Electronic Data Security • Data Breach • Third Party • Duty of Reasonable Care • Economic Loss Doctrine

Dittman v. UPMC, PICS Case No. 17-0103 (Pa. Super. Jan. 12, 2017) Olson, J. (21 pages).

Trial court properly dismissed appellants negligence and breach of contract claims against appellee in action based on data breach in which employees’ personal information was stolen from employer’s computer system because appellee did not owe a duty of reasonable care in its collection and storage of employees’ data, the economic loss doctrine barred appellants’ claims and there was no implied contract between the parties. Affirmed.