Social EngineeringProfessional ServicesProfessional ServicesPhishingEmployee Data InvolvedTargetedIdentity (basic)Government IDEmploymentMediumContained

O.C. Tanner

bd_b6c8327ade54d00e · schema v1 · pii pii-v1

Severity

Medium

Discovered

Apr 14, 2016

Filed

Apr 26, 2016

To disclose

12 days

Affected

2state residents only

Linked

2 filings

Confidence

65%

Full breach record for O.C. Tanner →2 incidents on file

O.C. Tanner experienced a targeted email phishing attack on April 14, 2016, resulting in the unauthorized disclosure of 2015 W-2 tax form information for employees. The compromised data included names, addresses, Social Security numbers, and wage information. The company discovered the incident on the same day and began notifying affected individuals via email on April 15, 2016. Two New Hampshire residents were affected. O.C. Tanner notified the FBI and IRS, and offered one year of credit monitoring to affected employees.

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Incident timeline

discovery → filing · 12 days

Apr 14, 2016

Begins

Apr 14, 2016

Discovered

Apr 26, 2016

Filed

vs. sector median

17 wks faster

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

Linked disclosures

Why this link?

Regulatory filings (1) · sorted by filing gap

Montana State AGbd_82727d989fbe70cf2016-04-15 · +11dCandidate

Name: O.C. Tanner
norm: oc tanner

Name: O.C. Tanner
norm: oc tanner
Industry: Professional Servicesllm

Discovered: Apr 14, 2016
Breach occurred: Apr 14, 2016
Undetected for: 0 daysoccurrence → discovery
Materiality determined: —
Notification sent: Apr 15, 2016
Affected individuals: 2state-resident count only
Data types: Identity (basic)Government IDEmployment
Data elements: Social Security number
Attack vector: Phishing
MITRE ATT&CK: T1566.002 Spearphishing Link
Threat actor: External
Regulator citations: Notified the Federal Bureau of InvestigationNotified the IRSNotified other state regulators
Initial access: phishing_link

During the incident: Began an investigation to determine the nature and scope of this incident
Notified the Federal Bureau of Investigation, IRS, and other state regulators of this incident
Provided potentially affected individuals access to one (1) free year of credit and identity monitoring services, including identity restoration services, through Experian
Provided potentially affected individuals with information on how to better protect against identity theft and fraud
Changes made: Reviewing its policies and procedures relating to data privacy
Provided further education to its staff on data privacy related issues, including email phishing and spoofing attacks
Working to implement additional safeguards
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 12 days(12 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 ↗

Montana State AGApr 15 · first

New Hampshire State AG+11d · this page

Pattern: first filing Apr 15 (MT), last Apr 26 (NH) — a 11-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/o-c-tanner-20160426.pdf
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: Apr 26, 2016
Raw hash: 275dd7942dc9a1777c1d1c67f9beff054d04162a9f4f06d33bc039a6f30e2740

Linked disclosures

Regulatory filings (1) · sorted by filing gap

Reporting entityO.C. Tanner

Victim entityO.C. Tanner

Incidentdiscovered Apr 14, 2016

Stated responseBegan an investigation to determine the nature and scope of this incident

Complianceclock not assessable

Extraction provenanceno artifact recorded

Source provenancemm.nh.gov