Compliance
SEC Disclosure Rule Covers Accidental Data Loss
In general, we believe that an accidental occurrence is an unauthorized occurrence. Therefore, we note that an accidental occurrence may be a cybersecurity incident under our definition, even if there is no confirmed malicious activity. For example, if a company’s customer data are accidentally exposed, allowing unauthorized access to such data, the data breach would constitute a ‘cybersecurity incident’ that would necessitate a materiality analysis to determine whether disclosure under Item 1.05 of Form 8-K is required.
Eoghan Casey
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