How do you protect against intrusions (including hacking and viruses and ransomware)?  Policies and technology, mainly.  How do you protect against internal breaches (phishing, etc.)?  Policies, training, and a bit of technology.  How do you respond to an actual breach? Policies and procedures, training, and technology.

In the response, keep the notice requirements in mind.  The rules vary from state to state.

“States Quiz Equifax on Disclosure,” The Wall Street Journal, October 30, 2017 B1. Several states initiate investigations into by Equifax’s delay in reporting after the hack that may have compromised the records of 145.5 million credit accounts.  What did they know, when did they know it, and when did they report it, and to whom?  Notice to the state, to the fed, to the consumers, and to investors?  What’s reasonable, or what’s required by statute?

It’s all about notice.  Given the business, should the directors have been on top of this?

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Filed under Communications, Compliance, Controls, Corporation, Directors, Duty, Governance, Information, Interconnections, Internal controls, IT, Legal, Oversight, Requirements, Security, To report, Value

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