By Mark Sanborn
Senior Product and Regulatory Counsel

Additional updates to the law include a reduced threshold for reporting breaches to credit reporting agencies. Now, businesses must report a breach affecting 500 or more individuals, down from the previous threshold of 1,000. Furthermore, if a breach involves the exposure of first and last names in combination with certain sensitive personal information—Social Security numbers, bank account numbers, or driver’s license/ID numbers—and impacts 500 or more individuals, businesses are required to provide 12 months of complimentary credit monitoring services to all affected individuals. In cases where an affected individual cannot obtain a free credit report, businesses must also offer access to a free report.
ComplyAuto Privacy customers have access to a Data Breach Reporting Wizard in which dealers can answer a few simple questions about an actual or hypothetical security incident to see their potential state and federal reporting requirements. The Wizard has been updated to reflect the updated Attorney General reporting requirements for Pennsylvania.