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HHS Publishes ‘Voluntary’ Healthcare Cybersecurity Performance Goals in Record Time but Leaves Questions Unanswered

As previously reported in this blog, on Dec. 6, 2023, the Department of Health and Human Services (HHS or the Department) released a “concept paper,” which laid out its vision of future action regarding healthcare...more

OCR releases YouTube Addressing “Recognized Security Practices” in HIPAA Enforcement Context

As a Halloween treat for HIPAA-covered entities and business associates, on October 31, the Department of Health and Human Services Office for Civil Rights (OCR) released a new video on its YouTube channel, in which senior...more

Federal Banking Regulators Issue 36-Hour Computer-Security Incident Notification Requirement

As the federal government continues its whole-of-government response to cyber incidents, federal banking regulators took action to impose a new notice requirement on federally regulated banks. In November, the Federal Deposit...more

SEC Cybersecurity Actions Against Registered Firms for Business Email Compromises Emphasize Importance of MFA

On August 30, 2021, the Securities and Exchange Commission (“SEC”) announced three settled orders against several investment advisers, broker-dealers, and dual registrants for violations of Regulation S-P allegedly resulting...more

Pairing Real-World™ Problems with Realistic Solutions – a Push for Practical Information Governance

For those attorneys and information governance practitioners unfamiliar with recent pedagogic advancements, “real-world problem solving” moves teaching approaches away from the classical model that assumes individuals will...more

A Risk-Based Approach to the SolarWinds Vulnerability Disclosures

On December 13, 2020, SolarWinds disclosed that an unknown attacker compromised its network and inserted malicious code (referred to as the Sunburst vulnerability) into software updates for the Orion platform. In what will...more

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