Penalty Amount
$16,000,000
Connecticut, as part of a 40-state coalition, secured multistate settlements totaling over $16 million with Experian and T-Mobile related to data breaches in 2012 and 2015 that exposed consumers' personal information. Experian agreed to pay $12.67 million and implement enhanced data security measures, while T-Mobile agreed to pay $2.43 million and strengthen vendor management. Additionally, Experian Data Corp. paid $1 million to resolve a separate 2012 breach investigation, with all entities required to improve data protection practices.
Experian agreed to pay $12.67 million and implement a comprehensive information security program with zero-trust principles, due diligence, data minimization, and specific security requirements. T-Mobile agreed to pay $2.43 million and implement a vendor risk management program with contractual security requirements for vendors. Experian Data Corp. agreed to pay $1 million to improve vetting of third parties and maintain a Red Flags program. Experian also must offer 5 years of free credit monitoring to affected consumers.
In-house legal teams should review vendor agreements (particularly those involving data brokers or credit reporting agencies like Experian), customer agreements (such as telecom service contracts with T-Mobile), and any data processing addendums. Focus on clauses governing data security obligations, breach notification timelines and procedures, audit and inspection rights, indemnification for data breaches, data encryption and access control standards, incident response plans, data retention and disposal policies, and vendor oversight requirements. Changes may include strengthening security specifications (e.g., mandatory encryption, regular penetration testing), clarifying breach notification within 72 hours, requiring third-party security audits, enhancing vendor due diligence and monitoring provisions, and updating indemnification terms to cover regulatory fines and consumer redress.
Entity
Experian; T-Mobile
Industry
Data Broker$500K
Connecticut Attorney General William Tong announced settlements with SunRun, Inc., Elevate Solar Solutions, and two salespeople over allegations of deceptive solar sales, including impersonating consumers and locking homeowners into long-term contracts without consent. SunRun must pay $300,000 and provide consumer relief; Elevate and the salespeople face a stated $200,000 penalty, with $100,000 suspended subject to ongoing compliance.
$8.0M
Connecticut announced an $8 million settlement with Mylan over allegations that it used agreements to delay generic EpiPen competitors and took other actions that inflated prices. Mylan also agreed to provide 10,000 free EpiPens; the release states that Mylan denies wrongdoing.
Connecticut Attorney General William Tong joined a coalition of 22 attorneys general in filing an amicus brief challenging DHS’s policy and practice of conducting warrantless civil immigration arrests. The press release describes a court challenge, not a privacy enforcement action or monetary penalty.
$625K
Connecticut reached a $625,000 settlement with Frontier Communications Parent Inc. over an April 2024 breach in which compromised employee and vendor credentials were used to access internal systems and exfiltrate unencrypted personal information of 58,841 Connecticut residents. The settlement requires Frontier to strengthen its security program, implement specific safeguards and training, and obtain an independent third-party assessment.
$2.6M
Connecticut and New York found that Boston Children’s Health Physicians and its security vendor, XTIUM, failed to use reasonable safeguards, resulting in hackers accessing sensitive personal, medical, and employee information. The companies agreed to pay penalties totaling $2.64 million and implement enhanced cybersecurity measures.
Connecticut joined a coalition of state attorneys general filing a notice in Character Technologies, Inc.’s bankruptcy proceedings, raising concerns about the company’s safety and privacy practices and the sensitive information it holds. The states seek protections for children and consumers if the company’s business or assets are sold or transferred; the filing does not impose a fine or other remedy.