Court Rules
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SettlementHigh RiskMultistate

NJ AG Settles Sabre for $2.4M Over Hotel Booking Data Breach

Sabre Corp.December 23, 2020New Jersey Attorney General

Penalty Amount

$2,400,000

Consumers Affected

1,300,000

Summary

New Jersey participated in a multi-state settlement resolving an investigation into a 2017 data breach at Sabre Hospitality Solutions. Intruders accessed the company's hotel booking system from August 2016 to March 2017, compromising data from over 1.3 million consumer credit cards, including CVV numbers and expiration dates. Sabre failed to promptly notify affected consumers. The $2.4 million settlement requires Sabre to implement enhanced data security measures, develop a breach notification plan, clarify contractual responsibilities with client hotels, and undergo third-party security assessments.

Remedy

Sabre must pay $2.4 million total to 27 states. The settlement includes injunctive relief requiring Sabre to implement and maintain a comprehensive information security program, meet specific security requirements, undergo a third-party security assessment, develop a written incident response and data breach notification plan, and include clear breach response roles in future client contracts. Sabre must also determine and report to Attorneys General whether its client hotels provided consumer notifications.

Monetary PenaltyInjunctionConsent DecreeCompliance ProgramReporting Requirements

Contract Impact

In-house legal teams should review vendor and customer agreements, especially those involving data processing or service provision like Sabre's hotel booking system. Focus on clauses related to data security, breach notification, indemnification, and audit rights. Specific clauses to examine include data security standards (e.g., encryption, access controls), breach notification timelines and procedures, allocation of liabilities for data breaches, requirements for third-party security assessments, and data retention and deletion policies. Changes may be needed to mandate compliance with specific frameworks like PCI DSS for payment card data, enforce prompt breach notification to consumers and clients, clarify contractual responsibilities between Sabre and client hotels regarding data handling, and include regular security audits and incident response plans.

Contract Search Terms

breach notification plandata security measurescontractual responsibilitiesthird-party security assessmentpayment card data protectionCVV data handlingconsumer notification timelineincident response plan

Violation Types

Entity Details

Entity

Sabre Corp.

Also known as: Sabre

Industry

Technology

Multistate Coalition

Official Sources

Source Evidence

Entity Name
"settlement with Sabre Corp."
Fine Amount
"Sabre will pay the 27 participating states a total of $2.4 million"
Violation Types
"Intruders Accessed Hotel Booking Company’s Web-Based Central Reservation System; Data from over 1 Million Consumer Credit Cards Was Compromised"
Violation Types
"Sabre did not notify actual hospitality consumers, leaving that task to the client hotels. The client hotels subsequently provided notice to consumers, but some consumers did not receive notice until as late as 2018"
Co Enforcers
"Attorneys General representing the following states have signed-on to today’s settlement with Sabre: Vermont, Arkansas, Connecticut, Illinois, Alaska, Arizona, Florida, Hawaii, Indiana, Iowa, Louisiana, Michigan, Minnesota, Missouri, Montana, Nebraska, Nevada, New York, North Carolina, North Dakota, Ohio, Oregon, Pennsylvania, Tennessee, Virginia, and Washington."

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