HackingTechnologyProfessional ServicesInformationVulnerability ExploitStolen CredentialsData ExfiltratedCustomer Data InvolvedIdentity (basic)Government IDHighContained

ComplyRight

bd_3cc02a1b1fb28556 · schema v1 · pii pii-v1

Severity

High

Discovered

May 22, 2018

Filed

Jul 13, 2018

To disclose

7 weeks

Affected

2,100state residents only

Linked

8 filings

Confidence

66%

Full breach record for ComplyRight →

ComplyRight, Inc. notified New Hampshire residents of a security incident involving unauthorized access to its web platform. The breach occurred between April 20 and May 22, 2018, and was discovered on May 22, 2018. Personal information including names, addresses, phone numbers, emails, and Social Security numbers of 2,100 residents was accessed. ComplyRight disabled the platform, engaged forensic investigators, and offered 12 months of credit monitoring.

J jump to incidentP pin to compareR raw source

Incident timeline

undetected · 32 days

discovery → filing · 7 weeks / 52 days

Apr 20, 2018

Begins

May 22, 2018

Discovered

Jul 13, 2018

Filed

vs. sector median

11 wks faster

This filing is one of 8 about the same incident.View merged incident

Linked disclosures

Why this link?

Regulatory filings (7) · sorted by filing gap

Washington State AGbd_ceca03da7c7029f32018-07-13Verified
Montana State AGbd_f9b984c81b6a84802018-07-12 · +1dCandidate
California State AGbd_1c54d5a1341ed63f2018-07-19 · +6dVerified
Massachusetts State AGbd_7f79661b9712d7072018-07-24 · +11dVerified

Show 3 more filings ↓up to 12d gap

South Carolina State AGbd_a24e0da7536f0da92018-07-24 · +11dVerified
Hawaii State AGbd_24a74f3f3d61b6852018-07-25 · +12dVerified
Oregon State AGbd_3a041c49d3f4d0c22018-07-25 · +12dVerified

Name: ComplyRight
norm: complyright
Domain: complyright.com

Name: ComplyRight
norm: complyright
Domain: complyright.com
Industry: TechnologyllmProfessional Servicesllm

Discovered: May 22, 2018
Breach occurred: Apr 20, 2018 – May 22, 2018
Undetected for: 32 daysoccurrence → discovery
Materiality determined: —
Notification sent: Jul 13, 2018
Affected individuals: 2,100state-resident count only
Data types: Identity (basic)Government ID
Data elements: Social Security number
Attack vector: Unauthorized Access
MITRE ATT&CK: T1190 Exploit Public-Facing ApplicationT1078 Valid Accounts
Threat actor: External
Initial access: exploit_public_facing

During the incident: Disabled the platform and remediated the issue on the website
Commenced a prompt and thorough investigation using external cybersecurity professionals
Provided written notice of this incident
Offered a complimentary membership with a credit monitoring and identity theft protection service
Provided dedicated call center support
Advised residents to remain vigilant in reviewing financial account statements
Advised residents about the process for placing a fraud alert on their credit files, placing a security freeze, and obtaining a free credit report
Provided contact information for consumer reporting agencies and the Federal Trade Commission
Changes made: Taking steps to strengthen its security protocols and practices
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 7 weeks(52 days from discovery to filing)
Compliance flags: — (clock not assessable for this source)

Status: No extraction artifact recorded for this disclosure.

Filing propagation · 8 filings · 8 states

View merged incident ↗

Montana State AGJul 12 · first

Washington State AG+1d

New Hampshire State AG+1d · this page

California State AG+7d

Massachusetts State AG+12d

South Carolina State AG+12d

Hawaii State AG+13d

Oregon State AG+13d

Pattern: first filing Jul 12 (MT), last Jul 25 (OR) — a 13-day rolling notification. Rolling spreads often mean counsel is filing as thresholds trip per state. Why this link?

Evidence ladder

Leak-site claim

Attacker assertion only. Establishes: claim date, group, alleged victim.

Press / market report

Unlocks: incident narrative, operational impact. Still no compliance clock.

State AG / regulator filingThis record

Unlocks: discovery date, data types, affected count, compliance clock.

SEC 8-K / victim statement

Unlocks: materiality, stated response, full audit trail. Ceiling removed.

Source URL: https://mm.nh.gov/files/uploads/doj/remote-docs/complyright-20180713.pdf
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: Jul 13, 2018
Raw hash: 159307385600c9525354df3dc419b2ef0d73acbb87046ba701a76d39bce4e0d2

Linked disclosures

Regulatory filings (7) · sorted by filing gap

Reporting entityComplyRight

Victim entityComplyRight

Incidentdiscovered May 22, 2018

Stated responseDisabled the platform and remediated the issue on the website

Complianceclock not assessable

Extraction provenanceno artifact recorded

Source provenancemm.nh.gov