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What are the recurring deficiencies that are common to most security lawsuits?

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What are the recurring deficiencies that are common to most security lawsuits?

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It seems that in every security related lawsuit two factors are always in play in some manner. Those factors are security training and incident reporting documentation. When defending this kind of litigation, it is always more difficult when the defendant is not using a computer-based Security Incident Tracking System. This also applies to Daily Activity Reports. Even when there has been adequate security training, there is often a failure to adequately document the training, such as producing test results to show that actual learning took place.

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