Penalty Amount
$16,000,000
Consumers Affected
15,000,000
New Jersey Attorney General Matthew J. Platkin announced a multistate settlement with Experian and T-Mobile over a 2015 data breach that compromised personal information of over 15 million consumers. The companies will pay over $16 million to states and agree to improve data security and vendor management practices. New Jersey will receive approximately $500,000 from the settlement.
Experian must implement a comprehensive information security program with zero-trust principles, regular executive-level reporting, enhanced employee training, data minimization and disposal requirements, and specific security measures including encryption, segmentation, patch management, and access controls. T-Mobile must strengthen vendor management practices. Both companies must offer five years of free credit monitoring services to affected consumers.
In-house legal teams should review vendor agreements (especially with data brokers like Experian), customer agreements (for telecom services like T-Mobile), and data processing agreements. Focus on clauses governing data security obligations, breach notification timelines and procedures, vendor management and oversight requirements, data retention and disposal policies, and consent mechanisms. Changes may include strengthening encryption and access control standards, mandating regular security audits, shortening breach notification windows to consumers and regulators, requiring enhanced third-party risk assessments, and updating data retention schedules to minimize stored personal information.
Entity
Experian and T-Mobile
Industry
Financial ServicesOfficial Press Release
https://www.njoag.gov/nj-to-receive-roughly-500k-from-16m-settlements-over-2012-and-2015-experian-data-breaches/
2022 1107 Experian CV Assurance (Executed Experian and DPC)
https://www.nj.gov/oag/newsreleases22/2022-1107_Experian-CV-Assurance-(Executed-Experian-and-DPC)-Filed-11.7.22.pdf
2022 1107 New Jersey Experian TM Assurance (Experian and DPC
https://www.nj.gov/oag/newsreleases22/2022-1107_New-Jersey_Experian-TM-Assurance-(Experian-and-DPC-Executed)-Filed-11.7.22.pdf
2022 1107 TMobile Assurance ExperianTM (TMobile and DPC Exec
https://www.nj.gov/oag/newsreleases22/2022-1107_TMobile-Assurance-ExperianTM-(TMobile-and-DPC-Executed)-Filed-11.7.22.pdf
New Jersey Attorney General Enforcement Page
https://www.njoag.gov/about/divisions-and-offices/division-of-consumer-affairs/
"Experian and T-Mobile"
"more than $16 million"
"lax data security"
"compromise of consumer data"
A multistate coalition co-led by New Jersey won a federal court order rejecting the Trump Administration’s decision not to request funding for the CFPB. The order struck down that decision and directed the Administration to follow the law and fund the agency; no monetary penalty or privacy violation is described.
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$2.3M
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$694.0M
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$650K
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$96.5M
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