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NIST prepares for Cybersecurity Framework 2.0, with increased focus on governance and supply chain

The US government continues to refine its influential cybersecurity guidance, the National Institute of Standards and Technology (NIST) Cybersecurity Framework (CSF), with a substantial update to the CSF expected later this...more

HHS OCR creates new HIPAA enforcement arm and enhances focus on cybersecurity and privacy oversight

This week the U.S. Department of Health and Human Services, the agency responsible for HIPAA enforcement, announced the formation of three new divisions within the Office for Civil Rights (“OCR”). The new divisions –...more

Aerospace and Defense Insights I Critical input needed: U.S. critical infrastructure asked to engage on proposed cyber reporting...

Through Aerospace & Defense Insights, we share with you the top legal and political issues affecting the aerospace and defense (A&D) industry. Our A&D industry team monitors the latest developments to help our clients stay in...more

Rail industry receives new cybersecurity performance-based security requirements from TSA

On October 18, 2022, the United States Transportation Security Administration (TSA) released a new Security Directive applicable to the rail industry that will require certain owners and operators to implement new,...more

Critical input needed: US critical infrastructure asked to engage on proposed cyber reporting rules

The Cybersecurity and Infrastructure Security Agency (CISA) has issued a Request for Information (RFI) and announced “public listening sessions” soliciting input in advance of formal rulemaking under the Cyber Incident...more

FTC emphasizes expectations around the health breach notification rule

The Federal Trade Commission (FTC) recently has signaled its intent to inject new life into a longstanding but rarely triggered rule governing health breach notifications for non-HIPAA-covered health records. Specifically,...more

Staying Ahead of the Hack: New Cybersecurity Requirements on the Horizon for Trains and Planes

Imagine a country paralyzed by the inability — even for just one day — to move people or goods by rail or by plane. This is not science fiction. This is the reality of the potential cybersecurity threats that could impact the...more

Hold the punitive damages: Connecticut is latest to incentivize implementing cybersecurity frameworks

Connecticut’s new cybersecurity standards law, which goes into effect on October 1, 2021, protects companies from punitive damages in certain data breach actions where an organization has a cybersecurity program that conforms...more

Fifth Circuit Vacates $4.3M Penalty Against MD Anderson Related to Data Losses - Challenge to Civil Money Penalties Imposed by HHS...

There has been a significant development in the ongoing debate regarding the scope of the authority of the Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) to issue penalties under the Health...more

New York Enacts New Data Security Laws

On July 25, New York Governor Andrew Cuomo signed into law a pair of bills establishing new requirements for businesses that process certain personal information related to New York residents. The changes include expanding...more

FTC Seeks Comment on Proposed Changes to GLBA Implementing Rules

The Federal Trade Commission (“FTC”) issued notices on March 5 seeking public comment on proposed amendments to the regulations implementing the Gramm-Leach-Bliley Act (“GLBA”), commonly known as the Safeguards Rule and...more

California Consumer Privacy Act: The Challenge Ahead – The CCPA’s “Reasonable” Security Requirement

This is the eleventh installment in Hogan Lovells’ series on the California Consumer Privacy Act. Much of the focus on the California Consumer Protection Act (“CCPA”) has been on the new rights that it affords California...more

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