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SettlementCritical RiskMultistate

NJ AG Settles Anthem for $39.5M Over 2015 Data Breach

Anthem, Inc.September 30, 2020New Jersey Attorney General

Penalty Amount

$39,500,000

Consumers Affected

78,800,000

Summary

New Jersey Attorney General announced a multi-state settlement with Anthem, Inc. over a 2015 data breach that exposed personal information of over 78 million Americans, including 1.15 million New Jersey residents. Anthem will pay $39.5 million to participating states and implement enhanced cybersecurity measures.

Remedy

Anthem agreed to pay $39.5 million in penalties and to implement enhanced cybersecurity and governance provisions to improve data security practices.

Monetary PenaltyCompliance Program

Contract Impact

In-house legal teams should review all agreements involving personal data handling, including vendor contracts, customer terms of service, data processing agreements, and employee confidentiality agreements. Key clauses to scrutinize are data security requirements, breach notification procedures, data retention schedules, audit rights, and indemnification for data breaches. Based on this settlement, contracts should be updated to include enhanced cybersecurity measures such as mandatory encryption, strict access controls, regular security audits, and clear governance provisions. Ensure breach notification timelines and methods comply with applicable state laws, and add clauses requiring vendors to adhere to specific security frameworks and provide immediate notification of security incidents.

Contract Search Terms

data breach notification clausecybersecurity standardssecurity incident response plandata retention scheduleencryption requirementsaccess controlsaudit rightsindemnification for data breachesgovernance provisionscompliance with security frameworks

Violation Types

Entity Details

Entity

Anthem, Inc.

Also known as: Anthem

Industry

Healthcare

Multistate Coalition

Official Sources

Source Evidence

Entity Name
"Anthem, Inc."
Fine Amount
"$39.5 million"
Violation Types
"massive data breach"

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