Penalty Amount
$500,000
Consumers Affected
157,629
Guardian Analytics, Inc. and Actimize, Inc. settled with the Connecticut Attorney General over a data breach affecting 157,629 Connecticut residents. The breach, from November 2022 to January 2023, exposed personal information due to security failures. The settlement includes a $500,000 penalty and mandatory cybersecurity improvements.
Guardian and Actimize must pay $500,000 to the state, maintain a comprehensive information security program, encrypt all personal information, conduct annual risk assessments, implement multi-factor authentication, maintain an incident response plan, and obtain a third-party security assessment.
In-house legal teams should review vendor agreements where the entity provides data analytics or fraud prevention services to financial institutions, focusing on data security obligations, breach notification timelines, and compliance with state privacy laws. Specific clauses to examine include data security requirements, incident response procedures, audit rights, and indemnification for breaches. Given the security failures leading to exposure of sensitive financial data, contracts may need enhancements such as mandatory encryption, regular security assessments, immediate breach reporting, and clearer vendor oversight provisions.
Entity
Guardian Analytics, Inc. and Actimize, Inc.
Also known as: Guardian Analytics
Industry
Technology"Guardian Analytics, Inc. (“Guardian”) and its successor Actimize, Inc. (“Actimize”)"
"pay $500,000"
"Connecticut’s privacy and consumer protection laws"
"failing to implement reasonable data security"
$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.