Our company experienced a cybersecurity incident. It seemed pretty minor — just a few suspicious emails and an employee’s account being locked. To my dismay, we’re now hearing from our IT team that the issue is more serious....more
It is no secret that ransomware dominates headlines, and cybersecurity incidents have become part of our everyday language. However, the criminal “business model” behind ransomware keeps evolving.
Originally published in...more
1/23/2025
/ Business Continuity Plans ,
Cybersecurity ,
Data Breach ,
Data Breach Plans ,
Data Protection ,
Federal Trade Commission (FTC) ,
Forensic Accounting ,
Incident Response Plans ,
Ransomware ,
Risk Management ,
Third-Party Risk ,
Third-Party Service Provider
By now, public companies are generally aware of the cybersecurity rules adopted by the U.S. Securities and Exchange Commission a year ago, requiring public companies to disclose material cybersecurity incidents under Item...more
10/21/2024
/ Cyber Attacks ,
Cyber Incident Reporting ,
Cybersecurity ,
Data Breach ,
Data Protection ,
Data Security ,
Disclosure Requirements ,
Form 8-K ,
Incident Response Plans ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
“Dear Mary” is Troutman Pepper’s Incidents + Investigations team’s advice column. Here, you will find Mary’s answers to questions about anything and everything cyber-related — data breaches, forensic investigations, how to...more
“Dear Mary” is Troutman Pepper’s Incidents + Investigations team’s advice column. Here, you will find Mary’s answers to questions about anything and everything cyber-related — data breaches, forensic investigations, how to...more
“Dear Mary” is Troutman Pepper’s Incidents + Investigations team’s advice column. Here, you will find Mary’s answers to questions about anything and everything cyber-related — data breaches, forensic investigations, how to...more
Each of the 50 states has its own definition of what constitutes a reportable data breach. For some, it requires “unauthorized access” to personal information. For others, it requires “unauthorized acquisition.” And then,...more
7/25/2024
/ Cybersecurity ,
Data Breach ,
Data Collection ,
Data Privacy ,
Data Protection ,
Data Security ,
Data Theft ,
Identity Theft ,
Personal Data ,
Personally Identifiable Information ,
Unauthorized Access
‘Dear Mary,’ is Troutman Pepper’s Incidents + Investigations team’s advice column. Here, you will find Mary’s answers to questions about anything and everything cyber-related – data breaches, forensic investigations, how to...more
On June 24, the staff of the U.S. Securities and Exchange Commission's (SEC) Division of Corporation Finance (Division of Corporation Finance) released five new Compliance & Disclosure Interpretations (C&DIs) relating to the...more
7/17/2024
/ C&DIs ,
Cyber Threats ,
Cybersecurity ,
Data Breach ,
Data Privacy ,
Data Protection ,
Disclosure Requirements ,
Enforcement Actions ,
Ransomware ,
Regulation FD ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Securities Violations
‘Dear Mary,’ is Troutman Pepper’s Incidents + Investigations team’s advice column. Here, you will find Mary’s answers to questions about anything and everything cyber-related – data breaches, forensic investigations, how to...more
‘Dear Mary,’ is Troutman Pepper’s Incidents + Investigations team’s advice column. Here, you will find Mary’s answers to questions about anything and everything cyber-related – data breaches, forensic investigations, how to...more
‘Dear Mary,’ is Troutman Pepper’s Incidents + Investigations team’s advice column. Here, you will find Mary’s answers to questions about anything and everything cyber-related – data breaches, forensic investigations, how to...more
‘Dear Mary,’ is Troutman Pepper’s Incidents + Investigations team’s advice column. Here, you will find Mary’s answers to questions about anything and everything cyber-related – data breaches, forensic investigations, how to...more
‘Dear Mary,’ is Troutman Pepper’s Incidents + Investigations team’s advice column. Here, you will find Mary’s answers to questions about anything and everything cyber-related – data breaches, forensic investigations, how to...more
