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The SEC’s amended Regulation S-P, adopted last year, will soon enhance data privacy protections for broker-dealers, investment companies, registered investment advisors, and transfer agents. The updated rule requires these...more
India just released a landmark draft of new rules to refine and implement the Digital Personal Data Protection Act (DPDP Act) – which is India’s first comprehensive data privacy legislation regulating digital personal data...more
On June 28, 2024, Pennsylvania Governor Josh Shapiro signed an amendment to Pennsylvania’s Breach of Personal Information Notification Act into law. The amended law, which includes significant changes to the Keystone State’s...more
On May 16, 2024, the SEC amended Regulation S-P to impose new data privacy and security requirements on broker-dealers, registered investment advisers, investment companies (whether or not they are registered with the SEC),...more
The amended rule requires financial institutions to notify the FTC within 30 days of discovery of a security breach involving information of at least 500 consumers. ...more
Banking organizations must notify the appropriate agency within 36 hours of certain computer-security incidents; and banking service providers must notify affected banking organizations as soon as possible in the event of an...more
Connecticut has become the third state to enact a cybersecurity safe harbor statute. On June 16 and July 6, 2021, Connecticut Governor Ned Lamont signed two new cybersecurity laws that continue the national trend of...more
This quarterly update highlights some of the international data protection issues that have caught our attention, and the attention of our clients, in the past three months....more
On October 1, 2020, the three-month grace period for businesses to comply with the Dubai International Financial Centre (DIFC) Data Protection Law (DIFC Law No. 5 of 2020) (“DPL 2020”) came to an end. Regulating the...more
On March 5, 2020, Gov. Phil Scott (VT-R) signed into law amendments to the Security Breach Notice Act (the “Act”). The amendments, which originated in the State Senate as part of an initiative addressing a number of data...more
On January 1, 2020, the California Consumer Privacy Act (CCPA), a consumer-friendly privacy law inspired by the European Union’s General Data Protection Regulation, is set to take effect. The CCPA is aimed towards bolstering...more
This version updates the third edition of the Survey that we circulated last year, including new statutes and amendments that have been enacted since August of 2018. This survey focuses on the data breach notification...more
On July 25, 2019, New York Governor Andrew Cuomo signed the Stop Hacks and Improve Electronic Data Security Act (the “SHIELD Act”), making key changes to New York’s data breach notification and cybersecurity laws....more
Over the past six months, a significant number of states have amended their data breach notification statutes. Specifically, thirteen states have amended their statutes to: (1) require notice to the State Attorney General,...more
A few weeks ago, Texas signed into law an amendment to its data breach law, capping off a busy first half of 2019 for state lawmakers in this arena. As we gear up for the second half of 2019, we thought a recap was...more
While most state data breach notification statutes contain similar components, there are important differences, meaning a one-size-fits-all approach to notification will not suffice. What’s more, as data breaches continue to...more
On May 24, 2019, Oregon Governor Kate Brown signed into law Senate Bill 684, which requires vendors, service providers and other entities that maintain or possess consumers’ personal information to notify consumers of a...more
As the unofficial start of summer begins, Washington and New Jersey have recently enacted two new pieces of cybersecurity legislation. ...more
On May 10, Governor Phil Murphy signed into law P.L.2019, c.95. an amendment enhancing New Jersey’s data breach notification law by expanding the definition of personal information, and updating notification requirements. As...more
• 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
The much-anticipated amendment to North Carolina’s data breach notification law that we reported on earlier this year (see here) has finally been introduced to the state’s General Assembly. The bill entitled, an Act...more
It was looking like Washington state would be the first state to follow the California Consumer Privacy Act (CCPA), with a GDPR-like law of its own. That effort has stalled, perhaps temporarily. However, both Washington’s...more
Significant changes to the Massachusetts data breach notification law take effect on April 11, 2019. You can view the amendment here. If you haven’t looked at your written information security plan, or WISP, in a while, now’s...more
As attorneys, our livelihood is often heavily dependent upon the keeping of secrets. But in this complex electronic-data driven environment we work in, where physical security via locked doors and piercing alarms may no...more
The Situation: In the wake of the Equifax data breach, Massachusetts has amended its data breach law. The Result: Companies reporting security breaches under the amended data breach law must provide additional information...more