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.