Data Privacy And Cybersecurity For Investment Funds

Troutman Pepper
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In This Presentation:

- WHY IS DATA PRIVACY AND SECURITY IMPORTANT?

..Why is it important to protect data?

..SEC Cybersecurity Risk Alert

..FINRA Scrutiny

- BEFORE THE BREACH

..What is the definition of a security breach?

..What is Personally Identifiable Information?

..Biggest cyber-security threats

..Before a Breach

..Regulation S-P (17 C.F.R. § 248)

..Regulation S-P

..State Privacy Laws

..Addressing a Breach

- ADDRESSING A BREACH

- AFTER A BREACH

..After a Breach

..Litigation

..FINRA – Regulatory Action

- OCIE CYBERSECURITY INITIATIVE

..SEC Cybersecurity Risk Alert – Sample Requests

- Excerpt from Why is it important to protect data?

“This is a global threat. Cyber threats are of extraordinary and long-term seriousness. They are first on the Division of Intelligence’s list of global threats, even surpassing terrorism. And Jim Comey, director of the FBI, has testified that resources devoted to cyber-based threats are expected `to eclipse’ resources devoted to terrorism.” Chair Mary Jo White - SEC Cybersecurity Roundtable – March 26, 2014.

Please see full publication below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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