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Yes, in the words of the ICO:

> A personal data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data. This includes breaches that are the result of both accidental and deliberate causes.

https://ico.org.uk/for-organisations/guide-to-the-general-da...

Most of the breaches I'm familiar with are accidental - people putting their research on thumb drives and losing them, etc etc.

Whether the fox gets into the chicken shed, or you let the chicken out of the safety of the shed, it's a breach of the chicken's security.




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