a breach is defined as ‘personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthoris

a breach is defined as ‘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 transmitted, stored or otherwise processed; Given the definition, I think it's a bit hard to argue this isn't a breach. It's a breach of security leading to unauthorised disclosure or personal data.