Vermont's $57,750 Message to Insurance Compliance Officers: Time Matters in Data Breach Response
Weekly snippets from the Insurance Compliance Insight (ICI) Newsletter. A weekly subscription service published by an insurance compliance professional for insurance compliance professionals!
A recent Vermont Department of Financial Regulation consent order sends a clear message about data breach notification timing. The regulator issued a $57,750 penalty to an insurer for delays in reporting a ransomware attack.
The case highlights two critical deadlines under Vermont law:
- 14 business days to notify regulators after breach discovery
- 45 calendar days to notify affected consumers
In this instance, the notifications arrived 155 and 131 days late, respectively. The timeline from initial breach to final notification spanned 16 months, affecting 149 Vermont consumers.
For insurance compliance officers, this case underscores the need for:
- Clear incident response protocols
- Pre-selected vendor relationships
- Documented discovery criteria
- State-specific requirement tracking
The full consent order reveals additional insights about regulatory expectations and compliance management strategies.
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[Note: This summary is for informational purposes only and does not constitute legal advice.]