FACT PATTERN:
Sullivan Research enters into a contract with XYZ Pharma. Sullivan will be conducting research on subjects related to COVID-19 vaccines. XYZ requires Sullivan collects data from individuals in Massachusetts, New York, and Texas. Sullivan has signed a Business Associate Agreement (BAA) with XYZ Pharma.
A coordinator from Sullivan goes into the office on a Saturday and the computers are locked (i.e. they are locked out of the EDC system) with a notice of a 100 bitcoin demand (i.e. $500,000).
Using IRAC (Issue, Rule, Analysis, Conclusion) identify the potential laws that are at issue, both state and federal, that Sullivan needs to be concerned about and whether, based on those laws, Sullivan has data breach notification requirements.
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