Cynthia Larose

Cynthia Larose

Mintz Levin

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Innocents Abroad: Privacy considerations for employees working abroad

Dear Ned, I understand that one of your employees will be engaging a six-month temporary assignment around Europe to scope market opportunities, and you’d like to have a better understanding of what to be thinking about...more

5/18/2016 - Data Protection EEA Employee Privacy Rights Employer Liability Issues International Data Transfers International Labor Laws Privacy Concerns Surveillance Traveling Employee

PCI DSS 3.2: It’s here, what does it mean for you?

The Payment Card Industry Security Standards Council (PCI SSC) has released a new version of its data security standard for the protection of cardholder data, the Payment Card Industry Data Security Standard (PCI DSS). PCI...more

5/9/2016 - Cyber Attacks Cybersecurity Data Security Debit and Credit Card Transactions Fraudulent Charges PCI-DSS Standard SSL

Breach Response Portal Added by Massachusetts Regulator

If you have had to provide data breach notices across any number of states (and who hasn’t….), you would know that they vary widely in how those notices must be provided to state regulators. In some states (for example,...more

4/28/2016 - Breach Notification Rule Data Breach Incident Response Plans Office of Consumer Affairs Portal State Data Breach Notification Statutes

FCC Broadband Privacy and Security Proposed Rulemaking Underway

As we reported last month, the FCC was preparing a proposed rulemaking (NPRM) to establish privacy and data security requirements for broadband internet access service (BIAS) providers. The FCC has now released that proposal...more

4/13/2016 - Customer Proprietary Network Information (CPNI) FCC Net Neutrality NPRM Open Internet Rules

It’s A Wrap! Sony Pictures Data Breach Case Settles Without A Hollywood Ending For The Plaintiff Class

Everyone loves a good courtroom drama. So just imagine this pitch: henchmen of an evil dictator hack their way into a movie studio computer system. Once inside, they steal the most sensitive personal information of the...more

4/11/2016 - Class Action Data Breach Personally Identifiable Information Settlement Agreements Sony

State Data Security Breach Notification Laws - April 2016

The general definition of “personal information” used in the majority of statutes is: An individual’s first name or first initial and last name plus one or more of the following data elements: (i) Social Security number, (ii)...more

4/4/2016 - Breach Notification Rule Corporate Counsel Cybersecurity Data Breach Data Security Personally Identifiable Information Popular Young Lawyers

Pay Attention to Business Associate Agreements!

For our HIPAA-covered entity readers, we have asked these questions before: Have you taken a business associate inventory? Have you undertaken a comprehensive risk assessment as required by HIPAA?...more

3/24/2016 - Business Associates Corrective Actions Covered Entities HIPAA HIPAA Audits HIPAA Breach OCR Risk Assessment Settlement

Beware of the CEO Email Request Phishing Scam: A Different Form of March Madness

Not only is it “March Madness” time, it is also prime tax return filing time. That means that the email scammers are out in full force as well. In the last 10 days, we have seen a marked uptick in what are called...more

3/17/2016 - CEOs Data Breach Email Human Resources Professionals Identity Theft Payroll Records Phishing Scams Popular Tax Scams

Apple vs. FBI: The House Judiciary Committee Hearing and Takeaways

Among the major headlines dominating not only the recent news cycle, but also this week’s RSA Conference in San Francisco, has been Apple’s challenge to the federal government’s request that Apple assist in unlocking the...more

3/3/2016 - All Writs Act Apple CALEA Corporate Counsel Criminal Investigations Encryption FBI iPhone Personal Data Right to Privacy Search Warrant Young Lawyers

CISA Guidelines: Privacy and Civil Liberties Interim Guidelines for Federal Agencies

Last week, we discussed the Federal government’s first steps toward implementing the Cybersecurity Information Sharing Act (CISA). Among the guidance documents released by the Department of Homeland Security and the...more

3/2/2016 - Cybersecurity Cybersecurity Information Sharing Act (CISA) Fair Information Practice Principles (FIPPs) Information Sharing Transparency

California by the Numbers (Part 1): 24 Million Compromised in 2015

California Attorney General Kamala Harris has released a report of the data breaches that have been reported to her office from 2012 until 2015. Although the California data breach notification law took effect in 2003,...more

2/27/2016 - Attorney Generals Cybersecurity Data Breach Data Protection Hackers Kamala Harris Malware Social Security Numbers

California by the Numbers (Part 2): How to Stay out of the 2017 Report

Receently, we reviewed the staggering numbers in California Attorney General Kamala Harris’ 2016 Data Breach Report. In addition to providing a comprehensive analysis of four years of data breaches, the report provides...more

2/26/2016 - Annual Reports Attorney Generals Cybersecurity Data Breach Data Protection Kamala Harris

Ransomware Strikes California Hospital – Could You Be Next?

