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Command Brief / CB-230

What a breach notice cannot establish

The Search Engines Knew First

The intelligence

In January 2019 a federal regulator, not the company, alerted the clearinghouse Inmediata that patient records it held were indexed by search engines; settlements followed years later. Reading that case against three state notification statutes, this brief asks what a breach notice can tell a recipient about where the data stands today. For advisors and family offices deciding how to log and weigh the notices a household receives, and the first of a series running to CB-234.

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Topics

Breach & Leaked DataPrivacy Law & RegulationThreat Doctrine