updating access controls and authentication mechanisms
- Applying additional security measures to prevent further exposures
- Communication Strategy for Exposures
Communication is one of the most critical components of any incident response. In the case of a misconfiguration, the organization must communicate quickly and clearly with internal teams, stakeholders, and affected individuals. Unlike breaches caused by external attackers, where the focus is on containment and recovery, communication during a misconfiguration exposure may also involve explaining the root cause of the incident and how it will be rectified. The communication plan should:- Notify affected parties as soon as possible, even if no malicious activity has been detected
- Provide clear and transparent updates on the incident and the steps being taken to resolve it
- Address any potential legal or regulatory obligations, such as data protection laws (e.g., GDPR, CCPA) that may require notification of the exposure
- Assure stakeholders that corrective measures are being implemented to prevent a recurrence
- Preventative Measures for the Future
A robust IR plan for non-hacked exposures should not only focus on the immediate incident but also on preventing future issues. After the misconfiguration is addressed, CISOs should take the following steps:- Perform a root cause analysis to understand why the exposure occurred and whether any processes or tools failed.
- Implement stricter configuration controls to ensure that no future mistakes are made. This may include:
- Setting up automated checks for exposed sensitive data
- Enhancing access controls and authentication mechanisms
- Training employees to recognize configuration risks and follow best practices for secure system setup
- Review incident response protocols to ensure they are adequate for a broad range of exposure types.
- Ongoing Training and Awareness
Because non-hacked exposures like misconfigurations are often human errors, regular training for both IT staff and end users is essential. Security awareness training should be integrated into the onboarding process and include topics like:- Secure configuration practices
- Recognizing the signs of misconfigured systems or exposed data
- Reporting potential vulnerabilities or security risks
Actionable Tip: Broaden Incident Response Playbooks
CISOs should ensure that their incident response playbooks explicitly address misconfigurations, data leaks, and other non-malicious exposures, in addition to more traditional breach scenarios. The plan should outline specific actions, including:
- How to identify and classify the exposure
- Immediate steps to stop the data exposure (e.g., locking down access, securing misconfigured endpoints)
- Communication strategies for informing stakeholders
- Measures to prevent recurrence, such as automated configuration checks and better access controls
The First American breach is a valuable reminder that incident response planning must go beyond just traditional breach scenarios. Misconfigurations, accidental data leaks, and unintentional exposures can be just as harmful as malicious hacking attempts and should be treated with the same urgency.
By broadening the scope of incident response plans to include a wide range of potential vulnerabilities—whether caused by human error, misconfiguration, or other causes—CISOs can ensure their organizations are prepared for the diverse security challenges of the modern digital landscape.
Incident response should not only be reactive but also proactive, addressing potential vulnerabilities before they lead to incidents. This approach will help build more resilient systems and improve the organization’s ability to respond quickly to a variety of exposure scenarios, safeguarding sensitive data and maintaining stakeholder trust.
Lesson 7: Breach Disclosure and Communication Are Critical
In the case of the First American Financial breach, communication was a critical component of the response, but it was also one of the areas where the company faced challenges. While the breach was quickly fixed, the public response, particularly regarding the timeliness and clarity of the company’s communications, left much to be desired.
This reinforces the essential lesson for CISOs and organizations: breach disclosure and communication must be clear, timely, and transparent—especially when dealing with significant data exposures, regardless of whether the event was a full-scale hack or a simple misconfiguration.
In today’s digital age, where data breaches and privacy violations are increasingly common, how a company communicates a breach can have a lasting impact not only on regulatory compliance but also on reputation, trust, and overall customer confidence. If a breach is handled poorly, it can lead to a loss of trust, legal ramifications, and significant reputational damage. By contrast, swift and transparent communication can help manage the situation, provide clarity to affected individuals, and mitigate negative fallout.
The Importance of Clear and Timely Communication
When the First American breach occurred, the company’s immediate action was to address the misconfiguration, which involved correcting the exposure of sensitive records. While prompt technical fixes are important, it is equally important to communicate these actions to stakeholders, including customers, regulators, and the public. However, the delay in disclosure—coupled with unclear or incomplete messaging—led to questions about the company’s overall transparency and commitment to addressing the issue.
Regulatory Requirements and Transparency
The breach at First American involved the exposure of highly sensitive data, including Social Security numbers (SSNs), bank records, and wire transaction details. While no malicious use of the exposed data was reported, the sheer scale of the breach (affecting 885 million individuals) meant that the company was bound by regulatory requirements related to data protection and breach disclosure.
Many data protection laws, such as the General Data Protection Regulation (GDPR) in Europe, California Consumer Privacy Act (CCPA) in the U.S., and various industry-specific standards, mandate timely and transparent breach notifications to affected individuals and relevant authorities. Even though the First American breach was caused by an internal misconfiguration, it still constituted a data exposure that could have resulted in harm had the data been accessed maliciously.