On May 21, 2024, Erik Gerding, the director of the Division of Corporation Finance of the Securities and Exchange Commission (SEC), released a statement containing guidance for public companies regarding the disclosure of...more
6/5/2024
/ Cybersecurity ,
Data Breach ,
Disclosure Requirements ,
Federal Breach Notification Standard ,
Final Rules ,
Form 8-K ,
New Guidance ,
Popular ,
Publicly-Traded Companies ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
‘Dear Mary,’ is Troutman Pepper’s Incidents + Investigations team’s advice column. Here, you will find Mary’s answers to questions about anything and everything cyber-related – data breaches, forensic investigations, how to...more
As we discussed in part three of this series, “Navigating the Complexities of Regulatory Data Incident Investigations,” when an organization is the subject of regulatory data incident investigations, it must navigate a...more
2/19/2024
/ Consumer Privacy Rights ,
Cybersecurity ,
Data Breach ,
Data Privacy ,
Data Protection ,
Data Security ,
Incident Response Plans ,
Investigations ,
NIST ,
Personal Data ,
Personally Identifiable Information ,
Privacy Laws ,
Regulatory Oversight ,
Regulatory Reform ,
Regulatory Requirements ,
Settlement
Unauthorized Access, Troutman Pepper's privacy and cybersecurity-focused podcast, spotlights the human aspect of the cybersecurity industry, introducing you to the remarkable personalities that make the industry amazing....more
It is indeed a tangled regulatory web woven to potentially trap an organization in the wake of a data incident. Navigating this web can involve significant resources, time, and stress. As we discussed in part two of this...more
12/13/2023
/ Consumer Privacy Rights ,
Cybersecurity ,
Data Breach ,
Data Collection ,
Data Privacy ,
Data Protection ,
Data Security ,
Personal Data ,
Personally Identifiable Information ,
Privacy Laws ,
Regulatory Oversight ,
State Attorneys General
Popular file transfer tool MOVEit’s recent data security vulnerability prompted many businesses to communicate, internally and externally, about the impact of the incident on its business.
Originally published in Law360 -...more
10/16/2023
/ Consumer Privacy Rights ,
Cyber Incident Reporting ,
Cybersecurity ,
Data Breach ,
Data Privacy ,
Data Protection ,
Data Security ,
Electronic Communications ,
Incident Response Plans ,
Personal Data ,
Personally Identifiable Information ,
Popular
Government regulators are seemingly as numerous as the stars nowadays, especially in the universe of data incidents. When organizations experience a data incident, they will need to quickly assess what happened, why it...more
10/16/2023
/ Consumer Privacy Rights ,
Cybersecurity ,
Data Breach ,
Data Collection ,
Data Privacy ,
Data Protection ,
FTC Act ,
Health Insurance Portability and Accountability Act (HIPAA) ,
OCR ,
Personally Identifiable Information ,
PHI ,
Regulatory Agencies ,
State Attorneys General
In the burgeoning realm of data incidents, it is a truism that such incidents are not created equal. Indeed, a data incident is not necessarily a data breach.
Originally published in Reuters -August 24, 2023...more
8/25/2023
/ Consumer Privacy Rights ,
Cybersecurity ,
Data Breach ,
Data Collection ,
Data Privacy ,
Data Protection ,
Data Security ,
NIST ,
Personal Data ,
Personally Identifiable Information ,
Popular ,
Privacy Laws ,
Regulatory Oversight
On July 26, the Securities and Exchange Commission (SEC) adopted, by a 3-2 margin, a final rule to require more immediate disclosure of material cybersecurity incidents by public companies. In addition, the final rule...more
Before we jump into February developments — trigger warning if you are a Russian hacker — for those keeping track of breach notification requirements, the National Credit Union Administration (NCUA) Board approved a final...more
3/8/2023
/ Cybersecurity ,
Data Breach ,
Data Privacy ,
Data Protection ,
FCC ,
Hackers ,
Malware ,
National Security Agency (NSA) ,
NCUA ,
Ransomware ,
Spyware ,
Telecommunications
A thesis statement for this month's Cyber Capsule might be "You're Doing It Wrong." Whether it's easily guessable passwords, manipulated URLs, or waiting longer than prudent to report a data breach, most of our items look at...more