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CT AG Settles Guardian Analytics Data Breach for $500K

Guardian Analytics, Inc. and Actimize, Inc.October 21, 2024Connecticut Attorney General

Penalty Amount

$500,000

Consumers Affected

157,629

Summary

Guardian Analytics, Inc. and Actimize, Inc. settled with the Connecticut Attorney General over a data breach affecting 157,629 Connecticut residents. The breach, from November 2022 to January 2023, exposed personal information due to security failures. The settlement includes a $500,000 penalty and mandatory cybersecurity improvements.

Remedy

Guardian and Actimize must pay $500,000 to the state, maintain a comprehensive information security program, encrypt all personal information, conduct annual risk assessments, implement multi-factor authentication, maintain an incident response plan, and obtain a third-party security assessment.

Monetary PenaltyCompliance ProgramAudit Requirement

Contract Impact

In-house legal teams should review vendor agreements where the entity provides data analytics or fraud prevention services to financial institutions, focusing on data security obligations, breach notification timelines, and compliance with state privacy laws. Specific clauses to examine include data security requirements, incident response procedures, audit rights, and indemnification for breaches. Given the security failures leading to exposure of sensitive financial data, contracts may need enhancements such as mandatory encryption, regular security assessments, immediate breach reporting, and clearer vendor oversight provisions.

Contract Search Terms

data security addendumincident response planbreach notification clauseencryption standardsaccess controlsthird-party risk managementaudit rightsdata processing agreementsecurity incident reportingvendor management clause

Laws Cited

Connecticut privacy and consumer protection laws

Violation Types

Entity Details

Entity

Guardian Analytics, Inc. and Actimize, Inc.

Also known as: Guardian Analytics

Industry

Technology

Official Sources

Source Evidence

Entity Name
"Guardian Analytics, Inc. (“Guardian”) and its successor Actimize, Inc. (“Actimize”)"
Fine Amount
"pay $500,000"
Laws Cited
"Connecticut’s privacy and consumer protection laws"
Violation Types
"failing to implement reasonable data security"

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