For instance, the GDPR requires organizations to report data breaches to authorities within 72 hours if the breach involves personal data that could result in risks to individuals’ rights and freedoms. While the First American breach may not have involved criminal activity, it still triggered a need for timely disclosure. Delayed reporting or incomplete communication about the exposure could have resulted in regulatory fines or sanctions, and more importantly, in loss of trust among customers.
To ensure compliance with data protection regulations, it is crucial for organizations to have a well-defined breach disclosure protocol in place. This includes not only technical fixes but also communication procedures with stakeholders. Regulatory bodies need to be informed, as well as customers and other affected parties.
Key Elements of Effective Breach Communication
Breach communication must meet several standards to be effective and minimize negative consequences. Here are key elements that should be included in any breach disclosure:
- Timeliness
Timing is everything when it comes to communicating a breach. The First American breach is an example of how delayed disclosure can cause further reputational damage. Companies must communicate as soon as possible once the breach is detected, outlining what happened and what is being done to fix the situation. Transparency from the start is crucial to preventing rumors, confusion, and misinformation. Organizations should aim for a clear, timely initial statement, even if all details are not yet available. This first communication should acknowledge the issue, provide a brief explanation, and assure affected individuals that corrective actions are being taken. - Clarity and Transparency
It is essential that breach communications be clear and transparent. Vague or evasive messaging can heighten distrust and lead to negative perceptions about the company’s commitment to security. In the case of First American, the initial communication lacked some clarity about the cause of the exposure and the steps being taken to remedy it. Clear messaging should explain:- What occurred (the root cause of the exposure, such as a misconfiguration)
- The scale of the exposure (number of individuals or records affected)
- The actions being taken to resolve the issue
- Any steps taken to prevent recurrence
- Addressing Stakeholder Concerns
Beyond customers, a breach can affect a range of stakeholders, including partners, investors, and regulators. Investors and shareholders are particularly sensitive to breaches, as they can lead to stock price declines, legal action, and significant financial losses. Clear communication with stakeholders can help mitigate potential financial fallout and demonstrate the company’s commitment to security. Regulatory bodies need to be informed as soon as possible, and the company must work to meet any reporting deadlines imposed by applicable laws. For First American, this would have included a notification to data protection authorities and, depending on the jurisdiction, the affected individuals themselves. - Offering Support to Affected Individuals
For many companies, the most important communication will be with affected individuals—those whose personal or financial data has been exposed. Companies should provide ongoing support to these individuals, including offering free credit monitoring, identity theft protection, or advice on how to safeguard their personal information. In the case of First American, while the data was not actively exploited, offering support to affected individuals would have been important to demonstrating the company’s accountability and care for customer welfare. Such measures help rebuild trust and show a genuine commitment to securing sensitive data. - Long-Term Communication and Follow-Up
After the initial disclosure, organizations should continue to provide updates as the situation evolves. Follow-up communication should inform stakeholders of additional steps taken to enhance security, prevent recurrence, and protect affected individuals. It is important to close the loop by communicating to the public once corrective actions have been successfully implemented and any investigations have been concluded. Additionally, long-term transparency is critical in showing that the company has learned from the breach and is actively working to prevent similar incidents in the future.
Actionable Tip: Have a Pre-Established Breach Communication Plan
One of the most critical takeaways from the First American breach is the need for a pre-established breach communication plan. CISOs should work with legal, PR, and leadership teams to design a framework for how to handle any potential breach or exposure. This plan should be regularly updated and include:
- Specific communication templates for various types of incidents (e.g., misconfiguration, hacker breach, third-party failure)
- Clear roles and responsibilities for internal teams involved in breach communication
- Timelines for notifying affected individuals and regulatory bodies
- A strategy for providing support to those affected by the breach
The First American breach is a poignant reminder that effective breach communication is just as important as technical fixes. By ensuring that breach disclosures are clear, timely, and transparent, organizations can reduce the reputational damage caused by a breach and maintain trust with customers, stakeholders, and regulators. Proactively addressing communication, offering support to affected individuals, and adhering to legal and regulatory requirements will position organizations to better handle future incidents and protect their reputation in the long term.
Conclusion: Breach Lessons That Still Matter
The First American Financial Corporation data breach of 2019, though stemming from a simple misconfiguration, serves as a reminder that even basic vulnerabilities can lead to massive consequences when sensitive data is involved.
The breach exposed the personal information of 885 million individuals, including Social Security numbers, bank account records, and wire transfer details. While no malicious use of the data was reported, the potential for harm was vast, illustrating the profound risks associated with poor configuration management and lax security practices.
