Penalty Amount
$17,500,000
Consumers Affected
40,000,000
Home Depot settled for $17.5 million over a 2014 data breach that compromised personal information of over 40 million consumers due to inadequate security at self-checkout kiosks. The settlement requires extensive cybersecurity reforms including an information security program, employee training, and encryption. New Jersey receives $579,623 from the multi-state settlement.
Home Depot must pay $17.5 million and implement cybersecurity measures such as creating an information security program headed by an executive, providing security training for personnel, maintaining encryption protocols, implementing strong password policies, two-factor authentication, and firewall policies.
In-house legal teams should review vendor agreements with third-party payment processors and point-of-sale (POS) system providers to ensure they mandate robust security standards for self-checkout kiosks, including encryption and regular vulnerability assessments. Customer agreements and terms of service should be examined for adequate data protection, breach notification, and audit rights clauses. Employee contracts and training materials must align with mandated cybersecurity training requirements. Changes may include adding specific security controls for POS environments, incorporating settlement-mandated encryption standards, clarifying incident response protocols, and ensuring subcontractor compliance with the required information security program.
Entity
Home Depot
Industry
RetailOfficial Press Release
https://www.njoag.gov/ag-grewal-announces-settlement-with-home-depot-over-data-breach-that-compromised-personal-data-of-millions-nj-to-receive-more-than-579000-share-of-17-5-million-settlement/
The Home Depot AVC
https://www.nj.gov/oag/newsreleases20/The-Home-Depot-AVC.pdf
New Jersey Attorney General Enforcement Page
https://www.njoag.gov/about/divisions-and-offices/division-of-consumer-affairs/
"Home Depot"
"Home Depot will pay $17.5 million"
"inadequate security measures in place when data thieves infiltrated its information systems"
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$2.3M
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