I recently worked at Capital One (left recently), they were not following protocols and probably had gained access to information they should not have had. Tha

I recently worked at Capital One (left recently), they were not following protocols and probably had gained access to information they should not have had. That being said, I highly doubt Capital One is "on the hook" because they were breaking company rules and would have been terminated. Further, I am pretty sure the employees were breaking several laws as well as Capital One's policy (at least according to the contracts I signed and seminars I had to sit through), Capital One would not be directly responsible if they attempted to prevent such behavior (which they do). In this case, Capital One could only be on the hook if they benefited or distributed individuals data, they actually did neither. They had only general sales data and only the two employees illegally made money.