Different Handling for Cybersecurity Whistleblowers

McDermott Will & Emery attorneys write about the unique characteristics and challenges of cybersecurity whistleblowers. Such relators are likely to become more common in response to the DOJ’s Cyber-Fraud Initiative—which invites them to turn in their employers or other associates in exchange for a cut of the monetary penalties—and statements by the FTC and SEC which also encourage whistleblowers. They warn that “the initial designation and routing of a whistleblower complaint may determine the adequacy of the steps a company will ultimately take (or fail to take) to address it.” They identify several things to do differently, including how to handle internal reports, manage the response, investigate concerns, maintain attorney-client privilege, document resolutions, and facilitate communication among the involved offices.

Source:

• Corporate Compliance Insights: Cybersecurity Whistleblowers Are Different. Here’s How to Deal With Them.