Sensitive Data Exposure in Logs in Plaintext

Issue

Sensitive data exposure in logs in plaintext

Impacted Frameworks and Reasons

Article 5 requires data minimization, purpose limitation, and integrity. Writing personal data to logs without a valid processing purpose violates these principles.
Article 28 requires proper controls over processors. When logs flow to platforms like Datadog or Splunk without contractual clarity, this breaks processor oversight requirements.

CCPA and CPRA

Logs that contain personal data may count as data sharing.
If users are not informed that their data is logged and transmitted to third parties, this results in undisclosed sharing without required notice or opt out controls.

HIPAA

PHI must be protected and only shared with authorized business associates.
Logging PHI into operational monitoring systems without a formal Business Associate Agreement is considered an unauthorized disclosure.

PCI

Cardholder data must never appear in plaintext outside the controlled PCI environment.
Logging card data directly violates storage, transmission, and masking requirements.

GLBA

Requires administrative and technical safeguards for financial data.
Plaintext logging shows a failure to safeguard customer financial information.

PIPEDA

Requires meaningful consent for the collection and disclosure of personal data.
If sensitive data is logged without user awareness, the organization cannot demonstrate consent or proper handling.

APPI

Requires clear purpose specification and data minimization.
Logging personal data without necessity breaks purpose limitation and storage minimization rules.

NIST 800 53

Emphasizes audit control, access restriction, and proper handling of sensitive information.
Plaintext logs increase exposure risk during retention, ingestion, and access by internal teams.

ISO IEC 29100

Requires transparency and accountability in handling personal data.
Excessive or unnecessary logging undermines privacy governance.

KSA PDPL

Requires lawful basis and explicit consent for processing and transferring personal data.
Logging personal data into systems that may export data cross border can violate transfer and disclosure controls.

UAE PDPL

Processing must remain aligned with declared purpose and user expectations.
Logging personal data beyond operational necessity exceeds authorized processing purpose.

Qatar PDPPL

Requires safeguards to prevent unauthorized disclosure.
Plaintext logs increase the likelihood of inadvertent exposure and unauthorized access.

Logs are often ingested into third party monitoring and SIEM platforms such as Datadog and Splunk. Once sensitive data enters these systems, remediation is costly and disruptive. Incidents often require stopping log ingestion, scrubbing retained data, and retroactively fixing the underlying code. This process can take 50 to 100 hours across engineering, privacy, and security teams.

Recommended Remediation

Identify locations where sensitive data is written to logs and remove or mask the data before logging. Confirm that no sensitive fields are included in debug or trace level logs. Verify that log data flowing to external observability platforms is limited to operational metadata only and aligns with the stated privacy notice and contractual data processing agreements.

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