How to Handle a Customer Data Breach

If your business holds customer data and gets breached, what you do in the first 72 hours often determines what you owe later. Every state has its own notification law, and many have hard deadlines that don't pause for investigation. Here's the practical playbook.

1. Hour 1: Contain and preserve evidence

Disconnect affected systems from the network, but don't wipe them — forensic evidence is critical. Engage IT security and (if available) cyber-insurance breach response. Document every step in a timeline.

2. Day 1: Engage breach counsel

An attorney experienced in breach response can structure the investigation under attorney-client privilege, identify which laws apply, and start the notification clock running on a sound footing. This step pays for itself.

3. Identify what data was actually accessed

Notification triggers depend on data types — names + Social Security numbers, financial account numbers, health info, biometrics. The more sensitive the data, the broader and faster the notification requirements.

4. Notify per each affected state's law

All 50 states have breach notification statutes. Texas (BC §521.053), Arizona (ARS §18-552), Nevada (NRS 603A.220), and New Mexico (NMSA §57-12C-1) all require notification "in the most expedient time possible" — typically 30–60 days.

5. Offer credit monitoring and document remediation

Most state laws and customer expectations call for offering 12–24 months of free credit monitoring. Document everything you did to investigate, notify, and remediate — it's your shield in any subsequent regulatory or civil action.

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NotALawyer.com provides general legal information, not legal advice.