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Multistate AGs Secure $52M Settlement with Marriott for Data Breaches

Marriott International, Inc.October 9, 2024New Jersey Attorney General

Penalty Amount

$52,000,000

Consumers Affected

131,500,000

Summary

A multistate coalition of 50 attorneys general, including New Jersey, reached a $52 million settlement with Marriott International, Inc. for two data breaches that exposed personal information of over 131 million consumers. The breaches resulted from inadequate cybersecurity practices at Starwood and Marriott networks. The settlement mandates comprehensive security improvements and monetary penalties.

Remedy

Marriott must pay $52 million, implement a cybersecurity overhaul including appointing a Chief Information Security Officer, establishing board oversight, enhancing security controls, allowing consumers to request data deletion and loyalty account reviews, training employees, conducting risk assessments, improving vendor management, and submitting to regular third-party audits.

Monetary PenaltyInjunctionCompliance ProgramAudit RequirementData DeletionReporting Requirements

Contract Impact

In-house legal teams should review all vendor and customer agreements, particularly those involving the processing or storage of personal data. Key clauses to examine include data security obligations, breach notification requirements and timelines, audit and inspection rights, third-party subcontractor management, data retention and disposal policies, and indemnification provisions related to security incidents. Given the settlement's focus on inadequate cybersecurity practices, contracts may need to be amended to include more specific technical security controls (e.g., encryption standards, multi-factor authentication), mandatory regular security audits by the company, stricter vendor management protocols, and clearer liability and remediation terms in the event of a breach.

Contract Search Terms

data security standardsincident response planencryption requirementsthird-party vendor managementdata retention policybreach notification timelinePCI DSS compliancesecurity audit rightsindemnification for data breachescyber insurance

Laws Cited

New Jersey Consumer Fraud Act

Violation Types

Entity Details

Entity

Marriott International, Inc.

Also known as: Marriott

Industry

Other

Multistate Coalition

Official Sources

Source Evidence

Entity Name
"Marriott International, Inc."
Fine Amount
"$52 million"
Laws Cited
"New Jersey Consumer Fraud Act"
Violation Description
"The States allege that Marriott violated data breach laws and consumer protection laws—including the New Jersey Consumer Fraud Act—by misrepresenting the ways in which it protected consumers’ personal information and failed to use adequate cybersecurity safeguards to protect that information."

Related Enforcement Actions

NY

Marriott International, Inc.

$52.0M

A multistate coalition of 50 attorneys general led by New York AG Letitia James reached a $52 million settlement with Marriott International, Inc. over a 2014-2018 data breach of its Starwood subsidiary’s guest reservation database that exposed 131.5 million consumers’ personal information. The breach, which went undetected for four years, compromised contact details, dates of birth, passport numbers, payment card information, and loyalty program data. Marriott is required to overhaul its data security practices, implement new compliance measures, and allow customers to delete their stored data as part of the settlement.

CT

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