*By Chris Tomlinson, Bill Butler, & Jim McLoughlin. Businesses are facing this system hack with ever-increasing frequency: An accounts payable employee receives new or updated payment instructions from a vendor via email. The email appears to be from a familiar…
Archives for Cyber Security
BEWARE COMPROMISED BUSINESS EMAIL . . . AND THE LITIGATION THAT FOLLOWS
*By Chris Tomlinson, Bill Butler, & Jim McLoughlin. Businesses are facing this system hack with ever-increasing frequency: An accounts payable employee receives new or updated payment instructions from a vendor via email. The email appears to be from a familiar…
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Schrems II Opinion Casts Doubt on EU-US Data Protection Rules
Facebook is at the center of the “Schrems” case, which exposed contradictions between U.S. and EU data privacy rules and toppled the U.S./EU Safe Harbor (Schrems I). In Schrems II, Austrian Max Schrems challenges the adequacy of standard contractual clauses…
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The Wait is Over: Proposed Regulations Implementing the CCPA are Released
By Suzanne Gainey and Tandy Mathis. On October 10, California Attorney General Xavier Becerra announced that the long-awaited proposed regulations implementing the California Consumer Privacy Act (“CCPA”) are available for public comment. Although the regulations are not yet final, they do provide some visibility into what the Attorney General will expect from businesses that are subject … Continue reading →
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NY Governor Signs Data Breach Security Law
As anticipated, today New York’s governor signed into law the Stop Hacks and Improve Electronic Data Security Act (SHIELD Act) discussed in our recap of US data breach laws enacted in the first half of 2019. The bill passed the state senate by a margin of 41 – 21. The law updates the body of … Continue reading →
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North Carolina Amendments to Data Breach Law Finally Introduced
On April 16, 2019, Representatives Saine, Jones and Reives introduced House Bill 904, the long anticipated amendments to the North Carolina Identity Theft Protection Act, N.C. Gen. Stat. § 75-61 et seq.. We first wrote about the proposed legislation in February 2018 [Two Proposed Data Security Laws Reflect National Trend Toward Affirmative Responsibilities]. The bill … Continue reading →
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SEC Issues Disclosure Guidance as Part of Continued Focus on Cybersecurity
As cybersecurity attacks have continued to gain prominence as a threat posing critical risk management and compliance challenges for financial institutions, the Securities and Exchange Commission (SEC) has emerged as an active federal regulator in this arena. In September 2017, the SEC announced creation of a Cyber Unit housed within the SEC’s Enforcement Division that … Continue reading →
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SEC Issues Disclosure Guidance as Part of Continued Focus on Cybersecurity
As cybersecurity attacks have continued to gain prominence as a threat posing critical risk management and compliance challenges for financial institutions, the Securities and Exchange Commission (SEC) has emerged as an active federal regulator in this arena. In September 2017, the SEC announced creation of a Cyber Unit housed within the SEC’s Enforcement Division that … Continue reading →
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NYS DFS September 4, 2018 Cybersecurity Compliance Deadline
Tuesday, September 4, 2018 marked the New York State Department for Financial Service’s deadline for compliance with several sections of cybersecurity regulation 23 NYCRR 500 (the “Regulation”). The Regulation covers any organization that operates (or is required to operate) under a license, registration, charter, certificate, permit, accreditation, or similar authorization under the Banking Law (Title … Continue reading →
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Two Proposed Data Security Laws Reflect National Trend Toward Affirmative Responsibilities
With major consumer data breaches making headlines on a semi-regular basis, legislators around the country are starting to hold businesses more accountable for cybersecurity compliance. Industry-specific laws such as HIPAA and the Gramm-Leach-Bliley Act (GLBA) already establish federal data security standards for some companies, and the Federal Trade Commission has taken the position that failure … Continue reading →
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