Effective Communication
One key lesson from these incidents is the importance of effective client communication when a breach occurs. Where the breach poses a high risk to affected individuals, Article 34 of the GDPR mandates companies communicate the breach directly and promptly to their customers.
These luxury brands have responded by adopting clear, timely communication strategies to maintain trust. Companies have prioritized prompt notification, reaching out quickly to affected customers via email or official letters as soon as the breach was confirmed. This proactive approach ensures that clients receive information directly from the source.
Both Dior and Cartier went a step further by providing advice and support to their clients. Their communications included guidance on protecting themselves, urging clients to be vigilant and avoid falling for phishing emails that could misuse their personal data. By offering advice, these companies empowered their customers to mitigate potential follow-on fraud.
Transparency with Clients
Notifications from Dior and Cartier specifically outlined what information was exposed, while also reassuring customers about what remained safe, particularly financial credentials. This transparency helps prevent misinformation and demonstrates the company's commitment to accountability.
Detailed communications ensure legal compliance with Article 34(3) of the GDPR, specifically communications using clear and simple language to explain the nature of the breach, its consequences, and the measures taken. If the controller fails to notify its customers, the supervisory authority may require them to do so. However, such non-compliance risks the authorities considering the omissions of the business when determining the quantity of fines to be imposed.
Reporting Obligations
Both luxury brands took steps to meet their legal reporting obligations, by notifying the respective data protection authorities. Article 33(1) of the GDPR requires controllers to notify the breach to the appropriate supervisory authority within 72 hours of becoming aware of it, unless the breach is unlikely to result in a risk to their customers’ rights.
Article 33(3) requires businesses not only to disclose the nature and scope of the breach, but also to outline the categories of data affected, the number of individuals impacted, and the measures taken or proposed for remediation. By adhering to these requirements, Dior and Cartier demonstrated their commitment to both regulatory compliance and the protection of their clients' personal data, reinforcing trust even in the wake of a security incident.