Despite the breach’s origin being tied to an internal error, the lessons it offers to CISOs and security professionals are profound and still highly relevant today. It underscores the critical importance of securing sensitive data, ensuring robust security configurations, and maintaining vigilant oversight of web-facing systems. This incident serves as a cautionary tale for organizations of all sizes and industries—reminding them that security is never just about defending against hackers, but about preventing all forms of exposure, even the accidental ones.
Key Takeaways from the First American Breach
The breach highlighted several key lessons that every CISO should internalize to build stronger, more resilient systems:
- The Importance of Web Application Security
Simple misconfigurations—like failing to restrict public access to sensitive data—can lead to catastrophic consequences. In today’s interconnected world, public-facing systems are under constant threat, whether from hackers or internal errors. Properly configuring access controls and employing robust authentication mechanisms is not optional; it’s fundamental. Security isn’t just about preventing attacks but also ensuring that systems are built with security in mind from the start. - The Dangers of Sequence-Based Access
Using predictable identifiers (like sequential document IDs) to access sensitive resources is a red flag. Such systems invite attackers to exploit insecure direct object references (IDORs), potentially giving them access to private data with minimal effort. Moving away from sequential identifiers to randomized or encrypted IDs can significantly reduce the risk of unauthorized access. - Defense-in-Depth for Sensitive Data
PII, financial records, and other sensitive data require a multi-layered approach to security. Defense-in-depth ensures that if one layer fails, others are still in place to protect the data. Proper encryption, access controls, and monitoring should be used to safeguard valuable data—especially when it involves personal financial information that could be exploited for identity theft or fraud. - Security Testing Must Be Comprehensive
Testing security configurations should go beyond automated scans and should include manual testing and real-world attack simulations. Ensuring that web applications are secure requires testing that replicates actual exploitation scenarios, including the possibility of misconfigurations or human errors. Automated scans may miss important vulnerabilities, like those exposed by an overlooked misconfiguration. - Managing Third-Party and Legacy System Risks
The First American breach lasted 16 years and likely involved legacy systems that were poorly maintained. When organizations retain data for long periods, they must be diligent in monitoring older systems, assessing their vulnerabilities, and ensuring that outdated platforms are upgraded or decommissioned. Risks associated with third-party platforms and legacy systems need to be carefully evaluated as part of an organization’s broader cybersecurity strategy. - Incident Response Plans Should Include Non-Hacked Exposures
While most breach response plans focus on external attacks, they should also cover scenarios where data is exposed due to internal errors—such as misconfigurations. Not every exposure involves a malicious actor, but the consequences can still be severe. Ensuring that IR plans are comprehensive and flexible enough to handle various types of breaches, including accidental data leaks, is essential for quick containment and effective damage control. - Timely and Transparent Communication Is Crucial
First American faced scrutiny not just for the breach but also for how it communicated the incident to the public. Breach disclosure must be handled with care, as poor communication can damage reputation and trust. CISOs should ensure that their breach response includes clear, timely, and transparent updates to all stakeholders, including customers, regulators, and the general public.
Why This Incident Still Matters Today
The First American Financial breach occurred in 2019, but its lessons continue to resonate, especially given the rising frequency and sophistication of data breaches. Despite the breach’s cause being a misconfiguration, its implications are still relevant for CISOs across industries:
- The Risk of Internal Exposures
The First American breach shows that internal errors—whether from misconfigured systems or human mistakes—are often just as damaging as external cyberattacks. This emphasizes the need for continuous security training, audit processes, and automated security checks to prevent such lapses from occurring. - Growing Regulatory Scrutiny
The growing landscape of data protection laws, including the GDPR, CCPA, and other regional regulations, means organizations are under increasing pressure to maintain security compliance and respond to breaches swiftly. Non-compliance with these laws can result in severe fines, which adds urgency to early detection, swift action, and proper reporting of breaches. - Public Awareness and Trust
As customers become more aware of their privacy rights and the risks of having their personal data exposed, trust becomes a key factor in a company’s brand equity. Organizations that fail to secure sensitive data—whether due to a hack, misconfiguration, or accidental exposure—risk significant reputational damage. Therefore, building a culture of security-first thinking and transparency is essential for organizations that want to maintain public trust.
Final Takeaway for CISOs
The First American breach should serve as a wake-up call to all organizations, regardless of size or industry. Security is not just about preventing external attacks, but about creating a holistic approach to data protection that involves addressing internal risks, performing regular audits, and developing a culture of security awareness throughout the organization. By taking proactive steps to secure systems, communicate effectively, and respond to incidents swiftly, CISOs can mitigate risks and build more resilient, secure systems.
Ultimately, the key takeaway from the First American breach is this: Even low-tech, seemingly simple errors—like an exposed misconfiguration—can lead to high-stakes damage. It’s imperative for CISOs to learn from the past, implement best practices, and build stronger defenses for the future.