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The Man Who Wrote Those Password Rules Has a New Tip: N3v$r M1^d!

Great article in the Wall Street Journal this week (paywall), on the history of passwords and password management. I did not know that the seeming obsession with passwords featuring a strange mixing of capital letters,...more

8/10/2017  /  Data Protection , NIST , Passwords

“If You Are Reading This, You Probably Weren’t Hacked Last Week” – So Now What?

First, the basic facts about the recent ransomware attack: ..US-CERT has received multiple reports of WannaCry ransomware infections in several countries around the world. ..Ransomware is a type of malicious software that...more

Google Docs Phishing (in real time, May 3, 2017, 4:30pm)

If you check your email this afternoon, you may see a message that someone you know is sharing something on Google Docs....more

Is Computer Security Broken?

The Economist certainly thinks computer security is broken (and it’s hard to argue the contrary). In its April 8 edition, The Economist’s cover story proclaims, “Why computers will never be safe.” While that’s good news for...more

Want to Know Why Memorial Healthcare Systems Is Paying HHS OCR $5.5 Million?

On February 16, 2017, HHS OCR announced that Memorial Healthcare Systems (MHS) had paid the U.S. Department of Health and Human Services (HHS) $5.5 million to settle potential violations of HIPAA’s Privacy and Security Rules...more

Additional Clarification regarding HHS OCR Phishing Email Alert

More information from HHS OCR about the phishing threat... ..On November 28, 2016, the HHS Office for Civil Rights issued a listserv announcement warning covered entities and their business associates about a phishing...more

HHS OCR Alert: Phishing Email Disguised as Official OCR Audit Communication

This alert just in from HHS OCR: “It has come to our attention that a phishing email is being circulated on mock HHS Departmental letterhead under the signature of OCR’s Director, Jocelyn Samuels. This email appears to...more

More on HIPAA Audits for 2016 and 2017–Desk Audits and On-Site Audits

As part of the ongoing HHS OCR HIPAA audit initiative, it is conducting “HIPAA desk audits.” These audits don’t involve auditors coming in your facility. Instead, covered entities are being asked to submit documents on...more

Sharing Consumer Health Information? Look to HIPAA and the FTC Act

Does your business collect and share consumer health information? Check out these tips from the FTC for complying with HIPAA and the FTC Act....more

Quick Thoughts About the Yahoo Breach

Another day, another 500 million Yahoo accounts reached. Our friends at the FTC are right on top of this with guidance for individuals with Yahoo accounts. First and foremost, change your Yahoo password....more

Bad News for HIPAA Business Associates: HHS OCR Announces $650,000 Settlement for BA Breach

Catholic Health Care Services of the Archdiocese of Philadelphia (“CHCS”), a HIPAA business associate, has agreed to pay the Department of Health and Human Services Office of Civil Rights (“OCR”) $650,000 in connection with a...more

Cybersecurity News and Notes – June 2016

In Case You Missed It: US and EU officials signed on to the so-called “Privacy Umbrella” deal last week. The agreement is designed to protect the personal data of EU citizens when it is transferred to the US for law...more

HHS OCR Launches Phase 2 of HIPAA Audit Program–So What?

You have seen all the hysterical headlines — “The HIPAA audits are coming, the HIPAA audits are coming….” But when you really think about it, what is the big deal? If you are a HIPAA covered entity, you surely know by now...more

Challenging the Conventional Wisdom on Mandatory Password Changes

Very interesting thought piece from the FTC’s Chief Technologist. Do mandatory password resets actually make us less secure? ...more

3/4/2016  /  Cybersecurity , FTC , Passwords

President Obama Signs the Judicial Redress Act (H.R.1428/S.1600)

As part of implementing the EU-US Privacy Shield, on February 24, 2016, President Obama signed the Judicial Redress Act (H.R.1428/S.1600). This law is designed to give EU citizens the right to sue the U.S. government for...more

In Cybersecurity, No Harm Does Not Necessarily Mean No Foul

How much does the question of harm matter in cybersecurity law? The answer is: It depends on who is bringing the claim. Businesses confronting data breaches can face litigation from private consumers as well as from...more

The Cybersecurity Act of 2015: Implications for Threat Sharing

On December 18, 2015, President Obama signed the Cybersecurity Act of 2015 (The “Act”), legislation designed to combat online threats to the federal government, state and local governments, and private entities. Within the...more

EU Commission and United States agree on new framework for transatlantic data flows: EU-US Privacy Shield

What follows below is the EU’s press release regarding the agreement on a replacement for the EU-US Safe Harbor. We are working to get details and will schedule a webinar on the new framework shortly....more

EU Safe Harbor Update: No Solution in January?

As we have noted previously, in the wake of the ECJ’s decision that undid the US-EU Safe Harbor, we were told that there would be no enforcement of the EU Directive until after January 31, to allow the US and EU to hammer out...more

Phishing for Christmas

As the Wall Street Journal noted yesterday, banks are being deluged with phishing attacks. These attacks are especially fierce around the holiday season, when more personnel are absent and normal procedures are ignored or...more

EU Gives US Until “The End of January” to Find Safe Harbor Solution or Enforcement Could Begin

On October 16, 2015, EU authorities gave the U.S. and European Union until the end of January 2016 6o find a replacement for the former US-EU Safe Harbor regime, or enforcement actions could begin. The full statement of the...more

The European Court of Justice Invalidates Safe Harbor

The European Court of Justice has just issued a decision (ECJ 6 October 2015 Case C-362/14, Maximillian Schrems v. Data Protection Commissioner) that invalidates the so-called US-EU “Safe Harbor” system. Suddenly, what 3,500...more

What is reasonable? The emerging legalities of cybersecurity post-Wyndham

This month’s edition of the Advanced Cyber Security Center’s newletter includes my discussion of lessons to be learned from the Wyndham decision: Historically, security was an issue reserved in a back room for the IT...more

Reflections on “Privacy in the Modern Age”

With the heart of the summer vacation season upon us, it seems like a good time for some reflection. Here, it comes in the form of excerpts from an essay by privacy maven, Deborah Hurley. The one time Director of the Harvard...more

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