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possible. Improperly handled data breaches can be extremely costly not only directly tothe balance sheet, but additionally to the reputation of the company. Below we discussbasic features of a generic data breach response plan.A. Lock it Down and Clean it Up.It is critical that the company stop the bleeding, immediately close the leak, and secureany data that has not yet been compromised. 35Management should physically securethe affected data systems, data, and documentation. 36B. Retain Breach Counsel.Upon learning of a data breach, companies should promptly make a call to outsidecounsel knowledgeable in responding to data breach emergencies (“breach counsel”). 37Breach counsel should direct the investigation so that the data breach investigation isprotected by the attorney-client privilege and work product doctrines. 38Breach counselshould also conduct their own investigation, including interviewing key employees,35 Dave Maxfield and Bill Latham, Data Breaches Perspectives from Both Sides of the Wall, SouthCarolina Lawyer, May 2014, at 33.36 Id. at 34.37 Id.38 Id.March 6, 2015 22 © 3-6-2015 ALFA International Business Litigation P.G.