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FTC Brings First Standalone Section 5 Unfairness Claims for Unreasonable Data Retention and Inaccurate Breach Notice

On February 1, 2024, the Federal Trade Commission (FTC) announced a complaint and proposed consent order against Blackbaud, Inc. concerning a 2020 data security incident that included a ransomware demand and payment....more

A Potential Look Into the Future: California Issues First Draft of Cybersecurity Audit and Risk Assessment Regulations

The Board of the California Privacy Protection Agency (the CPPA) held its first meeting since July on Friday, September 8, 2023, and discussed the first public draft of cybersecurity audit regulations and risk assessment...more

Sector-Based Cybersecurity Requirements for Critical Infrastructure, From Our Water Systems to the Skies

Following the release of President Biden’s National Cybersecurity Strategy, Acting National Cyber Director Kemba Walden explained that the Biden Administration is “expecting more” from owners and operators in critical...more

New TSA Rail Cybersecurity Rule Shows Trend Toward Prescriptive Mandates

Background  Critical infrastructure providers confront unique cyber threats. The use of operational technology (OT) introduces risks that arise from, for example, legacy equipment that cannot readily be patched, updated, or...more

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