Wait, that’s covered? Insurability of Fines and Penalties Flowing From a Cybersecurity Breach
FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions
FCPA Compliance and Ethics Report-Episode 30-Interview with the FCPA Professor-Part 2
Condo complaints not in writing?
Health Data on Leased Photocopier Costs Company $1.2m—What Others Can Learn
On June 5, 2025, the UK’s Information Commissioner’s Office (ICO) fined 23andMe £2.31 million (~$3.1 million). The fine was for failing to implement adequate security measures to protect the personal data of over 155,000 UK...more
On 27 March 2025, the UK Information Commissioner’s Office (ICO) issued a £3.07 million fine to an IT services provider following a ransomware attack in 2022 that affected the company’s health care business. The ransomware...more
2024 was a year chock-full of data breaches and privacy violations. Many new data privacy and cybersecurity regulations were introduced (and became effective), and regulators sent a strong message to businesses that privacy...more
In December 2019, the UK Information Commissioner’s Office (ICO) imposed a fine of £275,000 on Doorstep Dispensaree Limited (DDL) for multiple contraventions of the GDPR. On December 9 2024, five years on and three judgments...more
On October 31, 2024, the U.S. Department of Health and Human Services (“HHS”), Office of Civil Rights (“OCR”) announced a $500,000 settlement with Plastic Surgery Associates of South Dakota (“PSA”) concerning potential...more
On 26 August the Dutch Data Protection Authority (DPA) fined Uber EUR 290 million for a breach of the General Data Protection Regulation (GDPR). Following a number of complaints from French Uber drivers, the DPA found that...more
The Brazilian Data Protection Authority (Autoridade Nacional de Proteção de Dados, “ANPD”), applied its first two sanctions of 2024 against two Brazilian governmental institutions. It is worth noting that, as both are public...more
On July 26, 2023, the Securities and Exchange Commission (SEC) implemented new cybersecurity rules to require disclosure of material cybersecurity incidents within four business days, with limited exceptions. Additionally,...more
New York Attorney General Letitia James announced on March 27, 2023 that she had levied a fine against law firm Heidell, Pittoni, Murphy & Bach LLP for failing to secure personal and health information of clients exposing the...more
Report on Patient Privacy 22, no. 5 (May, 2022) - Compared to other agencies, the HHS Office for Civil Rights (OCR) is a little fish in the big federal pond, but it has an outsize effect on HIPAA covered entities (CEs) and...more
New York’s Department of Financial Services (“DFS”) announced on Wednesday, March 3, 2021, that an independent mortgage lender, Residential Mortgage Services Inc. (“RMS”), has agreed to pay a $1.5 million fine to the agency...more
In a remarkable decision, the UK ICO has issued British Airways ("BA") with a £20m fine, in connection with a data breach affecting more than 400,000 customers. This is a significant reduction from the £183m the ICO had...more
The decision to appeal a regulatory finding is never taken lightly. By the time a regulator has completed its investigation and notified a company of its intention to fine, the company will have invested significant time and...more
Since the first enforcement actions have been initiated, some with significant fines, many companies may find themselves somewhat at a loss as they may not fully know how to assess the risks involved and how to react should...more
The Office for Civil Rights (OCR) announced that it has fined the Texas Health and Human Services Commission (TXHHS) $1.6 million for HIPAA violations. This is one of the few fines the OCR has levied against a state agency....more
With it being Halloween, October being National Cybersecurity Awareness Month, and 2019 drawing to an end, let’s take a look at the data privacy breaches giving compliance professionals a fright this year! ...more
Elite Dental Associates (Elite), located in Dallas, Texas has agreed to settle alleged HIPAA violations with the Office for Civil Rights (OCR) for $10,000....more
July 2019 brought an escalation in the enforcement of privacy infringements by companies around the world. The trend began with a press release published on July 8, 2019, of a fine in the approximate amount of GBP 183 million...more
The UK Information Commissioner's Office has announced its intention to issue a £183 million fine to British Airways, in respect of a personal data breach under the GDPR. The announcement has wide-ranging consequences for...more
On 8 July 2019, the UK data protection authority (Information Commissioner’s Office; ICO) issued a notice of its intention to fine British Airways (BA) GBP 183.39 million (approx. USD 229.46 million) for infringements of the...more
The Securities and Exchange Commission recently settled with Voya Financial Advisors, Inc. for alleged violation of Regulation S-ID (otherwise known as the Identity Theft Red Flags Rule) and Regulation S-P (otherwise known as...more
On April 24, 2018, the Securities Exchange Commission (SEC) announced a $35 million fine against the company formerly known as Yahoo! Inc. (now known as Altaba, Inc.) for failing to disclose a massive cyber data breach to its...more