| Regime | Important distinction | Buyer action |
|---|---|---|
| FTC Safeguards Rule | Notification provision effective 13 May 2024; specified events involving at least 500 consumers' unencrypted information generally require notice within 30 days of discovery | Confirm coverage, acquisition/encryption facts and the actual trigger with counsel |
| SEC public-company incident disclosure | The domestic registrant's four-business-day clock runs from materiality determination, not simply detection; determination must not be unreasonably delayed | Define the technical-to-executive escalation and decision record |
| State, sector and contract obligations | May use different populations, triggers and recipients | Maintain an entity-specific matrix and prevent one rule from obscuring another |
Official sources: FTC notification announcement, FTC scope and rule guide and SEC disclosure compliance guide. The state-law row is a required research task, not a claim to have completed a 50-state analysis.
Operational implication: ask responders to preserve a reliable event timeline, explain what is known versus suspected, and update the legal owner as facts change. Technical severity and legal materiality are related decisions, but they are not synonyms.
Working view: explore the first table
Regime
FTC Safeguards Rule
- Important distinction
- Notification provision effective 13 May 2024; specified events involving at least 500 consumers' unencrypted information generally require notice within 30 days of discovery
- Buyer action
- Confirm coverage, acquisition/encryption facts and the actual trigger with counsel
Sources cited on this page
- FTC notification announcement ↗ftc.gov
- FTC scope and rule guide ↗ftc.gov
- SEC disclosure compliance guide ↗sec.gov