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Slew of OCR activity underscores agency’s focus on security and AI

Recent enforcement actions, audit activity, proposed rulemakings, and guidance issued by the U.S. Department of Health and Human Services (“HHS”), Office for Civil Rights (“OCR”) highlight the agency’s focus on health data...more

NIST refines Cybersecurity Security Framework, with increased focus on governance and supply chain

NIST has updated its widely used Cybersecurity Framework to provide key updates and practical resources for organizations to manage and discuss cybersecurity risk. The updated framework, which remains voluntary, is designed...more

SEC proposes significant new cybersecurity disclosure requirements

On March 9, 2022 the SEC proposed rule amendments that would require public companies to report detailed information about material cybersecurity incidents affecting their business and about their cybersecurity risk...more

New York regulator issues cyber insurance risk framework with implications for insurers and insureds

On February 4, the New York Department of Financial Services (NYDFS) released Insurance Circular Letter No. 2 (2021), a Cyber Insurance Risk Framework (Framework) for insurers that write cyber insurance....more

Virginia poised to enact comprehensive consumer privacy law

Virginia is on track to be the second U.S. state to enact comprehensive consumer privacy legislation. Both the Virginia House of Delegates and the Virginia Senate have passed nearly identical versions of the Consumer Data...more

Employers Take Notice: Increased Cybersecurity Threats Amid Coronavirus Precautions

On March 11, the Word Health Organization officially characterized the coronavirus (COVID-19) outbreak as a pandemic. During the outbreak, many employers around the world are seeking to prioritize the well-being and safety of...more

NIST Continues to Make Progress on its Privacy Framework

While eyes focus on the privacy legislative debate now underway in the United States, the development of a new Privacy Framework by the influential National Institute of Standards and Technology (“NIST”) is also worthy of...more

California Passes First-Of-Its-Kind Law Focused on Internet of Things Cybersecurity

Late last month, California Governor Jerry Brown signed the first US Internet of Things (IoT) cybersecurity legislation: Senate Bill 327 and Assembly Bill 1906. ...more

FDA signals increasing focus on cybersecurity requirements

With the continued explosion of software and software-controlled medical devices, including the growing use of machine learning and artificial intelligence, the FDA (the Agency) Medical Device Safety Action Plan (the Plan)...more

SEC Issues New Interpretive Guidance on Cybersecurity Disclosures

Prompted by concern over the increase in the risks and frequency of data breach incidents and other cyber-attacks affecting public companies, the Securities and Exchange Commission recently published interpretive guidance to...more

A guide to NYDFS Cybersecurity Regulation's March 1 implementation deadline

It’s been almost a year since the New York State Department of Financial Services (NYDFS) Cybersecurity Regulation (23 NYCRR Part 500) came into effect. Since that time, a series of key dates have marked the implementation of...more

Working Together: FDA Releases Final Guidance on Interoperability

On September 6, 2017, the Food and Drug Administration (FDA or the Agency) released its final guidance document, Design Considerations and Pre-Market Submission Recommendations for Interoperable Medical Devices (Final...more

The Internet of Things Cybersecurity Improvement Act of 2017: A potential mandate for security standards applicable to...

On 1 August 2017, a bipartisan group of four U.S. senators (Steve Daines (R-MT), Cory Gardner (R-CO), Mark Warner (D-VA), and Ron Wyden (D-OR) introduced the Internet of Things (IoT) Cybersecurity Improvement Act of 2017....more

Bipartisan Group of Senators Introduce Bill to Impose Baseline Security Requirements for IoT Devices Provided to U.S. Government

On August 1, a bipartisan group of four senators introduced a bill that would impose specific cybersecurity requirements on providers of Internet of Things (IoT) devices when doing business with the U.S. Government and...more

National Association of Corporate Directors Updates Cyber-Risk Oversight Handbook

Earlier this year, the National Association of Corporate Directors (NACD) released an updated version of its Director’s Handbook on Cyber-Risk Oversight (Handbook). The updates add 16 pages of content to the previously...more

The “Final Final” is Here: NYDFS Cybersecurity Regulations

As Hogan Lovells previously reported, the New York State Department of Financial Services (NYDFS) has launched a significant initiative to impose detailed cybersecurity requirements on covered financial institutions. On...more

NTIA Highlights Promise and Policy Challenges of IoT, Seeks Additional Comments

On January 12, 2017, prior to the new administration taking power, the National Telecommunications and Information Administration (NTIA) within the Department of Commerce (Department) released a Green Paper on “Fostering the...more

NIST Updates Cybersecurity Framework Guidance

In the past month, the National Institute of Standards and Technology (NIST) has issued a draft update to its flagship cybersecurity framework as well as new standalone guidance on how organizations can plan to recover from...more

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