Fraud went out from the firm’s own email while the employee was on vacation.

a law firm · Alberta · November 2019. Fraudulent mail went out from an Alberta law firm's own address — the real account of an employee who was away on vacation. Another law firm contacted them to report it. About 400 people had to be notified.

What happened

Identified in the record as Alberta OIPC Breach Notification Decision P2020-ND-033.

≈400 people the firm was ordered to notify, after mail went out in its name

Missing control

Nothing stopping the firm’s own address being used, and no way to notice it

Alberta OIPC decision Read the original →

On November 13, 2019, the firm was contacted by another law firm, which had received a suspicious email that appeared to come from them.

The address was real. The mail was sent from the actual account of one of the firm's employees, who was on vacation at the time. About 60 individuals and companies contacted the firm about the emails.

“The Organization reported that the likelihood that the significant harm will result is “Extremely low. Our office does not typically send emails with links.””
Decision P2020-ND-033

The Commissioner disagreed.

“The unauthorized access did in fact result in fraudulent emails being sent.”
Decision P2020-ND-033

The firm was ordered to notify roughly 400 people whose personal information had been collected in Alberta. Its own conclusion, recorded in the decision, was that IT and training improvements were required. The cost here was never a ransom — it was the firm's clients learning that mail from the firm could not be trusted.

The rule that applied — in Alberta

Alberta PIPA s.34.1 and s.37.1 — report the breach, then notify everyone affected

“There is a real risk of significant harm to the individuals affected by this incident. The Organization is required to notify those individuals whose personal information was collected in Alberta, pursuant to section 37.1 of the Personal Information Protection Act (PIPA).”

The document

The part that matters

The firm's own assessment was that this was extremely low risk. The Commissioner overruled it in a published decision, and about four hundred people got a letter. The cost here was never a ransom — it was the firm's clients learning that mail from the firm could not be trusted, and hearing it from the firm.

This one transfers almost without translation. It is a private law firm, of the size that has no security team, and the failure is the ordinary one: a mailbox somebody else could use, and no mechanism to find out. The statute differs — Alberta PIPA rather than Ontario's PIPEDA — but both make the firm, not its IT provider, responsible for telling everyone affected.

What your own regulator and insurer require →

The documents

We hold dated copies — ask and we will send you what we read.

Document	Our copy
Decision P2020-ND-033	Copy held 2026-08-20
The decisions index	Copy held 2026-08-20

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Claim	Figure	Basis
Most small firms have no security budget at all	84.5%	of Canadian businesses with 5–19 employees had no dedicated cybersecurity budget (92.0% at 1–4 employees; 69.8% at 20–99). Separately, most businesses (54.4%) had no plans to take any new or additional cybersecurity action in the following 12 months, and the most common reason given was not needing cybersecurity measures (57.1%).
Most small Canadian professional firms can be impersonated by email	77%	of small Canadian professional firms with a website have no enforced DMARC — meaning anyone can send email that appears to come from them, and the receiving server has not been told to reject it. We measured this ourselves across 3,821 firm domains, because no independent source publishes it.
Recovery spending doubled in two years	$1.2 billion	is what Canadian businesses spent recovering from cyber security incidents in 2023, double the roughly $600 million spent in 2021 — while total spending on prevention and detection rose only from $9.7 billion to $11.0 billion. Small businesses accounted for about $300 million of the recovery bill.
For most small firms, the IT provider IS the security plan	50%	of Canadian businesses had any employees responsible for cyber security in 2023 — down from 61% in 2021. Among those without, the most common reason given was that they use consultants or contractors instead (47%).
Your CCO personally certified your cybersecurity answers to the OSC	G10	Every OSC-registered firm answers the Risk Assessment Questionnaire, and from 2026 the Chief Compliance Officer must personally certify each section — including Question G10 on cybersecurity. CIRO Dealer Members additionally have three days from discovering an incident to report it. Neither the certification nor the deadline can be satisfied by a firm that would not notice an incident in the first place.
Clients and partners now require security measures in writing	44%	of Canadian businesses were required to implement cyber security measures by suppliers, customers, partners or regulators, or to meet the requirements of security standards or certification programs — up from 29% two years earlier. Statistics Canada, 2019 and 2017. Inside the legal profession the ABA measures the same pressure directly, and finds it concentrated in larger firms: 15% at 2–9 lawyers against 59% at 50–99.
Your insurer asks whether you enforce MFA before it will quote you	MFA	is the control insurers ask about first, in writing, on their own application forms — Coalition's Canadian questionnaire and Beazley's US one both ask whether it is enforced on email and remote access, alongside tested backups and patching. Aon's 2025 report still calls it "an underwriting requirement" in a buyer-friendly market. Travelers rescinded a policy after a ransomware claim where the MFA represented on the application did not exist.
Corporate clients hand law firms a security schedule — their own association wrote one	24 hours	is the breach-notification window in the Association of Corporate Counsel's model security schedule — a ready-made set of controls written for in-house counsel to impose on the outside firms they retain. 27% of US law firms have been asked for their security requirements document; at 2–9 lawyers it is 15%.

Figure	What it measures
84.5%	of Canadian businesses with 5–19 employees had NO dedicated cybersecurity budget, Q3 2024. By size: 92.0% at 1–4 employees, 84.5% at 5–19, 69.8% at 20–99, 43.2% at 100+. Statistics Canada table 33-10-0875-01, vector v1594328208; StatCan rates this estimate's quality "excellent".
54.4%	of businesses had no plans to take new or additional cybersecurity actions over the next 12 months — and among the reasons given, the most common was not needing cybersecurity measures (57.1%). That is the "hope" in the sentence above. Canadian Survey on Business Conditions, Q3 2024.
37.0%	of Canadian legal-services businesses had no employee whose regular responsibilities include cyber security in 2023 — 38.6% of accounting, tax and bookkeeping practices, and 37.6% of ambulatory health care. Statistics Canada table 22-10-0129-01, vectors v1212389881 / v1212389887 / v1212390001.

Figure	What it measures
77%	of small Canadian professional firms WITH A WEBSITE have no enforced DMARC — anyone can send email that appears to come from them. The frame is firms we could find a domain for, so the figure describes firms with a web presence.
81.7%	clinics and health practices
73.1%	law firms
72.4%	accounting practices

Figure	What it measures
$1.2 billion	"Total spending on recovery from cyber security incidents also increased in 2023, doubling from approximately $600 million in 2021 to $1.2 billion in 2023." Prevention and detection spending over the same period went from $9.7 billion to $11.0 billion — recovery is the line that doubled.
$300 million	"Large businesses accounted for almost half of total spending on recovery from cyber security incidents in 2023 (about $500 million), while medium-sized and small businesses each spent approximately $300 million." Small businesses carry a quarter of the national recovery bill.
≈ $12,600	OUR ARITHMETIC, shown so you can check it: $300 million ÷ ≈23,800 small businesses impacted in 2023 (170,000 × 14%, the same calculation as the "1 in 7" table on this page). It is an average, and a skewed one — among small businesses actually impacted in 2023, 35.5% described the incident's effect as minor (Statistics Canada table 22-10-0133-01), so most sit below this figure and a few sit far above it.
Not in this number	Lost clients, lost billable hours, the cost of notifying everyone whose data was in a mailbox, and reputational damage. StatCan measures money spent recovering, not total harm. For a professional firm the uncounted half is usually the larger one, and no Canadian source quantifies it at this size — which is why we do not put a figure on it here.