a statute in 1985 that partially restored immunity to landowners from some types of lawsuits from trespassers. Colorado's highest court adopted the Rowland unified duty of care analysis in 1971. The resulting explosion of lawsuits against Colorado landowners caused the state legislature to enact the Colorado Premises Liability Act in 1986, which enacted a cleaned-up statutory version of the common law classifications and simultaneously expressly displaced all common law remedies against landowners in order to prevent state courts from again expanding their liability. In the Republic of Ireland, under the Occupiers' Liability Act, 1995, the duty of care to trespassers, visitors and "recreational users" can be restricted by the occupier; provided reasonable notice is given, for which a prominent notice at the usual entrance to the premises usually suffices. Business In business, "the duty of care addresses the attentiveness and prudence of managers in performing their decision-making and supervisory functions." The "business judgment rule presumes that directors (and officers) carry out their functions in good faith, after sufficient investigation, and for acceptable reasons. Unless this presumption is overcome, courts abstain from second-guessing well-meaning business decisions even when they are flops. This is a risk that shareholders take when they make a corporate investment." Cybersecurity With increased cyber threats and attacks, legislation has evolved to incorporate how to establish responsibility in the event of a breach. Key terms in privacy bills and laws cite 'reasonable security' or 'duty of care' as a requirement of organizations when managing sensitive data. If a company manages private information such as social security numbers (SSN) or personal health information (PHI), it is their responsibility to practice 'duty of care' and establish 'reasonable controls' to protect this data. For example, if a hacker group attacks a bank with ransomware, and they exfiltrate all their client data - who is responsible for potential wire fraud, identity theft, and costs for litigation? Businesses are required to demonstrate they have implemented a security strategy based on their risk profile, as it is specific for each working environment. Legislation is outlining specific roles for executives in order to carry out 'duty of care' properly, as in the case of the Colorado Privacy Act. It states, "A controller shall take reasonable measures to secure personal data during both storage and use from unauthorized acquisition. The data security practices must be appropriate to the volume, scope, and nature of the personal data