breach-multi-jurisdiction

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SKILL.md

Managing Multi-Jurisdiction Breach Notification

Overview

When a data breach affects individuals across multiple legal jurisdictions, the controller must navigate overlapping and sometimes conflicting notification requirements. The EU GDPR imposes a 72-hour supervisory authority notification deadline; US state laws impose varying timelines and content requirements; and other jurisdictions (Canada, Australia, Brazil, Japan, South Korea) have their own regimes. This skill provides the framework for coordinated notification across jurisdictions.

Jurisdiction Mapping — Notification Requirements

European Union — GDPR (All Member States)

Element Requirement
SA notification timeline 72 hours from awareness (Art. 33(1))
SA notification threshold Unless breach is "unlikely to result in a risk"
DS notification timeline Without undue delay when "high risk" (Art. 34(1))
Lead SA determination One-stop-shop: Art. 56 lead SA based on main establishment
Cross-border mechanism Lead SA notified; other concerned SAs informed via Art. 60
Content requirements Art. 33(3)(a)-(d) for SA; Art. 34(2) for data subjects
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