Home Depot has agreed to settle a multi-state enforcement action by 46 U.S. states and Washington, D.C. arising from the data breach that occurred in 2014. Home Depot has agreed to pay $17.5 million to put the enforcement action behind it. The investigation was led by the Attorneys General of Connecticut, Illinois and Texas.

The multi-state investigation followed Home Depot’s data breach that affected 40 million customers who used self-checkout terminals in its U.S. and Canadian stores between April 10, 2014, and September 13, 2014. According to the investigation, hackers used a vendor’s username and password to infiltrate Home Depot’s network and deployed malware to access the customers’ payment card information. In addition to the credit card information, at least 52 million people’s email addresses were exposed.

In announcing the settlement, Connecticut Atty. Gen. William Tong stated that companies collecting sensitive personal information “have an obligation to protect information from unlawful use or disclosure… Home Depot failed to take those precautions.” In addition to the monetary settlement, Home Depot has agreed to hire a Chief Information Security Officer, upgrade its security procedures and provide employee training. Home Depot denies liability in the matter.

Photo of Linn Foster Freedman Linn Foster Freedman

Linn Freedman practices in data privacy and security law, cybersecurity, and complex litigation. She is a member of the Business Litigation Group and the Financial Services Cyber-Compliance Team, and chair’s the firm’s Data Privacy and Security Team. Linn focuses her practice on…

Linn Freedman practices in data privacy and security law, cybersecurity, and complex litigation. She is a member of the Business Litigation Group and the Financial Services Cyber-Compliance Team, and chair’s the firm’s Data Privacy and Security Team. Linn focuses her practice on compliance with all state and federal privacy and security laws and regulations. She counsels a range of public and private clients from industries such as construction, education, health care, insurance, manufacturing, real estate, utilities and critical infrastructure, marine and charitable organizations, on state and federal data privacy and security investigations, as well as emergency data breach response and mitigation. Linn is an Adjunct Professor of the Practice of Cybersecurity at Brown University and an Adjunct Professor of Law at Roger Williams University School of Law.  Prior to joining the firm, Linn served as assistant attorney general and deputy chief of the Civil Division of the Attorney General’s Office for the State of Rhode Island. She earned her J.D. from Loyola University School of Law and her B.A., with honors, in American Studies from Newcomb College of Tulane University. She is admitted to practice law in Massachusetts and Rhode Island. Read her full rc.com bio here.