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On the heels of Vermont's recent amendment to its data
breach notification law (which we blogged about
here), Connecticut's legislature recently
amended its own data breach notification law (Conn. Gen. Stat.
§ 36a-701b). The amended law will take effect on October
1, 2012.
While several of the changes to the law were non-substantive in
nature and more for the sake of clarification, the amended law does
impose what seems to be the new trend in data breach notification
obligations: the requirement to notify the state attorney
general.
Under newly added subsection (b)(2) of the statute, companies
that are required to notify Connecticut residents of a data breach
must also notify the Attorney General of Connecticut no later than
the time when notice is provided to the residents (which, according
to subsection (b)(1), must be made without unreasonable delay,
subject only to delays resulting from law enforcement
investigations and a company-conducted investigation to determine
the nature and scope of the incident, identify the individuals
affected, or restore the reasonable integrity of the underlying
data system).
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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