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SEC Warns Registered Firms about Client Privacy and Data Security

• The SEC released a Risk Alert summarizing key areas in which it continues to see compliance deficiencies related to Regulation S-P, the primary SEC rule regarding privacy notices and safeguard policies of investment...more

Non-profit Activists’ Strategic Pursuit of Alleged GDPR Violations Spurs Compliance Developments

• Non-profit organizations are testing companies’ GDPR compliance through targeted requests for information and other means and are filing complaints against allegedly non-compliant companies. • Main areas for non-profit...more

SEC Warns Companies of Potential Internal Accounting Control Violations with Business Email Compromise

• The SEC issued guidance in the form of a rare “21(a) report” this week after investigating a series of email frauds impacting 9 unnamed companies. • These email-based frauds, referred to as “CEO scams” or “vendor scams,”...more

Six Recent Government Supply Chain Risk and Cybersecurity Initiatives

• DoD and other government agencies will scrutinize contractors’ supply chain security plans and programs from proposal submission to contract closeout. • The 2019 NDAA as approved by Congress and DHS initiatives highlight...more

Five New Requirements Under New York DFS Cybersecurity Regulation Go Into Effect on September 1, 2018

On September 1, 2018, five new requirements included in the New York State Department of Financial Services’ (DFS) Cybersecurity Regulation go into effect – (1) audit trails, (2) application security, (3) data disposal...more

Trending in Social Media Law (Part 2): Snapping Away at Biometric Privacy

On May 23, 2016, plaintiffs and Illinois residents Jose Luis Martinez and Malcolm Neal filed a class action in California state court claiming that “Snapchat is actively collecting, storing, and using the biometrics of its...more

Trending in Social Media Law (Part 1): Biometric Privacy and Your Facebook Photos

On May 5, 2016, a federal judge denied Facebook’s attempt to dismiss a consolidated putative class action alleging that Facebook’s “Tag Suggestions” feature violates the Illinois Biometric Information Privacy Act (BIPA)....more

The Panama Papers: Managing Corporate Risk and Uncertainty

On April 3, 2016, it became public that an anonymous source had leaked 11 million confidential documents, known as the “Panama Papers,” belonging to the Panama-headquartered international law firm Mossack Fonseca. As more of...more

New German Data Protection Law Enables a German Version of “Class Actions”

Germany has enacted a new data protection statute, which came into force on February 24, 2016, and enables business associations and consumer groups to enforce violations of German data protection laws against businesses....more

Top 10 Topics for Directors in 2016: Cybersecurity

Cybersecurity - Nearly 90 percent of CEOs worry that cyber threats could adversely impact growth prospects, up from nearly 70 percent the previous year. Yet, in a recent survey, nearly 80 percent of the more than 1,000...more

Senate Passes Burr-Feinstein Cybersecurity Bill

The Senate has passed the Cybersecurity Information Sharing Act (S.754, CISA), sponsored by Sens. Richard Burr (R-NC) and Dianne Feinstein (D-CA), the chair and vice-chair of the Senate Intelligence Committee, by a margin of...more

7th Circuit Opens Door to Data Breach Class Actions

On July 20, 2015, the U.S. Court of Appeals for the 7th Circuit issued an opinion that could dramatically change the class action landscape for companies that are victims of hackers. In Remijas v. Neiman Marcus Gp., the 7th...more

Criminal Cyberattacks: The No. 1 Cause of Health Care Data Breaches in 2014

A new study released on May 7, 2015, by the Ponemon Institute revealed that criminal cyberattacks on health care organizations were the most prevalent cause of data breaches in 2014. The report underscores the need to think...more

SEC Issues New Cybersecurity Guidance for Investment Funds

On April 28, the Securities and Exchange Commission (SEC) Division of Investment Management (the “Division”) published a Guidance Update setting forth cybersecurity concerns and advice for the registered investment ...more

California Eyes Groundbreaking Privacy and Cybersecurity Legislation

In California, home to Silicon Valley, Biotech Beach, drones and some of the nation’s strongest laws protecting personal and consumer privacy, legislators are grappling with how to balance popular innovations in technology...more

Energy & Commerce Subcommittee Holds Hearing on Data Security and Breach Notification; FTC Releases “Internet of Things” Report

Tuesday, the House Energy & Commerce Subcommittee on Commerce, Manufacturing, and Trade held its first hearing of the 114th Congress, entitled “What Are the Elements of Sound Data Breach Legislation?”...more

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