Information Sharing

News & Analysis as of

Preparing for Increased Cybersecurity Information Sharing

Cybersecurity remains a top focus of government regulators, and the prevailing trend is to encourage information sharing between the government and private entities to combat cybersecurity threats. In line with this theme, on...more

A New Cybersecurity Regime and a New Regulation to Mandate Secure Information Systems for Government Contractors

Congress has enacted a recent wave of legislation to address ongoing cybersecurity threats; the Executive Branch, on May 12, 2016, adopted new cybersecurity regulations; and other Federal initiatives are underway and will...more

What Companies Need to Know About Cyber Threat Information Sharing Under CISA

Cyber threat information sharing has the potential to provide numerous benefits for organizations (both public and private) faced with cyberattacks, which are increasing in frequency and sophistication. Cyber threat...more

Information shared by World Bank Group with RCMP protected from disclosure

Corruption crosses borders and anti-corruption efforts require cooperation - On April 29, 2016, the Supreme Court of Canada released its much anticipated decision in World Bank Group v. Wallace. The decision highlights...more

Surviving Settlement Provisions in Joint Defense Agreements

Anyone who watches Survivor or Game of Thrones knows that alliances are critical. And while they may be necessary to endure from one day to the next, alliances are inevitably broken. Co-defendants in antitrust cases...more

Supreme Court Sustains Protections for World Bank Information Sharing

On April 29, 2016, the Supreme Court of Canada ruled unanimously in World Bank Group v. Wallace that documents from World Bank Group investigations remain immune from document production requests that are part of domestic...more

CISA Guidance Clarifies How to Share Cyber Threat Information… but Issues Remain

The Cybersecurity Information Sharing Act of 2015 ("CISA"), enacted on December 18, 2015, as part of the omnibus Consolidated Appropriations Act[1], 2016, creates a voluntary process that encourages public and private sector...more

MTC Arm’s-Length Adjustment Service (Part II): “An Expression of Grief, Pity, or Concern”

Executive Summary - ..Multistate Tax Commission (MTC) transfer pricing program moving forward in some fashion; ..Priority includes information sharing among participating states (and possibly their third party...more

Disclosure of Substance Use Disorder Records Enters the 21st Century: SAMHSA Proposes Changes to Part 2, But Do They Go Far...

Background - As many health care practitioners, health information management professionals, and health lawyers know, balancing patients’ privacy interests with the need to access accurate, up-to-date medical information can...more

To Share or Not to Share (with the Government)? That is the Question: DHS Announces Interim Guidelines for Sharing Cyber Threat...

On February 16, 2016, Secretary of Homeland Security Jeh Johnson announced interim guidelines and procedures for sharing cyber threat indicators under the Cybersecurity Information Sharing Act of 2015 (“CISA”). Because the...more

Privacy Implications of CISA for Financial Institutions

Financial institutions are attractive targets for cyber attacks due to their collection of private customer and economic information. In order to help the private sector respond more effectively to cyber attacks, President...more

HHS Announces Health Care Industry Cybersecurity Task Force

On March 16, 2016, via an online blog announcement, Department of Health & Human Services (“HHS”) Acting Deputy Secretary Mary Wakefield announced the formation of a Health Care Industry Cybersecurity Task Force (“Task...more

CISA Guidelines (Part 3): Guidance to Assist Non-Federal Entities

As we wrote previously, the federal government released several guidance documents last month implementing The Cybersecurity Information Sharing Act (CISA). Among these was the Guidance to Assist Non-Federal Entities to...more

Cybersecurity Information Sharing Act of 2014: What does it allow?

The Cybersecurity Information Sharing Act of 2014 was created to identify and share cyber threat indicators, which are pieces of information necessary to describe or identify “malicious reconnaissance;” a method of defeating...more

Enhanced Sharing of Antitrust Evidence: New EU/Japan Cooperation Agreement

On 15 March 2016, the Japan Fair Trade Commission (JFTC) and the European Commission (Commission) announced their intention to upgrade the current antitrust co-operation agreement between Japan and the European Union. The...more

Our Global Privacy Officer Answers Data Privacy FAQs

Every company in the world stores data—and much of it is personal information about customers, employees, vendors and other stakeholders. Regardless of size, industry or location, these organizations are obligated to follow a...more

Lesson in the history of the Gramm-Leach Bliley privacy protections: Victoria’s Secret started it all

Did you know that a Victoria’s Secret catalog is one of the top reasons that Congress included privacy protections in the Gramm-Leach Bliley Act (GLB Act)? The GLB Act protects consumers’ financial information and requires...more

Class action against Reader’s Digest for selling subscribers’ personal information

Reader’s Digest, owned by Trusted Media, was hit with a class action in New York federal court alleging that the magazine sells its subscribers’ personal information, including names, addresses, and demographic information,...more

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

DHS Publishes CISA Privacy And Civil Liberties Interim Guidelines

On February 16, 2016, the Department of Homeland Security (“DHS”) published four documents related to implementing the Cybersecurity Information Sharing Act of 2015 (“CISA”). CISA, which became law on December 18, 2015,...more

President Obama Signs Cybersecurity Act of 2015 into Law

On December 18, 2015, President Obama signed into law the Federal Cybersecurity Act of 2015 (the Act). The long-awaited and heavily negotiated legislation recognizes the need for greater cybersecurity threat information...more

Dismissal for Sharing Confidential Information Was Unfair

In Stimpson v Citibank N.A. ET/3200437/15, Mr Stimpson brought claims for unfair and wrongful dismissal after being dismissed without notice by Citibank N.A. (Citi) for an alleged breach of Citi’s policies on confidential...more

DHS issues reports to Congress on cybersecurity information sharing: a quick overview for the private sector

The Department of Homeland Security has issued four reports to Congress focusing on information sharing through the DHS portal, also known as the Automated Indicator Sharing (AIS) capability. DHS was required to produce the...more

DOJ/DHS Issue Interim Guidance on Implementation of Cybersecurity Information Sharing Act

The Department of Homeland Security (DHS) and the Department of Justice (DOJ) have released Interim Guidance Documents (Guidance Documents) to implement the Cybersecurity Information Sharing Act of 2015 (CISA). The Act...more

Senate HELP Committee Clears Bipartisan Biomedical Innovation, Health IT Bills

The Senate Health, Education, Labor and Pensions (HELP) Committee has approved several bipartisan health policy bills, including health information technology (HIT) legislation and bills aimed at spurring biomedical...more

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