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Covered Entities Third-Party Service Provider

BakerHostetler

Change Healthcare Incident: Update on ‘Impacted Data’ Analysis and Notification Plan

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Late on March 27, Change Healthcare (CHC)’s parent company, UnitedHealth Group (UHG), provided an update on its analysis of the extent of “impacted data” involved in the CHC incident....more

Holland & Knight LLP

Lawsuit Seeks to Block OCR HIPAA Guidance on Online Tracking Tools

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Hospitals care about patient privacy, but they also have to connect with the public. In the real world, people mostly connect online. Having a fully functional online presence often requires help from third parties. ...more

Holland & Knight LLP

Changing of the Guard? SEC Proposes Significant Amendments to the Safeguards Rule

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The SEC continued its recent onslaught of proposed cybersecurity rules in mid-March with three new proposals covering a litany of entities, including investment advisers, broker-dealers, investment companies, clearing...more

Sullivan & Worcester

SEC’s Proposed Changes to Regulation S-P Would Overhaul Records and Information Requirements of Covered Institutions

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On March 15, 2023, the United States Securities and Exchange Commission (“SEC”) proposed amendments to Regulation S-P that, if finalized, would place additional burdens on covered institutions when it comes to handling...more

Dorsey & Whitney LLP

Tracking Online User Activity: HIPAA and Other Legal Risks

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The use of tracking technologies on websites and mobile applications (e.g., cookies) has become largely ubiquitous in our technology-driven world. Health care providers and organizations, for example, may use tracking...more

Faegre Drinker Biddle & Reath LLP

NYDFS Releases Pre-Proposed Second Amendment to its Cybersecurity Regulations, 23 NYCRR 500

On July 29, 2022, the New York Department of Financial Services (NYDFS) published the pre-proposed second amendment to its Cybersecurity Regulations, 23 NYCRR 500 (Part 500), that if adopted, would likely require numerous...more

Hinshaw & Culbertson - Consumer Crossroads

Another Cybersecurity Wake Up Call: Connecticut Insurance Department Issues Guidance on Cyber Law Set to go Into Effect

Covered entities received two cybersecurity wake up calls from insurance regulators this month. As we have reported, the New York State Department of Financial Services (DFS) issued its long-awaited first cyber enforcement...more

Epstein Becker & Green

HHS Addresses Federal Court Invalidation of Certain Provisions of the HIPAA rule Relating to the Third-Party Requests for Patient...

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On January 28, 2020, the Department of Health & Human Services (“HHS”) Office for Civil Rights (“OCR”) addressed a federal court’s January 23rd invalidation of certain provisions of the Health Insurance Portability and...more

Locke Lord LLP

Third Party Service Provider Cybersecurity Management: The (Not Quite) Last Requirement of the New York Department of Financial...

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In prior issues, we have reported on the various requirements imposed by the New York Department of Financial Services (the DFS) Cybersecurity Regulation (23 NYCRR 500) (the Regulation) on “Covered Entities,” which are...more

Pillsbury - Global Sourcing Practice

The Deadline Looms for New York Cybersecurity Regulations Vendor Compliance Requirements

Financial institutions regulated by the New York Department of Financial Services (DFS)—referred to in this post as “Covered Entities”—should by now be well familiar with the department’s sweeping cybersecurity regulation, 23...more

Bradley Arant Boult Cummings LLP

New Year, New Data Security Requirement: South Carolina Adopts New Data Security Law

On January 1st, South Carolina became the first state to adopt the model insurance data security law requiring certain insurance licensees to investigate and report cybersecurity events in the state of South Carolina. The law...more

Sheppard Mullin Richter & Hampton LLP

Company’s Vendor Suffers Breach, No Business Associate Agreement, $500K OCR Settlement

A Florida staffing agency which provides physicians to hospitals and nursing homes, has agreed to a $500,000 settlement with the U.S. Department of Health and Human Services, Office for Civil Rights. The settlement comes...more

