Gramm-Leach-Blilely Act Cybersecurity

News & Analysis as of

Alert: New Department of Defense Regulations Mandate the Reporting of Cyber Incidents

The Department of Defense (DoD) has published regulations that require DoD contractors to report cyber incidents impacting unclassified DoD contractor systems. The new regulations mandate compliance with elements of the...more

SEC brings first cybersecurity-related enforcement action

The Securities and Exchange Commission (“SEC”) recently settled its first cybersecurity-related enforcement action against a Missouri based registered investment adviser, R.T. Jones Capital Equities Management, Inc. (the ...more

What's So Great About an Information Security Policy?

Lawyers and compliance professionals constantly tout the importance of internal information security policies, particularly in light of data privacy problems that are reported almost daily in the media. Admittedly, drafting...more

How to Avoid and Respond to a Cybersecurity Breach

In light of numerous recent data breaches, cybersecurity has emerged as an issue impacting organizations ranging from the local hardware store to the largest multi-national firms in the world. In short, no industry is immune...more

FTC Can Regulate Cybersecurity Practices, Third Circuit Rules

The Federal Trade Commission (FTC) can regulate cybersecurity policies and procedures as “unfair” acts or practices under Section 5 of the FTC Act, the U.S. Court of Appeals for the Third Circuit has ruled in a very important...more

Special Alert: Third Circuit Gives FTC Green Light to Continue Enforcing Corporate Data Security

Last week, the U.S. Court of Appeals for the Third Circuit affirmed the Federal Trade Commission’s authority to hold companies accountable for their data security practices under Section 5 of the FTC Act (15 U.S.C. § 45(a)),...more

Under the Thumb: Regulatory Compliance When Outsourcing Cybersecurity Management

Managed security services are often a natural “add-on” when outsourcing IT services given that data protection is integral to application development, software as a service, and cloud storage, among other services. More...more

New Potential Liability for Data Security: U.S. Court of Appeals for the Third Circuit Announces FTC has Authority to Scrutinize a...

The U.S. Court of Appeals for the Third Circuit announced that the Federal Trade Commission (FTC) has the authority to scrutinize a business’s data security protocol -- and to file a complaint if the FTC finds that protocol...more

Assessing Your Cybersecurity Preparedness: It May Be Time to Update Your Bank’s Information Security Plan and Response Program

With increased oversight, regulatory scrutiny and risk related to cybersecurity, now is the time for those in the banking industry to be proactive in managing cybersecurity risk. Waiting until a breach occurs to formulate or...more

The FTC, Privacy, and the Life & Health Business

The Federal Trade Commission Act (“FTC Act”) prohibits unfair or deceptive acts or practices affecting commerce, as well as unfair competition in commerce. The FTC Act also created the Federal Trade Commission (“FTC”), and...more

Data Privacy and Security Considerations in M&A Transactions

By some estimates, cybercrime costs the global economy $445 billion annually. If cybercrime were a single country, this dollar amount would place it within the world’s top 30 countries in terms of gross domestic product, and...more

Privacy Bills Abound in Congress

Why it matters - From the President to Senators to Representatives, everyone in Washington, D.C. appears to be focused on privacy-related issues. Continuing his focus on cybersecurity, President Barack Obama signed an...more

President Obama Unveils Plans About Cybersecurity

Written by Sydney White President Obama made a series of announcements on cybersecurity, data security, and privacy that will be incorporated into his State of the Union address tonight.  In conjunction with the...more

Interconnectivity And Information Sharing: Cause As Well As Cure for Cyber Attacks?

The modern day interconnected business creates a number of opportunities, but also brings with it massive issues relating to breach of privacy and data security in the form of cyber attacks, which cost companies and taxpayers...more

Privacy & Cybersecurity Update - October 2014

In This Issue: - October: National Cyber Security Awareness Month - New California Data Protection Law - Obama Signs Cybersecurity Executive Order - FTC Cautions Executives About Personal Liability for False...more

Credit Unions Continue to Demand New Data Security Standards for Retailers and Right to Recover Losses After a Breach

On September 3, 2014, following the news of a possible breach at Home Depot (which was confirmed on September 8), the National Association of Federal Credit Unions (NAFCU) called on Congress to enact new legislation to hold...more

Privacy Tuesday – August 2014

We are just two Mondays away from Labor Day, the traditional end of summer in the United States. Here are some privacy tidbits to get your week started. See especially Jake Romero’s piece on the new Delaware data...more

Tips For Navigating U.S. and International Data Breaches

Navigating today’s complex legal and regulatory framework surrounding data breaches can be a daunting process for even the most sophisticated organization. In the United States, there is not currently a national uniform data...more

Risk of Data Breaches Keeping You Up? Assess Data Security Before The Holiday Season

Data security breaches marred the 2013 holiday season for many consumers and retailers. The most famous security breach, at Target Corporation (Target), involved the loss of information on 40 million payment cards and...more

Cybersecurity Is Not Just an IT Issue; It’s an IG Issue

For leaders and counsel in many organizations, the word “cybersecurity” typically triggers concerns about the IT department, conjuring images of hackers and requiring unfamiliar terminology such as “firewalls” and...more

Social Media: Consumer Compliance Risk Management Guidance

On December 11, 2013, the Federal Financial Institutions Examination Council (FFIEC) released final guidance (“Guidance”) on the applicability of consumer protection and compliance laws, regulations, and policies to...more

Enterprise Data Security For The Securities Lawyer

Assuring cybersecurity has become a necessity for businesses across all industries. Cybercrime — with over $1 trillion in annual profits — is now the most lucrative illegal global business. Any business with computers and...more

Outsourcing to the Cloud

As many companies turn to cloud computing as a means of increasing accessibility and saving costs, you should consider a variety of risks which require thoughtful planning before moving your data to “the cloud.” Outsourcing...more

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