Penalty Amount
$2,400,000
Consumers Affected
1,300,000
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.
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.
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.
Entity
Sabre Corp.
Also known as: Sabre
Industry
TechnologyOfficial Press Release
https://www.njoag.gov/ag-grewal-announces-njs-participation-in-2-4-million-settlement-over-sabre-hospitality-solutions-data-breach/
Sabre Settlement Agreement
https://www.nj.gov/oag/newsreleases20/Sabre-Settlement-Agreement.pdf
New Jersey Attorney General Enforcement Page
https://www.njoag.gov/about/divisions-and-offices/division-of-consumer-affairs/
"settlement with Sabre Corp."
"Sabre will pay the 27 participating states a total of $2.4 million"
"Intruders Accessed Hotel Booking Company’s Web-Based Central Reservation System; Data from over 1 Million Consumer Credit Cards Was Compromised"
"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"
"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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