On June 11, 2015, Connecticut Governor Dannel Malloy signed Senate Bill 949  (“S.B. 949”) into law.  This new law imposes a various new requirements relating to data breach response and notification, including imposing a hard 90-day deadline for data breach reporting and requiring that entities regulated by the Connecticut Insurance Department to implement and maintain a “comprehensive information security program” to protect personal information.  The various sections of  S.B. 949  take effect in stages, with some having taken effect on July 1, 2015, and others becoming effective as late as October 1, 2017.

The U.S. National Labor Relations Board (NLRB) recently filed complaints against the United States Postal Service (USPS), alleging that the USPS violated the National Labor Relations Act (NLRA) by failing to collectively bargain with its employees’ union regarding the postal service’s response to a 2014 data breach that reportedly affected over 800,000 current and former postal employees. Specifically, in one of its complaints, the NLRB alleged that the postal service’s unilateral decision to provide credit monitoring and fraud insurance to affected employees without engaging in collective bargaining with the union on these issues violated Sections 8(a)(1) and (5) of the NLRA. These provisions of the NLRA mandate collective bargaining for any issue that relates to the “wages, hours, and other terms and conditions of employment.”