Proskauer on Privacy

New York DFS Cybersecurity September 2018 Deadline

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The New York Department of Financial Services cybersecurity regulation 23 NYCRR 500 (the “Regulation”) came into effect in March 2017 and established four staggered compliance deadlines for its various requirements. By the...more

Stinson LLP

Colorado Enacts New Privacy and Cybersecurity Legislation

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On May 29, 2018, Colorado passed House Bill 18-1128, which requires "covered entities" to comply with new rules regarding the security and disposal of "personal identifying information" (PII). The new law also provides an...more

Ballard Spahr LLP

Colorado Enacts Groundbreaking Privacy and Cybersecurity Legislation

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Colorado has enacted groundbreaking privacy and cybersecurity legislation that will require covered entities to implement and maintain reasonable security procedures, dispose of documents containing confidential information...more

Fisher Phillips

New York's Far-Reaching Cybersecurity Law Takes Effect March 1 - Are You Ready?

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New York’s Department of Financial Services Cybersecurity regulation became effective March 1. According to the press release issued with the regulation, the regulation is intended to require banks, insurance companies and...more

Pillsbury - Global Sourcing Practice

Sweeping New York Cyber Regulations Hit Financial Institutions March 1: Time to Look at Those Vendor Relationships

Effective March 1, 2017, first-in-kind regulations issued by the New York Department of Financial Services (New York DFS) will begin to affect a wide array of both depository and non-depository financial institutions. The new...more

Orrick - Finance 20/20

New York Department of Financial Services Promulgates First-in-the-Nation State Cybersecurity Regulation

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On February 16, 2017, the New York Department of Financial Institutions (“DFS“) promulgated a regulation that requires “Covered Entities” to establish and maintain a cybersecurity program designed to protect consumers and the...more

Sheppard Mullin Richter & Hampton LLP

New York State Department of Financial Services Cybersecurity Regulation Poised to Reshape Existing Regulatory Landscape

In late December, New York State’s Department of Financial Services (“DFS”) released its revised proposed cybersecurity regulation (the “DFS Rule”). While the revisions pare back some of the DFS Rule’s original requirements...more

Cadwalader, Wickersham & Taft LLP

New York State Revises “First-In-Nation” Cybersecurity Rules

The New York Department of Financial Services (“DFS”) recently issued a revised version of the cybersecurity rules that it first announced in the fall of last year. The rules apply to a wide range of insurance, banking, and...more

Bond Schoeneck & King PLLC

Cybersecurity and Data Privacy: Proposed New York State Regulations Updated, Implementation Delayed (1/17)

On September 16, 2016 we informed you of new proposed cybersecurity regulations that would cover all entities regulated by the New York State Department of Financial Services (DFS). On December 28, 2016, DFS released...more

Kramer Levin Naftalis & Frankel LLP

New York State Department of Financial Services Modifies Proposed Cybersecurity Regulations and Pushes Implementation Date Back to...

On Dec. 28, 2016, the New York State Department of Financial Services (NYDFS) published a revised version of its “Cybersecurity Requirements for Financial Services Companies” (the “Regulations”). The revised Regulations...more

Proskauer on Privacy

New York Department of Financial Services Revises Cybersecurity Proposal: Greater Flexibility and Delayed Compliance Deadlines

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As we previously reported, in December 2016 the New York Department of Financial Services (the “DFS”) announced that it was revising its proposed regulation that would require banks, insurance companies and other financial...more

BakerHostetler

New York Department of Financial Services Issues Revised Cybersecurity Regulations

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With the clock ticking down to the new year, on December 28, 2016, the New York State Department of Financial Services (NYDFS) released highly anticipated revisions to its proposed Cybersecurity Requirements for Financial...more

Proskauer on Privacy

Financial Industry Groups Criticize New York Department of Financial Services Cybersecurity Proposal

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As we previously reported, in September 2016 the New York Department of Financial Services (the “DFS”) proposed a regulation that would require banks, insurance companies and other financial services institutions regulated by...more

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