5 Questions the NY Attorney General is Asking TransUnion and Experian, and the 5 Questions CEOs Should Be Asking Themselves (and Their Team)


Leading cybersecurity can be challenging as a CEO if you don’t know what questions to ask. A top down approach is necessary for an organization to be successful in creating a cyber security culture.

With the recent Equifax breach, many CEOs who haven’t paid attention in the past are starting to ask questions. The truth is, it doesn’t matter what industry you are in, or how many employees or clients you have, just the fact that you exist as a business owner, or entrepreneur, makes you a potential target. Just like being a consumer makes you a potential victim of a breach at every place you spend money.

As a CEO, if you have large B2B clients, irrespective of industry, then that can make you a potential target for a beach because a hacker may want to use your company to get to your client. According to a study by the Identity Theft Resource Center, as many as 42 colleges and universities were victims of cyber-attacks in 2014 alone. The number of U.S. data breaches tracked through June 30, 2017 hit a half-year high of 791. This represents a significant jump of 29% over 2016 figures during the same period. According to SANS, ransomware is the top attack threat to financial institutions (55%), followed by phishing (50%).

Additionally, if you do business with, purchase from or take money from a business that has been breached, that makes you vulnerable. Since 90% of breaches impact small businesses, as a CEO, you can’t escape cyber security, no matter how small you are.

In New York, where the Department of Financial Services enacted cybersecurity regulations for the banking, financial services and insurance industries, the current Attorney General, Eric Schneiderman, is not only investigating the Equifax data breach, but asking TransUnion and Experian what their cyber security strategy was before the Equifax breach and what they have done since the breach.

There are supposedly five questions that Schneiderman’s office wants answers to from Experian and TransUnion by Friday, September 21st:

What security measures did TransUnion (Experian) have in place to ensure the safety of private consumer information before it learned of the Equifax breach, including but not limited to administrative safeguards, technical safeguards, and physical safeguards, as well any best practices or certifications of compliance with any data security regulations or leading standards?

What steps has TransUnion (Experian) taken since learning of the Equifax breach to ensure that TransUnion (Experian) has not already suffered any similar intrusions?

What steps has TransUnion (Experian) taken since learning of the Equifax breach to ensure that it does not experience breaches going forward? Please address steps to prevent both malicious hacking as well as breaches caused by employee negligence.

What steps has TransUnion (Experian) taken since learning of the Equifax breach to help consumers implement additional protections for their private data in TransUnion’s (Experian’s) possession?

Will TransUnion (Experian) consider waiving any fees it currently charges for New York consumers who wish to implement and manage a credit freeze for their files through TransUnion (Experian)?

With the CEO of Equifax testifying before Congress on October 3rd here are 5 questions all CEOs should be asking themselves (before a breach):

What is my cyber security incident response plan for when a breach occurs?

If you don’t have a plan for what to do if there is a breach you are already behind. This also means you most likely don’t have a way to proactively detect if a breach is occurring. The fallacy that you have be a multi-billion-dollar company to be impacted by a breach is false. Living Social, during the same quarter that they announced their data breach revealed the company had a first-quarter operating loss of $44 million on revenue of $135 million. We are seeing solopreneurs lawyers who haven’t taken security seriously compromise their client’s information. Your Chief Information Officer (CIO), General Counsel, or IT team can help you address this question, but as the CEO you have you lead the way.

What are the compliance risks and are they systemic across every vertical?

What are the SOC and PCI challenges that your company many not be reviewing regularly? Do you have a lawyer, or a compliance exert to help you meet regulations for your industry?  This would also be a great question to ask your lawyer or General Counsel.

How long would our business halt if we had a breach?

In other words, how many hours could your team not access email? How many days? How many days could your company go without receiving, or giving, payment until it becomes a liability for the company. One hour? One day? Some companies take up to three weeks just to access email again after a breach. What would that do to your business? Business continuity is critical. As a CEO, you have to know how long your business will stop if there is a breach and how much that will cost you. What is your risk appetite? Your CIO and IT team can help give you an accurate response to this question.

What type of data do we have and who would want it? 

For some companies, they know exactly what data they have that is of valuable. Other companies think they have nothing of value to potential hackers. Does your company collect donor information, PII, user activity or user data? Do you store intellectual property from your company or another companies? Where do you keep your financial and employee data? What data do you have that could be valuable to a third party that you don’t even realize? For example, maybe your client’s customer base. As a CEO, you should know what your most valuable data is, how you collect it and where it is stored. Your CIO or IT leader can help you identify this information.

What is our cyber insurance policy?

We are slowly approaching the point where every business should have a cyber security insurance policy. Especially if you are a B2B company, in highly regulated industries, or if your total sales are over $1 million a year. Cyber insurance will pay for a crisis communications team to help you communicate to internal and external stakeholders. They will also pay for a digital forensics team to support with the response to the breach.  The smaller the company the harder it is to bounce back from a cyber breach. This is a great question to discuss with your corporate attorney.


Jessica Robinson, is a writer and Founder & CEO of PurePoint International. As a cyber security expert, she advises and consults with small and medium sized businesses on cyber prevention and response. Learn more at www.the-purepoint.com.

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