Connecticut Attorney General William Tong announced on October 21, 2024, that his office has settled a data breach case against Guardian Analytics, Inc. for $500,000. The data breach affected the personal information of 157,629 Connecticut residents. The CT AG alleged that Guardian Analytics failed to implement reasonable and appropriate data security across its systems and allowed threat actors to gain access to the data, which was a violation of Connecticut’s data privacy and consumer protection laws.

In addition to the monetary settlement, Guardian Analytics is required to:

  • Maintain a comprehensive information security program designed to protect the security, confidentiality, and integrity of personal information;
  • Implement and maintain strong integration practices that require onsite inspections of acquired entities;
  • Encrypt all personal information, whether stored or transmitted;
  • Conduct and document annual risk assessments;
  • Implement and maintain multi-factor authentication for all individual user accounts and for remote access;
  • Implement and maintain an incident response plan to prepare for and respond to security incidents; and
  • Obtain an information security assessment to be conducted by a qualified third-party professional.

The above requirements are a virtual roadmap of of the Connecticut AG’s expectations when it comes to data privacy and security, and companies would do well to review and update processes to adhere to them.

Photo of Linn Foster Freedman Linn Foster Freedman

Linn Freedman practices in data privacy and security law, cybersecurity, and complex litigation. She is a member of the Business Litigation Group and the Financial Services Cyber-Compliance Team, and chairs the firm’s Data Privacy and Security and Artificial Intelligence Teams. Linn focuses her…

Linn Freedman practices in data privacy and security law, cybersecurity, and complex litigation. She is a member of the Business Litigation Group and the Financial Services Cyber-Compliance Team, and chairs the firm’s Data Privacy and Security and Artificial Intelligence Teams. Linn focuses her practice on compliance with all state and federal privacy and security laws and regulations. She counsels a range of public and private clients from industries such as construction, education, health care, insurance, manufacturing, real estate, utilities and critical infrastructure, marine and charitable organizations, on state and federal data privacy and security investigations, as well as emergency data breach response and mitigation. Linn is an Adjunct Professor of the Practice of Cybersecurity at Brown University and an Adjunct Professor of Law at Roger Williams University School of Law.  Prior to joining the firm, Linn served as assistant attorney general and deputy chief of the Civil Division of the Attorney General’s Office for the State of Rhode Island. She earned her J.D. from Loyola University School of Law and her B.A., with honors, in American Studies from Newcomb College of Tulane University. She is admitted to practice law in Massachusetts and Rhode Island. Read her full rc.com bio here.