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Delaware and New Hampshire Join Growing List of States With New Insurance Data Security Laws

Delaware (July 31, 2019) and New Hampshire (August 2, 2019) have become the latest states to add to the insurance cybersecurity landscape by enacting information security laws.  These laws come on the heels of Connecticut’s...more

Connecticut Becomes Latest State to Enact Insurance Data Security Law

On July 26, 2019, Connecticut Governor Ned Lamont signed into the law the state’s new Insurance Data Security Law, which imposes new information security, risk management, and reporting requirements for carriers, producers,...more

FTC Seeks Comment on Proposed Amendments to Safeguards and Privacy Rules

The FTC has proposed amendments to its 2003 Safeguards Rule and the 2000 Privacy Rule, applicable to financial institutions under the Gramm Leach Bliley Act (GLBA). ...more

PA Supreme Court: Businesses Have Duty to Safeguard Sensitive Employee Information

The Pennsylvania Supreme Court has drastically changed the data breach litigation landscape by holding that an employer has a common law duty to use reasonable care to safeguard its employees' personal information stored on...more

Mandatory Data Breach Notification in Canada: Understanding Your New Obligations

On April 18, 2018, the Government of Canada published the final regulations relating to mandatory reporting of privacy breaches under Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”). ...more

What Does “Reasonable” Data Security Mean, Exactly?

One of the most bedeviling aspects of data privacy and security law concerns the concept of “reasonable” data security, which has become the default statutory and common law standard.  The FTC began articulating a...more

Fiat-Chrysler Ruling May Pave the Way for Overpayment Class Actions Based on Security Flaws

We’ve previously blogged about the creative efforts of plaintiffs’ counsel to expand the contours of data breach litigation. ...more

Uber Settles FTC Dispute Over Consumer Data Privacy and Security Allegations

There are several key takeaways from a 20-year proposed consent order agreed to by Uber Technologies, Inc. (Uber) and the Federal Trade Commission (FTC)...more

Ponemon Institute Study on Costs of Data Breaches Highlights Improvement and New Risks for U.S. and Global Companies

The average cost of a data breach, on both an aggregate and a per-record basis, has decreased slightly according to the Ponemon Institute's 2017 Cost of Data Breach Study: Global Overview. In addition to presenting recent...more

FTC Submits Comment To Aid NTIA In Developing Internet of Things Guidance

In its latest effort to address security concerns about Internet of Things (IoT) devices, the Federal Trade Commission (FTC) has submitted public comments to the National Telecommunications and Information Administration's...more

Affair Website Ashley Madison Fined $8.75 Million Over Data Breach, Misrepresentations

The Federal Trade Commission (FTC) has entered into a multimillion dollar settlement with the owners and operators of AshleyMadison.com, a dating website for people interested in having discreet affairs, related to the...more

HHS Designates Cloud Service Providers as Business Associates Under HIPAA

Cloud service providers that process electronic protected health information (ePHI) are business associates under the Health Insurance Portability and Accountability Act of 1996 (HIPAA), even if the PHI is encrypted and the...more

Lessons for Businesses from FTC’s Opinion on LabMD’s Data Security Practices

The Federal Trade Commission (FTC) has issued an Opinion and Final Order finding that the data security practices of LabMD, Inc. were unreasonable, and therefore constituted an unfair act or practice in violation of Section 5...more

Ninth Circuit Vastly Expands Scope of Criminal, Civil Liability for Computer Fraud

In a pair of highly anticipated decisions, the Ninth Circuit significantly reshaped criminal and civil liability under the federal Computer Fraud and Abuse Act (CFAA). The court’s recent decisions in United States v. Nosal...more

Class Certification Improper in Data Breach Case, PA Appellate Court Finds

The Pennsylvania Superior Court has affirmed a trial court's decision denying class certification in a data breach case against two health plans, reversing its own earlier ruling in the same case that the plaintiff did not...more

CFPB Initiates Its First Data Security Enforcement Action

The Consumer Financial Protection Bureau (CFPB) has announced its first data security enforcement action. Since the 1990s, the Federal Trade Commission (FTC) has primarily taken on the role as the de facto federal regulator...more

California Data Breach Report Defines “Reasonableness” Standard for Data Protection

Nearly three in five Californians were victims of a data breach in 2015, according to a report released by state Attorney General Kamala D. Harris. The report adopts minimum standards of ''reasonable security'' for personal...more

European Court of Justice May Invalidate Safe Harbor Framework

In a landmark decision that threatens to undo the process by which American companies handle personal data flowing from the European Union, the Advocate General (AG) of the European Court of Justice (ECJ) issued an advisory...more

NIST Guide Highlights Cybersecurity Considerations for Utilities and Manufacturing Companies

In 2013 alone, the U.S. Department of Homeland Security (DHS) and its Industrial Control Systems Cyber Emergency Response Team (ICS-CERT) responded to more than 256 cyber-incident reports—more than half of them in the energy...more

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