New data breach laws in Australia mean that if an incident like this happened again, disclosure would be legally required.
The bank said it could not confirm that the tapes containing the 15 years of data were destroyed. Fuji Xerox officials could not be immediately reached for comment.
"But we also need to recognise that based on CBA's statements, it seems highly likely the data never fell into malicious hands and whilst it's natural for people to feel that their privacy has been violated, it seems highly unlikely any unauthorised party saw the data and that it will result in any tangible loss or impact on them".
In April, the inquiry heard that the Commonwealth bank collected fees from customers it knew had died. "We concluded, given the results of the investigation, that we would not alert customers", Sullivan said in a statement, adding that the bank consulted with the OAIC on that matter.
"But this maintaining data security is of vital importance for everybody, whether it's the private sector or governments, and if there is a serious data breach or loss, the people affected should be advised so they can take steps to protect themselves".
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Because the potential breach occurred two years ago, Australia's mandatory breach notification law doesn't apply.
"A data disaster is coming", Brody said.
The incident is "not the same as a USB stick, let's be fair", Hunt says.
Commonwealth Bank of Australia (CBA) CBA.AX , the country's top lender, confirmed on Thursday it lost records of nearly 20 million accounts and made a decision to not inform its clients, a breach the nation's prime minister called "an extraordinary blunder".
CBA said it notified both the Office of the Australian Information Commissioner and the Australian Prudential Regulation Authority (APRA) of the incident. It is continuing to monitor the affected accounts for suspicious activity.
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The bank admits it was "unable to confirm the scheduled destruction of two magnetic tapes", but claims the tapes did not contain passwords, PIN numbers, or "other data which could enable account fraud". The tapes contained customer names, addresses, account numbers and transaction details from 2000 to early 2016.
Commonwealth also hired KPMG to conduct an independent investigation. According to CBA, KPMG found the "most likely scenario was the tapes had been disposed of".
"I think what we'd always do with something like this is, with the prominence of it, go back and check across all our policies and practices to make sure that they are right and they are being done", Mr Thorburn said. "That's not to say they shouldn't disclose when necessary, it's just saying, if it was not necessary, I could very well them understand not disclosing". The data on the tapes was apparently not encrypted. Another question is why Commonwealth did not delete the tapes before sending them off for destruction.
Branch of Commonwealth Bank in Melbourne. In December, Australia launched a Royal Commission into misconduct in financial services. "If that had happened today, the bank would have to advise each of their customers".
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