MisuseOtherPrivilege AbuseEmployee Data InvolvedCustomer Data InvolvedFinancial accountIdentity (basic)LowContained

Union League Club of Chicago

bd_9979049f9158adfd · schema v1 · pii pii-v1

Severity

Low

Discovered

Mar 5, 2016

Filed

Apr 29, 2016

To disclose

8 weeks

Affected

2state residents only

Linked

2 filings

Confidence

66%

Full breach record for Union League Club of Chicago →

Union League Club of Chicago notified NH AG of an insider incident where an employee used unauthorized keylogging software to capture payment card info and names of members/guests. Occurred Dec 2015-Mar 2016. Discovered Mar 5, 2016. 2 NH residents notified. Employee terminated; FBI notified.

J jump to incidentP pin to compareR raw source

Incident timeline

undetected · 86 days

discovery → filing · 8 weeks / 55 days

Dec 10, 2015

Begins

Mar 5, 2016

Discovered

Apr 29, 2016

Filed

vs. sector median

+2 wks slower

This filing is one of 2 filings about the same incident.View merged incident

Linked disclosures

Why this link?

Regulatory filings (1) · sorted by filing gap

Massachusetts State AGbd_c6ed421da6320bb92016-04-29Verified

Name: Union League Club of Chicago
norm: union league club of chicago
Domain: ulcc.org

Name: Union League Club of Chicago
norm: union league club of chicago
Domain: ulcc.org
Industry: Otherllm

Discovered: Mar 5, 2016
Breach occurred: Dec 10, 2015 – Mar 2, 2016
Undetected for: 86 daysoccurrence → discovery
Materiality determined: —
Notification sent: Apr 29, 2016
Affected individuals: 2state-resident count only
Data types: Financial accountIdentity (basic)
Attack vector: Insider
MITRE ATT&CK: T1056 Input CaptureT1078 Valid Accounts
Threat actor: Internal
Regulator citations: Notified the Federal Bureau of Investigation
Initial access: insider_action

During the incident: Retained an expert computer security firm to examine all Union League computers
Notified the Federal Bureau of Investigation of the incident and is cooperating with its investigation
Established a dedicated call center to assist individuals with any questions
Terminated the employee
Changes made: Removed the keylogger software
Enhancing its technical safeguards related to employee access to personal information
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 8 weeks(55 days from discovery to filing)
Compliance flags: — (clock not assessable for this source)

Status: No extraction artifact recorded for this disclosure.

Filing propagation · 2 filings · 2 states

View merged incident ↗

Massachusetts State AGApr 29 · first

New Hampshire State AGApr 29 · first · this page

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/union-league-club-20160429.pdf
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: Apr 29, 2016
Raw hash: 326236de37dec3dc0967f0fc74dbd38d31c6ec1d48d744021f020b8a6ab10af4

Linked disclosures

Regulatory filings (1) · sorted by filing gap

Reporting entityUnion League Club of Chicago

Victim entityUnion League Club of Chicago

Incidentdiscovered Mar 5, 2016

Stated responseRetained an expert computer security firm to examine all Union League computers

Complianceclock not assessable

Extraction provenanceno artifact recorded

Source provenancemm.nh.gov