State Data Breach Notification Letter

ARIZONA DATA-INCIDENT NOTIFICATION PREPARATION PACKET

DO NOT SEND OR FILE: This packet collects facts and source decisions. It is not the operative notice.

1. Incident and Matter Record

2. Current Official Source Register

☐ Pending, enacted, and recently effective amendments were checked.

☐ Current agency contact information and submission method were confirmed.

3. Entity Role and Data-Control Map

Owner/licensee or other upstream notification required: [________________________________]

Downstream service-provider or vendor notification required: [________________________________]

4. Person and Data-Element Analysis

Do not treat a general label such as “personal data,” “PII,” “health data,” or “credentials” as a statutory conclusion.

Public-record, encrypted-data, good-faith, or other exclusion analysis: [________________________________]

5. Event, Acquisition, and Risk Analysis

6. Notification Decision Matrix

Master deadline source and calculation record: [________________________________]

Law-enforcement delay request, scope, authority, and release: [________________________________]

7. Operative Resident-Notice Content Map

Draft the operative notice only after counsel completes this table from the current source.

8. Operative Regulator Submission Map

9. Delivery, Accessibility, and Substitute Notice

10. Accuracy and Communication Controls

☐ Each statement is supported by the incident investigation and approved evidence.

☐ No statement of “no fraud,” “no misuse,” containment, eradication, encryption, or affected count exceeds the evidence.

☐ Consumer, regulator, employee, customer, media, insurer, vendor, and law-enforcement communications are reconciled.

☐ Privilege, work-product, confidentiality, public-records, and litigation-hold issues were reviewed.

☐ URLs, telephone numbers, enrollment codes, hours, deadlines, and agency contacts were tested immediately before release.

☐ Translation, disability access, deceased persons, minors, returned mail, and undeliverable notices were addressed.

11. Operative Document and Approval Record

This packet remains non-operative. List each separately approved notice or filing.

12. Completion Checklist

☐ Current official Arizona law and Attorney General procedure were read and recorded

☐ Entity role, resident status, data elements, combinations, encryption, access, acquisition, and risk were analyzed

☐ Resident, regulator, consumer-reporting, owner/licensee, sector, contract, and other-state routes were separated

☐ Every deadline uses the correct trigger, delay rule, and current source

☐ Required, optional, and prohibited content is mapped for each recipient

☐ Delivery, substitute notice, accessibility, translation, and proof records are complete

☐ Operative notices and submissions were separately drafted, approved, tested, and sent through current channels

END OF NON-OPERATIVE PREPARATION PACKET