Franklin Templeton Investor Services, LLC
bd_0639a10b4abad7dd · schema v1 · pii pii-v1
Franklin Templeton Investor Services, LLC notified the NH Attorney General of a security incident involving one New Hampshire resident. In April 2015, an employee erroneously assigned a third-party administrator to the resident's 403(b) account and provided that administrator with PII including name, SSN, DOB, and account numbers. The error was discovered in January 2016 during an internal review. The resident was notified in February 2016, and new account numbers were assigned.
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Incident timeline
Apr 1, 2015
Begins
Jan 1, 2016
Discovered
Mar 9, 2016
Filed
vs. sector median
+1 wks slower
Evidence ladder
Attacker assertion only. Establishes: claim date, group, alleged victim.
Unlocks: incident narrative, operational impact. Still no compliance clock.
Unlocks: discovery date, data types, affected count, compliance clock.
Unlocks: materiality, stated response, full audit trail. Ceiling removed.