The old song by The Byrds says there is a season for everything. In the data protection world, the season for getting key issues settled with vendors is before closing the deal—when they are most eager to get something done. Anything after that is too late. Here’s why.

In recounting recent incident response “war stories,” one case stood out as a poster child for what can go wrong with a vendor. [Please note that the names have been omitted and some details have been changed to protect the guilty.] The client in this case received federal and state funding for providing important public services to the local community. In performing their services, the client collected sensitive personal information subject to state and federal privacy regulations. They had faithfully served the community for decades without incident.  When a large trove of data appeared on a dark web leak site containing sensitive personal information on the customers of the client, a major investigation ensued. After detailed examination, nothing in the client’s organization indicated a data breach had occurred. No lost laptops, no open S3 buckets, no advanced persistent threats (APTs). Nothing. So where had the leaked data come from?

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