In a chain of events that should be a wake-up call to any entity using and storing critical health information (and indeed, ANY kind of critical information), Hollywood Presbyterian Medical Center (“HPMC”) has announced that...more

2/23/2016 - Electronic Medical Records FBI Hackers HIPAA Hospitals Popular Ransomware

Cyber Threat Information Sharing Guidelines Released by DHS

This week, the Federal government took the first steps toward implementation of the The Cybersecurity Information Sharing Act (CISA), enacted into law last December. CISA aims to encourage sharing of cyber threat indicators...more

2/18/2016 - Cyber Threats Cybersecurity Information Sharing Act (CISA) DHS DOJ Federal Register Government Agencies New Guidance Personally Identifiable Information Private Sector

Political Agreement Reached on US-EU Safe Harbor; Details “Hazy”

According to press reports, European Union and U.S. negotiators in Brussels finalized what is being called a “political agreement” on a new Safe Harbor transatlantic data transfer agreement. European Union justice...more

2/3/2016 - EU EU Data Protection Laws EU-US Privacy Shield European Commission European Court of Justice (ECJ) International Data Transfers US-EU Safe Harbor Framework

Cybersecurity Tops SEC Office of Compliance Inspections 2016 Examination Priorities

The 2016 lists are starting to be released by regulatory agencies in the United States, giving a heads’ up to covered entities as to what compliance issues will take front and center this year. Once again, the Office of...more

1/13/2016 - Broker-Dealer Cybersecurity Investment Adviser OCIE SEC SEC Examination Priorities

The Problem With Data Security is not the Hardware or the Software, It’s the Wetware

Remember this? - “Wetware” – coder slang for biological life forms (i.e., people) – is the weak link in most companies’ data security protections, according to a new data security report issued by the Association of...more

1/13/2016 - Cybersecurity Data Breach Data Security Employee Training Popular

Happy New Year – Cybersecurity Information Sharing Act

Just at the end of 2015, the Cybersecurity Information Sharing Act (CISA) was enacted into law as part of the omnibus spending measure passed by Congress and signed by President Obama at right before Christmas. The...more

1/5/2016 - CISA Cybersecurity DHS ECPA Information Sharing Private Sector Repeal

Wyndham and FTC Settle Case Over “Unfair” Data Security Practices

The years-long saga of the Federal Trade Commission’s suit against Wyndham Hotels over data breaches that occurred at least as early as April 2008 is finally coming to an end with a proposed settlement filed today with the...more

12/11/2015 - Data Breach Data Security FTC FTC v Wyndham Settlement Unfair or Deceptive Trade Practices Wyndham

Happy Holidays: VTech data breach affects over 11 million parents and children worldwide

The recent data breach of Hong Kong-based electronic toy manufacturer VTech Holdings Limited (“VTech” or the “Company”) is making headlines around the world for good reason: it exposed sensitive personal information of over...more

12/8/2015 - Attorney Generals COPPA Cyber Attacks Data Breach FTC Hackers Hong Kong Popular

Privacy Tuesday - November 2015: EU/Safe Harbor Updates

And the days dwindle down, to a precious few … November … We are still following developments in the EU relating to the invalidation of the US-EU Safe Harbor Framework. ...more

11/10/2015 - Data Protection Authority EU European Commission International Data Transfers Personal Data Standard Contractual Clauses US-EU Safe Harbor Framework

Data Breach Planning in 10 Easy Steps: How to Think Like A Litigator

For the first Tuesday in November, we have 10 easy steps to make sure that your data breach incident response planning is viewed from that pesky point of view of a litigator....more

11/3/2015 - Cyber Incident Reporting Cybersecurity Data Breach Data Breach Plans Data Privacy Data Protection Data Security Email Policies Personally Identifiable Information Popular Tone At The Top Training

5 Popular Cybersecurity Writers to Follow Right Now

For your convenience, a short list of JD Supra writers covering the myriad issues raised surrounding Cybersecurity, date privacy and protection, and related matters. ...more

10/23/2015 - Corporate Counsel Cybersecurity Data Breach Data Protection Popular

More Dominos Fall on the Data Protection Table

As all of our readers know by now, as of October 6, the US-EU Safe Harbor Framework is no more. Safe Harbor was the mechanism on which thousands of US companies (and thousands of companies based in the European Union)...more

10/22/2015 - Data Privacy Data Protection Data Protection Authority Data Security EU EU Data Protection Laws European Court of Justice (ECJ) International Data Transfers Israel Model Contracts Personal Data SCC Schrems v Data Protection Commissioner Switzerland US-EU Safe Harbor Framework

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