MOVING TARGET: DATA BREACH NOTIFICATION IN PRACTICE January 14, 2014 By Jeffrey Possinger The recent Target (and now Neiman-Marcus) data security breach provides a clear illustration of the challenges faced by businesses that must comply with the various data breach notification laws. As of the writing of this article, what is known is that for 19 days (between November 27 and December 15) computer hackers gained “unauthorized access” to Target’s customers’ names, credit or debit card numbers, card expiration dates, and three-digit CVV security codes. [link] Target initially revealed on December 19 (four...
