Our Securities Litigation, Securities, and Privacy, Cyber & Data Strategy teams outline vital takeaways for public companies and their directors and officers in light of the Securities and Exchange Commission’s recent civil...more
11/13/2023
/ Chief Information Security Officer (CISO) ,
Corporate Liability ,
Cybersecurity ,
Data Security ,
Disclosure Requirements ,
Enforcement Actions ,
Fraud ,
Popular ,
Publicly-Traded Companies ,
Securities and Exchange Commission (SEC) ,
SolarWinds
Our Privacy, Cyber & Data Strategy and Privacy & Cybersecurity Litigation teams examine the New York Department of Financial Services’ finalized Second Amendment to its Cybersecurity Regulation....more
On October 27, 2023, the FTC approved an amendment to the Safeguards Rule (the “Amendment”) requiring that non-banking financial institutions notify the FTC in the event of a defined “Notification Event” where customer...more
The Federal Bureau of Investigation (FBI) issued a Private Industry Notification on September 27, 2023, highlighting two concerning ransomware trends and providing companies with guidance on mitigating potential threat actor...more
On October 4, 2023, the National Security Agency (NSA) and Cybersecurity and Infrastructure Security Agency (CISA) published Identity and Access Management: Developer and Vendor Challenges, an advisory document developed by...more
On September 27, 2023, The U.S. National Security Agency (NSA), the U.S. Federal Bureau of Investigation (FBI), the U.S. Cybersecurity and Infrastructure Security Agency (CISA), the Japanese National Police Agency (NPA), and...more
New York Attorney General Letitia James recently announced two agreements related to data breaches with entities that operate in the education industry. In both instances the entities paid the ransom and received evidence of...more
In late August 2023, the California Privacy Protection Agency (“CPPA” or “Agency”) released a discussion draft of proposed regulations under California’s data privacy law, the California Consumer Privacy Act (“CCPA”)....more
Publications and Advisories - July 31, 2023 – Dave Brown, Kate Hanniford, Kim Peretti, Julia Mediamolle, Cara Peterman, Sierra Shear, Kristen Bartolotta, and Kezia Osunsade published “Securities Law, Securities Litigation,...more
8/10/2023
/ Artificial Intelligence ,
California Consumer Privacy Act (CCPA) ,
Civil Investigation Demand ,
COPPA ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Federal Trade Commission (FTC) ,
Hackers ,
International Data Transfers ,
Online Safety for Children ,
Popular ,
Ransomware ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Standard Contractual Clauses ,
Telehealth
Our Securities, Securities Litigation, and Privacy, Cyber & Data Strategy teams highlight the key aspects of the Securities and Exchange Commission’s final changes to its cybersecurity reporting rules for public companies...more
In mid-July, the Federal Trade Commission (FTC) reportedly opened an investigation into OpenAI, the maker of ChatGPT, sending the company an extensive Civil Investigative Demand (CID). While FTC investigations are normally...more
The New York Department of Financial Services (“NY DFS”) published an updated proposed Second Amendment to its Cybersecurity Regulation (23 NYCRR Part 500) in the New York State Register on June 28, 2023, updating its...more
On June 13, 2023, the Securities and Exchange Commission (“SEC”) published its Spring 2023 rulemaking agenda that delayed finalizing the proposed Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure...more
On June 7, 2023, the Federal Bureau of Investigation (FBI) and the Cybersecurity and Infrastructure Security Agency (CISA) released a Joint Cybersecurity Advisory in connection with a recent zero-day (or previously...more
On May 1, 2023, bitFlyer USA, Inc. (“bitFlyer”) entered into a Consent Order with the New York Department of Financial Services (“DFS”) for multiple deficiencies in bitFlyer’s cybersecurity program, most notably for failure...more
Publications and Advisories - April 5, 2023 – Kate Hanniford and Elinor Hiller published “Healthy Byte: White House and HHS Both Update Their Cybersecurity Guidance.”...more
Our Privacy, Cyber & Data Strategy Team breaks down how the two dozen strategic objectives in Biden’s National Cybersecurity Strategy will fundamentally shift how the United States allocates roles, responsibilities, and...more
Publications and Advisories - February 10, 2023 – Kathleen Benway, David Keating, and Sara Pullen Guercio published “Privacy, Cyber & Data Strategy / Consumer Protection/FTC Advisory: Limit Your Health Data Sharing and Call...more
2/15/2023
/ California Consumer Privacy Act (CCPA) ,
California Privacy Rights Act (CPRA) ,
Consumer Privacy Rights ,
Cybersecurity ,
Data Breach ,
Data Privacy ,
Data Protection ,
Data Security ,
FCC ,
Federal Trade Commission (FTC) ,
Personal Information ,
Popular ,
State Privacy Laws
On January 6, 2023, the FCC released a Notice of Proposed Rulemaking (the “Notice”) proposing to “modernize the Commission’s data breach rules,” and thereby launching a formal effort to gather information from the industry on...more
The New York Department of Financial Services (“DFS”) released their proposed second amendment to the Cybersecurity Regulation, 23 NYCRR Part 500 (“Proposed Second Amendment”) on October 9, 2022....more
Selected U.S. Privacy and Cyber Updates - California Privacy Protection Agency Issues Notice of Modifications to Proposed CPRA Regulations - On November 3, 2022, the California Privacy Protection Agency (CPPA) issued a notice...more
The United Kingdom’s National Cyber Security Centre (NCSC) recently released its 2022 Annual Review, which reports on the state of cyber security threats in the country. As the UK’s technical authority for cyber security, the...more
On October 31, 2022, the Federal Trade Commission (FTC) announced it has taken action against education technology provider Chegg Inc. (“Chegg”) for its “careless” cybersecurity practices that exposed sensitive personal...more
On October 24, 2022, the Federal Trade Commission (“FTC”) announced a proposed consent order against both Drizly LLC, an online marketplace for alcohol delivery, and its CEO over the company’s alleged security failures that...more
On October 18, 2022, EyeMed Vision Care LLC (“EyeMed”) entered into a Consent Order with the New York Department of Financial Services (“DFS”) relating to a cybersecurity event from 2020 that exposed consumer nonpublic...more