On 14 October 2025, our monitoring flagged logins to twenty-three broker portal accounts from unfamiliar networks, using passwords reused from breaches elsewhere. One session viewed the records of forty-one policyholders, including addresses and contract values, before we suspended the accounts. The portal had 1,900 users across 420 broker firms, and multi-factor authentication was optional; about a third used it. December, when many savers make their pension contributions for the year, was seven weeks away.
The data-protection officer concluded that the access was notifiable under GDPR. We notified the Italian data-protection authority within seventy-two hours and wrote to the forty-one policyholders. Against DORA's major-incident criteria it fell short; we recorded that classification and reported it to the risk committee.
The commercial director proposed phasing in compulsory authentication from February, after the December peak, to avoid disrupting brokers at their busiest. His concern was fair: a portal brokers could not use would send business to other insurers. I recommended making it mandatory for every user by 2 November, nineteen days after detection. The reused passwords could be tried again at any moment, and December would concentrate the access an attacker wanted. The chief executive accepted my recommendation.
We gave up convenience and money. We staffed a temporary helpdesk of eight people, supplied hardware keys to firms that could not use phone apps and opened a secure upload route for brokers not yet enrolled. The additional cost was €240,000. Some brokers were angry, and two firms complained formally.
By 1 December, 97.8 per cent of users had enrolled. December portal submissions reached 94 per cent of the previous December's volume, and most of the shortfall arrived in January. We have seen no further account takeover.
What I would do differently is uncomfortable. When we rebuilt the portal in 2021, I agreed to leave the second factor optional because brokers asked for it. That was my decision and it was wrong; correcting it during an incident cost far more than requiring it then.