Disclaimer: Not defending Marriott, as their Starwood Rewards/Marriott Rewards merger has been demonstrably one of the most epic, public IT integration failures that I've ever personally witnessed as a consumer bystander. BLUF: I am a huge advocate of companies being fined on the basis of number of people affected and types of data leaked. This incentive to not be fined will be built into the formal or informal risk…
I agree with the idea that fines based on the number of users affected makes a lot of sense. One question I have is how would you propose that number be calculated? In truth, I think the company whose data has been leaked should know exactly how many records have been leaked, but per-individual based fines create an incentive for them to underreport this number. Do you think that’s a problem, and if so, is there a go…
As a percentage of worldwide revenue on a sliding scale.
> In truth, I think the company whose data has been leaked should know exactly how many records have been leaked, but per-individual based fines create an incentive for them to underreport this number.
Very true, so triple damages for wilful underreporting and/or criminal sanctions for individuals.