HackingProfessional ServicesProfessional ServicesData ExfiltratedCustomer Data InvolvedIdentity (basic)Government IDMediumContained

Gallagher NAC

bd_d97fa06fce151999 · schema v1 · pii pii-v1

Severity

Medium

Discovered

Sep 21, 2017

Filed

Nov 13, 2017

To disclose

8 weeks

Affected

Not disclosed

Linked

5 filings

Confidence

64%

Full breach record for Gallagher NAC →

Gallagher NAC reported that unusual activity was detected on September 21, 2017, relating to a database tied to a customer web application. Investigation determined that a small amount of data left the system between June 18, 2017, and September 19, 2017. The data potentially included names and Social Security numbers of individuals affiliated with client organizations. The web application was disabled, and a third-party forensic firm was retained. Affected individuals were offered credit monitoring and identity theft protection services.

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California clockDiscovered Sep 21, 2017 → Notified Oct 25, 201734d ✓ CA 60-day OK8 weeks discovery → filing

Incident timeline

undetected · 95 days

discovery → filing · 8 weeks / 53 days

Jun 18, 2017

Begins

Sep 21, 2017

Discovered

Nov 13, 2017

Filed

vs. sector median

11 wks faster

This filing is one of 5 about the same incident.View merged incident

Linked disclosures

Why this link?

Regulatory filings (4) · sorted by filing gap

Oregon State AGbd_a59e584f1b7409712017-11-13Candidate
New Hampshire State AGbd_afacb937f8715b572017-11-13Verified
Massachusetts State AGbd_c1cec3b579ba2a9b2017-11-13Verified
Washington State AGbd_d016f68e21f1ab0c2017-11-13Verified

Name: Gallagher NAC
norm: gallagher nac

Name: Gallagher NAC
norm: gallagher nac
Industry: Professional Servicesllm

Discovered: Sep 21, 2017
Breach occurred: Jun 18, 2017 – Sep 19, 2017
Undetected for: 95 daysoccurrence → discovery
Materiality determined: —
Notification sent: Oct 25, 2017
Affected individuals: Not disclosed
Data types: Identity (basic)Government ID
Attack vector: Unknown
MITRE ATT&CK: T1041 Exfiltration Over C2 Channel
Regulator citations: Provided notice to state regulators and consumer reporting agencies as required

During the incident: Disabled the web application
Retained a leading third-party forensic investigation firm to assist with the internal investigation
Reporting this incident to law enforcement, as necessary
Providing notice to state regulators and consumer reporting agencies as required
Offering identity theft protection services through ID Experts, including 12 months of credit monitoring, a $1,000,000 insurance reimbursement policy, and fully managed id theft recovery services
Changes made: Working with third-party forensic investigation team to ensure the security of our systems
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 8 weeks(53 days from discovery to filing)
Compliance flags: CA 60-day OK · 34d
Discovery-date grounding: letter-groundedThe discovery date is the detection date narrated in the notification letter — the defensible tier.
Clock breakdown: Statute Window Elapsed Threshold Status
California
Discovered: Sep 21, 2017
→ Notified: Oct 25, 2017
34d 60 days (analyst band, pre-2026 discoveries) CA 60-day OK

Statute	Window	Elapsed	Threshold	Status
California	Discovered: Sep 21, 2017 → Notified: Oct 25, 2017	34d	60 days (analyst band, pre-2026 discoveries)	CA 60-day OK

Status: No extraction artifact recorded for this disclosure.

Filing propagation · 5 filings · 5 states

View merged incident ↗

Oregon State AGNov 13 · first

New Hampshire State AGNov 13 · first

Massachusetts State AGNov 13 · first

Washington State AGNov 13 · first

California State AGNov 13 · 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://oag.ca.gov/ecrime/databreach/reports/sb24-104236
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: Nov 13, 2017
Raw hash: ffdc4c6f7af9ac0197735adf27a817a20645b6b914fec65931d011a4979e39b8

Linked disclosures

Regulatory filings (4) · sorted by filing gap

Reporting entityGallagher NAC

Victim entityGallagher NAC

Incidentdiscovered Sep 21, 2017

Stated responseDisabled the web application

ComplianceCA 60-day OK

Extraction provenanceno artifact recorded

Source provenanceoag.ca.gov