Ten Steps Every Organization Should Take To Address Global Data Security Breach Notification Requirements
Client/Legal Alert
August 2011
Author/s:
Brian L. Hengesbaugh,
Michael S. Mensik,
Michael A. Stoker,
Michael (Mike) J. Wagner,
Sergio Legorreta,
Edward Bekeschenko,
Dr. Daniel Krone,
Dr. Christoph Rittweger,
Antonio V. Ortúzar, Jr.,
Theo C. Ling
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Data security breach notification is rapidly becoming a significant compliance risk for global enterprises. A data security breach can disrupt business operations, damage brand reputation and customer relationships, and attract government investigations and class action lawsuits. Among other benchmarks, the Ponemon Institute estimates that a data security breach now costs an organization approximately USD214 per compromised record or USD7.2 million on average per incident. As such, data security breach is moving into the "upper right quadrant" on the compliance chart that maps likelihood of an incident against the severity of its potential harm. This client alert summarizes the rapid expansion of global data security breach notification requirements, and identifies ten key steps every global enterprise should take to address such obligations.