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Epiq performs non-public personal information review for data breach notification in record time

challenge

An Epiq risk management consulting client was supporting one of their clients in the manufacturing industry that was the victim of a data breach. The firm’s immediate task was to determine who needed to be notified of the breach. It was determined the priority was to identify those with non-public personal information exposure and for them to be notified. The document review needed to uncover personal identification information that was exposed. The client had an estimated 40K documents that needed to be reviewed. They needed it fast and they did not want to break the bank. Epiq was first notified on Saturday, and the final notification list was needed by the coming Wednesday.

solution

Epiq utilized 20 reviewers in India and had them begin reviewing documents on Sunday evening U.S. Eastern time. Additionally, 15 reviewers were staffed in New York manage the quality control workflow and for review management. By utilizing resources in both India and NYC, Epiq was able to provide around the clock review staffing. Epiq also created customized workflows and coding forms that were fine-tuned through experience in over 50 previous data breach review matters, which provided extra efficiency and made completion by the requested deadline possible.

execution

Successful execution on quick turn data breach review matters requires creative solutions beyond just staffing teams in multiple time zones. Intelligent and insightful use of technology is paramount to the overall success of the engagement. For this review, the Epiq team created a series of non-public personal identification search terms and regular expressions (7+ pages of terms) that helped target the most likely documents to yield a notification requirement.

The review team also created a Relativity dynamic objectthat allowed just one set offields to link multiple individuals’ non-public personal information to a single document or to link one individual’s NPPI to multiple documents. The review team setup a comprehensive, yet efficient coding layout.

Lastly, to facilitate the population of blank cells for duplicate individuals there were several excel formulas used (4+ pages offormulas). It was this level of detail and commitment to defining a systematic approach that sets the methodology used by Epiq apart from others and yields consistent positive results for our clients in these trying situations.

results

The Epiq team completed the review in less than three days. The project came in on time and under budget, exceeding the client’s expectations.

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