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NY AG Reaches $3.5M Data Security Agreement with Marymount Manhattan College

Marymount Manhattan CollegeSeptember 21, 2023New York Attorney General

Consumers Affected

99,097

Summary

Marymount Manhattan College suffered a data breach in 2021 affecting 99,097 New Yorkers. The New York Attorney General found that MMC failed to secure its network infrastructure and update security policies. As part of the agreement, MMC must invest $3.5 million over six years to improve data encryption, enable multi-factor authentication, and implement other security measures.

Remedy

MMC is required to invest $3.5 million over six years to maintain a comprehensive information security program, encrypt all personal information, perform security updates and patch management, enable multi-factor authentication, scan for vulnerabilities, and publicly share its data collection and deletion plan.

Compliance Program

Contract Impact

In-house legal teams should review all agreements involving the handling of student, faculty, and alumni personal data, including vendor contracts, data processing agreements, and third-party service provider agreements. Specific clauses to scrutinize are data security requirements, encryption standards, multi-factor authentication mandates, breach notification procedures, and data retention/deletion schedules. Given the findings of inadequate security policies and unencrypted sensitive data, contracts may need amendments to mandate specific technical controls (e.g., enforced MFA, encryption of SSNs and financial data), require regular security policy reviews and firmware updates, and clarify procedures for ransomware incidents and data disposal.

Contract Search Terms

multi-factor authenticationdata encryption standardsecurity incident response plandata retention schedulevendor data security requirementsbreach notification clauseinformation security programfirmware update policyransom payment policyencryption of sensitive data

Violation Types

Entity Details

Entity

Marymount Manhattan College

Industry

Education

Official Sources

Source Evidence

Entity Name
"Marymount Manhattan College (MMC)"
Violation Types
"MMC failed to adequately safeguard personal information, including failing to use multi-factor authentication for accounts, not encrypting sensitive data, and failing to update both their security policies and firmware in response to new security threats."
Consumers Affected
"99,097 New Yorkers"

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