The New York Department of Financial Services (NYDFS) has launched its first enforcement action under New York’s Cybersecurity law for financial services, so-called Part 500. Part 500 requires NYDFS licensed institutions to...more
9/23/2020
/ Banking Sector ,
Chief Information Security Officer (CISO) ,
Cybersecurity ,
Cybersecurity Framework ,
Data Protection ,
Financial Institutions ,
Financial Services Industry ,
Information Technology ,
Insurance Industry ,
NYDFS ,
Personally Identifiable Information ,
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Risk Assessment ,
Risk Management
We enjoy Jerry Bruckheimer movies. Living in one is another matter. COVID-19 has generated scenes that give us pause. An empty Times Square. A Los Angeles with moving traffic. A Washington eerie in its silence. Closed stores....more
As Congress continues to wrestle with federal privacy legislation, the states have been lining up alternative proposals. North Carolina has introduced its own bipartisan bill. The bill, H.B 904, will not pass this year. Even...more
HIPAA was enacted in 1996. In the years since, most healthcare entities have adapted to the major requirements imposed by HIPAA, HITECH, and the Privacy and Security Rules. Nevertheless, the thicket of regulations still...more
Data privacy regulation tends to take one of two general approaches. In most of the world—but not in the United States—the approach is usually characterized as “omnibus.” Under an omnibus regime, privacy rights are defined at...more
As data breaches go, they don’t get much bigger than this. On Thursday, September 7, credit reporting giant, Equifax, reported that it had suffered a cyber-incident. 143 million consumer records, including names, birth dates,...more
As we have previously noted, a recent ransomware attack crippled over 75,000 computers in over 100 countries. The “WannaCry” appears to be the largest Ransomware attack to date. However, cyber-experts are already warning of a...more
In my software consulting years, it was remarkably routine for clients to concede that they had never read their own procedures and documents. While it lent itself to amusing anecdotes like the database administrator who...more