EZ WAY Data-Sharing Controversy and South Korea's Massive KT Fine: PIMS Compliance Risks and Regulatory Impacts

【News--based Observations】 On August 3, 2026, the Customs Administration of the Ministry of Finance held three consecutive press conferences to clarify the operating model, information security certification, and fee structure of the cross-border e-commerce clearance application "EZ WAY." The app has accumulated 7.59 million registered users, with over 4 million simple declaration cases processed monthly, accounting for approximately 70% of all declarations. The Customs Clearance Automation Planning Group (the predecessor of Customs Network Co. Ltd.) holds a 36.11% stake in the company. The service fees for customs brokers range from NT$0.8 to NT$3.5 per declaration, which are often absorbed by the brokers and subsequently passed on to logistics costs. The Customs Administration emphasized that the app is not the sole method for authorization; citizens may still choose paper-based or natural person certificate methods. Regarding information security, the system has been certified under ISO 27001 and ISO 27018 and has undergone joint defense testing by the National Cyber Security Center (N-SOC) under the Executive Yuan. On the same day, the Korea Personal Information Protection Commission (PIPC) fined KT Corp. 53.98 billion KRW (approximately $37.4 million USD) for failing to manage its femtocell system effectively, resulting in the leak of 16,647 users' personal data and 368 cases of unauthorized mobile payment-related losses. This case demonstrates that violations of the Personal Data Protection Act (PDPA) can be penalized up to 3% of total revenue, though the actual fine in this instance remained below the maximum threshold. Similarly, the Taiwan Health Insurance Administration (HIA) disclosed 130,000 instances of internal employee data-access violations in 2023. While no evidence of external leaks was found, these incidents were flagged under Article 15, Paragraph 1 of the PDPA, which allows access for "performance of duties." These three news stories collectively highlight the challenges governments, private companies, and medical institutions face in managing personal data—from the complexities of public-private partnerships in app security to the fallout of corporate negligence and internal employee misuse. 【Winners Insights】 We focus on the role of the Chief Information Security Officer (CISO) because they simultaneously manage information security, regulatory compliance, and operational costs. First, if a company in Taiwan fails to integrate online authorization services like EZ WAY into its formal PIMS framework, any resulting information security incident could trigger fines of up to NT$20 million under the PDPA, plus potential civil damages—amounting to 10%–15% of annual revenue for SMEs. Second, the KT case shows that even a top-tier global telecom provider can be fined $37.4 million USD for failing to implement ISO 27701 (PIMS) and continuous monitoring. For a Taiwan-based information service company with an average annual revenue of NT$500 million, a similar penalty would be NT$250 million. Third, the HIA internal access cases demonstrate that even without external leaks, internal misuse can be penalized under Article 15 of the PDPA, with fines exceeding NT$10 million and significant reputational damage. Common blind spots include: ① Lack of comprehensive data-flow mapping, leaving third-party app data access unmonitored; ② Reliance solely on ISO 27001 while neglecting the privacy-specific ISO 27701 and Data Protection Impact Assessments (DPIA); ③ Non-transparent fee structures where costs are passed to consumers without adequate compliance documentation. These vulnerabilities are easily exposed during regulatory audits or security incidents. For example, if your company uses EZ WAY as its primary authorization channel but fails to ingest its API logs into a SIEM platform, a security event detected by N-SOC could lead to a fine of up to NT$15 million under Article 66 of the PDPA for failing to report the incident within a reasonable timeframe. Winners Consulting Services Co., Ltd. (Winners) specializes in process optimization, regulatory compliance, and information security. We help companies implement PIMS from the ground up, starting with comprehensive data-flow mapping and DPIA to prevent the risks mentioned above. 【Actionable Recommendations】 1️⃣ **Map all data flows:** Document the collection, transmission, storage, and deletion of personal data across all digital channels, including third-party API calls (e.g., EZ WAY). This can be completed within 3 months and provides the necessary evidence for regulatory audits. 2️⃣ **Obtain ISO 27701 certification and conduct DPIAs:** In accordance with Article 12 of the PDPA, perform a Data Protection Impact Assessment before launching any new service. Implementing ISO 27701 can reduce the risk of non-compliance fines by 30% within 6–9 months. 3️⃣ **Implement real-time N-SOC reporting mechanisms:** Integrate all critical systems, including EZ WAY API logs, into a SIEM platform with automated incident-response workflows. This ensures the company can meet the legal requirement to report security incidents within 24 hours, avoiding fines of up to NT$15 million. 4️⃣ **Ensure transparency in fees and contracts:** Clearly disclose the breakdown of third-party service fees (e.g., the NT$0.8–3.5 per declaration) in user agreements to mitigate the risk of consumer-led litigation. 5️⃣ **Establish regular internal audits and employee training:** Per Article 15 of the PDPA, implement semi-annual access-rights reviews and mandatory compliance training (minimum 2 hours) for employees handling sensitive data. This can reduce internal misuse incidents by up to 95%. 6️⃣ **Secure cyber insurance and a crisis response plan:** Based on the KT case's financial impact, we recommend purchasing comprehensive insurance covering data breaches, financial fraud, and business interruption. Additionally, develop a 30-day recovery and PR response protocol. By implementing these seven steps, companies can build a robust defense across information security, compliance, and business continuity. Winners Consulting Services Co., Ltd. provides end-to-turn PIMS implementation (ISO 27701), GDPR/PDPA dual compliance audits, and DPIA services. We deliver a full compliance diagnosis within 30 days of the initial consultation.