The clock starts before the paperwork does. An incident declared in Jira or ServiceNow opens the task with just a discovery date; the forensics report, contract stack, and processing records attach as they arrive. Every deadline on the case runs off that one timestamp.
We found the intrusion Tuesday 9:40am. What do we owe whom — and by when?
Grain scopes the affected data — elements, residency, encryption, per system — while a second pass mines the customer contracts for notice clauses and named security contacts. Then the notification matrix runs as a gate across every statute in play: triggers, safe harbors, thresholds. Unknowns block: a system whose encryption status is unconfirmed holds its jurisdictions rather than guessing.
What counsel sees is the case organized: how many records, where the people live, what was encrypted, which contracts carry clocks. And the check results in plain terms — what's exempt and why, which twelve states trigger, and the one honest “we don't know yet” that's holding Colorado.
- Discovered
- Tuesday 9:40am
- Records affected
- 48,200 · 14 states + EU
- Data involved
- names, emails · partial SSNs on one system
- Encryption
- confirmed on 2 of 3 systems
- Contracts with notice clauses
- 14
- Two systems were encrypted — those records are exempt in most states
- No payment-card data was touched
- All 14 contractual notice contacts are current
- 12 states' notification rules are triggered
- 3 states require notifying the attorney general, not just individuals
- One system's encryption status is still unknown — Colorado's notice held
The packet is the entire notification posture: the matrix itself, per-jurisdiction regulator letters and individual notices with state-mandated content, a counsel brief, and every proposed dispatch as a checkable action. Validations list what's unresolved — Colorado's hold sits here until the forensics addendum lands — and an independent pass confirms no notice exists for a jurisdiction the matrix cleared.
Alex works the case by asking Nia — which states flipped since the last addendum, what Maryland requires before individuals are told. New forensics re-run only the affected jurisdictions; a regulator's reply wakes the task with Nia's draft response attached. Dispatches — mail-house, portals, email — execute in the firm's own systems after approval, never before.
12 states, 2 regulators, 14 contracts — every notice drafted, none sent.