The Silent Risk in Data Breach Reviews - Incorrect Merging
Akshay Misra
Head of Review Services
Iota Analytics
My friend must be everyone’s favorite target; he just received three separate notifications about the same data breach. After the third one arrived, I figured it was time to write this article!
Why Correct Merging is Critical in Data Breach Review for Notifications
When an organization suffers a data breach, one of the most important steps is identifying who was impacted and ensuring that the right individuals are notified. This process may sound straightforward, but in practice, it involves sifting through data from multiple sources, employee records, client databases, vendor files, and more. These voluminous datasets often contain inconsistencies, duplicate entries, and fragmented information.
At the center of this challenge lies one crucial task: merging the data correctly. Without accurate merging, organizations risk regulatory penalties, unnecessary costs, and reputational damage (the annoyance my friend felt by receiving three notifications since his name was not captured consistently or accurately!). Correct merging is not just a technical step; it is the foundation of a defensible and effective breach response.
Accuracy of Impacted Individual Counts
In breach reviews, precision in counting impacted individuals is essential. Datasets may contain the same person listed under different email addresses or with slight variations in their name. If merging is done incorrectly, the review team might double-count them, artificially inflating the number of impacted individuals. On the other hand, missed matches can lead to under-reporting, where not all affected people are accounted for.
Both scenarios create problems: regulators may question inflated numbers, while undercounts risk non-compliance with notification laws.
Avoiding Duplicates in Notifications
Sending multiple notices to the same person may seem like a minor mistake, but it can significantly damage trust. A recipient who receives two or three notifications about the same incident may assume the organization has poor control over its own data. This not only raises doubts among customers but also attracts regulatory scrutiny, as duplicate notifications suggest disorganized handling of sensitive information.
Correct merging helps ensure that each impacted individual receives exactly one notification, no more and no less.
Preventing Missed Notifications
The opposite risk of missing people who should have been notified is even more serious. If an impacted individual is excluded because their records were not merged correctly, the organization may be accused of non-compliance. Regulations such as GDPR, CCPA, and HIPAA place strong emphasis on ensuring that all affected individuals are properly informed.
Missing even a handful of notifications can have outsized consequences, including fines, reputational damage, and potential litigation.
Regulatory Compliance Risks
Regulators expect organizations to demonstrate robust processes for handling breach notifications. An inaccurate notification list caused by poor merging exposes the organization to compliance failures. Authorities may ask for proof of how the impacted list was prepared, and if the merging process cannot withstand scrutiny, the consequences can be severe - financial penalties, consent decrees, and loss of goodwill with oversight bodies.
Correct merging creates a clear, defensible audit trail that shows regulators the organization took its obligations seriously.
Cost Implications of Errors
Notifying individuals after a breach is costly. Expenses include printing and mailing notifications, running dedicated call centers, and in some cases, offering credit monitoring or identity theft protection. If merging errors inflate the list, organizations end up paying for unnecessary notifications.
On the other hand, undercounting often leads to a second round of notifications once the error is discovered which doubles the cost and raises questions about competence. Proper merging helps balance the financial and legal risks by ensuring accuracy from the outset.
Maintaining Data Integrity
Merging is not just about deduplication; it’s also about aligning the right personal information with the right individual. Mistakes here can cause notifications containing sensitive details to be sent to the wrong recipient. Such errors compound the original breach, creating new privacy incidents and undermining confidence in the organization’s handling of sensitive data.
Correct merging safeguards data integrity and minimizes the chance of compounding the breach with further missteps.
Reputational and Legal Risks
Public perception often weighs heavily in breach response. Media outlets are quick to report on mishandled notifications, and plaintiffs’ attorneys actively look for evidence of negligence. Duplicate or misdirected notices, or worse - missed notifications can provide a strong foundation for legal claims.
Accurate merging helps organizations avoid giving adversaries ammunition. It demonstrates diligence, professionalism, and respect for the individuals affected.
Best Practices for Correct Merging
Organizations can improve the accuracy of their breach notification lists by adopting a few best practices:
Deduplication techniques: Use fuzzy matching and unique identifiers to catch duplicates with minor variations.
Data normalization: Standardize name formats, addresses, and dates across datasets.
Quality control checks: Apply sampling and automated validation to confirm accuracy.
Technology + human oversight: Use tools for speed, but rely on human reviewers for judgment calls.
Audit trail creation: Document the merging process for transparency and defensibility.
Conclusion
Data breach notifications are more than a compliance requirement; they are a test of an organization’s integrity and professionalism. Accurate merging ensures that the right people are informed, regulatory risks are minimized, and costs are controlled.
In the high-stakes world of breach response, precision matters and it begins with correct merging.
