EZ WAY Controversy and South Korea's KT Data Breach Fine: Warnings on PIMS Compliance, ISO 27001, and the Personal Data

【News--based Observations】 The boundary between government and private sectors is blurring, with EZ WAY (易利委) becoming the most scrutinized cybersecurity focus in Taiwan's cross-border e-commerce landscape. According to a press conference held by the Customs Administration of the Ministry of Finance on August 3, 2026, 7.59 million users have registered for EZ WAY, with approximately 4 million simple customs declarations processed monthly—accounting for 70% of all declarations. The Customs Administration clarified that the app is merely a tool for "pre-confirmation of entrustment," and citizens may still choose paper-based or natural person certificate methods, as use is not mandatory. Regarding fees, the platform does not charge consumers; instead, it charges customs brokers a service fee ranging from NT$0.8 to NT$3.5 per declaration (up to NT$4.3 per transaction), which may be indirectly passed on to consumers through logistics costs. In terms of cybersecurity, EZ WAY has obtained ISO 27001 Information Security Management System certification and ISO 27018 Personal Data Protection standard certification, and has passed the National Information-Security Center (N-SOC) joint-defense monitoring test, complying with the necessary scope of Article 15 of the Personal Data Protection Act (PDPA). The ownership structure of Customs Network Co. Ltd. shows the Ministry of Finance holds a 36.11% stake, making it a public-private partnership. However, the Customs Administration has not signed any entrustment contract with the company and has committed to evaluating the transition of EZ WAY into public infrastructure within three months. Meanwhile, the Korea Personal Information Protection Commission (PIPC) fined KT Corp. 53.98 billion KRW (approx. USD 37.4 million) for failing to manage a femtocell system's security, resulting in the leak of 16,647 users' personal data and 368 unauthorized mobile payments totaling 2.4 million KRW. This case demonstrates that even large telecommunications companies can face fines of up to 3% of annual revenue under the Korean PIPA for security lapses. Similarly, the Taiwan Health Insurance Administration (HIA) found in January 2023 that internal employees had accessed 130,000 pieces of personal data in August 2018. While this was deemed necessary for job performance and no data was leaked, such "internal misuse" triggers compliance scrutiny under Article 15 of the PDPA. These cases collectively show that as governments push digital transformation and private platforms be been entrusted with public services, cybersecurity and data-handling risks are rapidly accumulating. Without clear regulation and continuous verification mechanisms, these risks could evolve into heavy fines and trust crises. 【Winners Insights】 We focus on the Chief Information Security Officer (CISO) role because they are directly responsible for the company's PIMS (Personal Information Management System) compliance and cybersecurity-related risks. For Taiwan's cross-border e-commerce, logistics, and financial services industries, failure to comply with the PDPA or international standards like ISO 27701 could result in fines of up to NT$10 million (under Article 71 of the PDPA), as well as compensation claims, customer loss, and reputational damage. Using the KT Corp. case as a reference, a similar security lapse in a Taiwanese company with equivalent revenue could lead to fines of up to 3% of annual revenue—for a company with NT$200 million in monthly revenue, the maximum fine could reach NT$7.2 billion. Regarding EZ WAY, while the current fee is only NT$0.8 to NT$3.5 per declaration, any security incident would be scrutinized under its public-private ownership model, potentially making the government and the company jointly liable. CISO must be closely monitoring these third-party service-level risks. Common pitfalls in PIMS implementation include: ① conducting incomplete DPIAs (Data Protection Impact Assessments) and relying solely on vendor claims of ISO 27001 compliance without verifying actual data flows and access controls; ② outsourcing data protection responsibility to third-party platforms without clear Service Level Agreements (SLAs) or penalty clauses; and ③ failing to implement internal audit mechanisms, which could allow internal data misuse—similar to the HIA employee incident—to occur within the company. If these gaps are not addressed, companies face the risk of regulatory audits, emergency response costs, and heavy compensation claims. For instance, a cross-border e-commerce platform with over 3 million transactions per month could face a fine of NT$150 million if a security breach leaks 1% of customer data (30,000 records) under the NT$50,000 per record maximum penalty in the PDPA. Winners Consulting Services Co., Ltd. specializes in integrating process optimization, legal compliance, and cybersecurity technology to help CISOs implement PIMS effectively. 【Actionable Recommendations】 1️⃣ **Conduct a comprehensive DPIA:** Map all personal data-handling processes, data flows, and third-party interfaces. Use the ISO 27701 standard to identify compliance gaps, prioritizing high-risk systems such as cross-border declaration platforms and payment gateways. This proactive approach identifies vulnerabilities before they are exploited. 2️⃣ **Establish a third-party cybersecurity assessment mechanism:** For all third-party services, including platforms like EZ WAY, require up-to-date ISO 27001 and ISO 27018 certifications and N-SOC monitoring records. Ensure all contracts include SLAs with penalty clauses—such as three times the service fee per transaction—to mitigate supplier risk and limit company liability. 3️⃣ **Implement continuous monitoring and auditing:** Deploy SIEM (Security Information and Event Management) systems to maintain data access logs for at least 90 days as required by the PDPA and GDPR. Conduct semi-annual third-party audits and enforce the Principle of Least Privilege (PoLP) to prevent internal data misuse. 4️⃣ **Develop a cybersecurity incident response and notification plan:** In accordance with Article 73 of the PDPA, ensure the company can notify regulators within 30 days of a significant breach. Establish a cross-functional response team (IT, Legal, Customer Service) to manage customer notifications, compensation, and media communications, thereby avoiding additional fines for delayed reporting. 5️⃣ **Foster a culture of cybersecurity and professional expertise:** Provide annual data protection training to all employees and specialized certifications (e.g., ISO 27701, CISSP) to key IT personnel. Establish a Cybersecurity Committee reporting directly to the Board of Directors to ensure organizational-level oversight. 6️⃣ **Prepare for changes in the regulatory environment:** As the government evaluates the future of EZ WAY, companies should be closely monitoring the outcome of the three-month evaluation period. If the platform is transitioned to a government-managed model, companies should be closely closely monitoring any changes in data-handling obligations or contractual terms. Winners Consulting Services Co., Ltd. provides complete ISO 27701 PIMS implementation blueprints, GDPR/PDPA dual-compliance audits, and automated DPIA tools. We offer free initial mechanism diagnosis to help your company achieve compliance and cybersecurity resilience in the shortest possible time.