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Entity Fined $650,000 in First HIPAA Settlement with a Business Associate

The possibility of business associates potentially being audited, investigated, and ultimately fined is now a reality. On June 24, 2016, the United States Department of Health and Human Services’ Office of Civil Rights...more

Privacy Shield is Finally Official

The EU Commission has formally adopted Privacy Shield and the US Department of Commerce will go live with a new Privacy Shield registration website on August 1. US companies that had been registered under Safe Harbor will...more

EU-US Privacy Shield approved

The EU-US Privacy Shield has now been formally approved, providing a new mechanism for transferring personal data from the EU to the US, and reducing the legal uncertainty international businesses have been facing – at least...more

Privacy Shield Passes Art. 31 Hurdle; European Parliament LIBE Committee Advisory Vote July 11, 2016

The final version of Privacy Shield (which has not yet been officially published) passed the Article 31 Committee vote on July 8th and is being presented on July 11th to the LIBE committee of the European Parliament. LIBE’s...more

Cybersecurity News & Notes – July 2016 #2

In Case You Missed It: The EU/US Privacy Shield is set to go into effect this Tuesday, July 13, pending a decision today by the EU’s College of Commissioners. On Friday, July 8, the Privacy Shield agreement (entered into in...more

“Privacy Shield” Framework for Transatlantic Data Transfers Poised to Move Forward

After months of back and forth, an updated version of the EU-US Privacy Shield agreement originally announced in February is on the verge of being formally adopted on Tuesday, July 12, 2016. While the final documents...more

Business Associate Settles HIPAA Investigation for $650,000

The U.S. Office for Civil Rights (OCR), the agency responsible for enforcing the HIPAA Privacy and Security rules, has just sent a strong message that business associates are not immune from scrutiny. On June 24, 2016, in a...more

What Brexit Means for Data Protection

For global pharmaceutical and medical device companies handling personal data in the European Union (EU) or engaged in transatlantic data transfers, some of the many questions created by the Brexit vote include what its...more

Does Your Organization Collect Geo-Location Information?

Smartphones, smartphone apps, websites, and other connected devices (e.g., “wearables”) increasingly request that consumers provide their geo-location information. Geo-location information can refer to general information...more

Privacy Shield: Rumors of Progress

According to several news reports, the Commission has sent a revised draft of the Privacy Shield adequacy decision to the Article 31 Committee. One tech industry news source, Ars Technica, has made available a purportedly...more

HIPAA Compliance: Navigating a Health Care Minefield

In the two decades since its original passage, complying with the federal Health Insurance Portability and Accountability Act (HIPAA) hasn’t gotten any easier. Enacted with the primary goal of protecting the confidentiality,...more

Best Practices For Implementing Internal Security Controls

Many security risks can be avoided or mitigated by implementing sufficient internal security controls which are tailored to the organization’s size, needs, and specific industry. The Federal Trade Commission (“FTC”) sets...more

Data Protection in a Post-Brexit Landscape

The United Kingdom’s vote to leave the European Union coincides with a seismic change in data protection law. Once Article 50 of the Lisbon Treaty is invoked, there will be a period of two years to complete negotiations and...more

BREXIT – What does this mean for UK Data Protection law?

As the whole world now knows, the UK voted to leave the European Union (EU) in its historic referendum on 23rd June by a vote of 51.9 percent in favour of “leave” to 48.1 in favour of “remain”. This blog focusses on how that...more

New Agreement on Privacy Shield Set to Become Final in Early July

On June 24, 2016, the European Commission announced that it had reached a final agreement with the United States on the terms of the EU-U.S. Privacy Shield, which will permit U.S. companies to transfer the personal data of...more

NTIA Multistakeholder Process Finalizes General Privacy Guidelines for Commercial Facial Recognition Use

We’ve previously blogged about the National Telecommunications and Information Administration (NTIA) privacy multistakeholder process to address concerns associated with the emerging commercial use of facial recognition...more

New Data Protection Obligations In Europe: Data Protection Officers and Impact Assessment under the New General Data Protection...

The full text of the General Data Protection Regulation (GDPR) was published on 4 May 2016. Although the GDPR will not be effective until 25 May 2018, it is worth looking into it right now given the major changes it makes to...more

Latest FTC Privacy Action Looks Carefully at Geolocation Promises

A mobile device’s geolocation can be passed to apps and ad networks through various application programming interfaces (APIs) provided by Android or iOS, but there are other ways to determine a consumer’s location using...more

DHS and DOJ Release Updated Guidance for Sharing Cyber Threat Indicators and Defensive Measures

On June 15, in response to feedback from non-federal entities on guidance released in February, the Departments of Homeland Security (DHS) and Justice (DOJ) issued updated guidance for companies about sharing cyber threat...more

Your Organization is Impacted by Ransomware - Now What?

Some forms of cyber extortion are automated and not targeted at any specific victim. For example, “ransomware” refers to a type of malware that prevents users from accessing their systems unless, and until, a ransom is paid....more

How to Comply with the Children’s Online Privacy Protection Act (COPPA)

There are relatively few restrictions on collecting information from children offline. Efforts to collect information from children over the internet, however, are regulated by the Children’s Online Privacy Protection Act...more

EU Privacy Shield Status Update

While it’s making few headlines, the European Commission is still working to finalize Privacy Shield, and it’s even possible that Privacy Shield will pass a key hurdle by the end of this month. The Commission is still...more

They Will Click: Cybersecurity and the Human Factor

Cybercrime cost the world economy about $445 billion in 2014 and the 2015 numbers will be even higher. The cost of data breaches will reach $2.1 trillion globally by 2019. Worldwide spending on information security is...more

Cybersecurity News & Notes – June 2016 #3

In Case You Missed It: Illinois strengthened its data privacy and security law, with the amendments going into effect in January 2017. The amendments include expanding the definition of “personal information” to include a...more

EU-US Data Transfers?: An update on actions taken by European DPAs

After the European Court of Justice invalidated Safe Harbor on October 6, ?2015, the Article 29 Working Party announced in an October 16, 2015 statement that US companies that were Safe Harbor certified had until the end of...more

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