News & Analysis as of

Cyber Incident Reporting Data Protection Policies and Procedures

Health Care Compliance Association (HCCA)

Privacy Briefs: October 2023

Report on Patient Privacy 23, no. 10 (October, 2023) Kaiser Foundation Health Plan Inc. and Kaiser Foundation Hospitals will pay California $49 million to resolve allegations that they unlawfully disposed of hazardous waste,...more

Pillsbury Winthrop Shaw Pittman LLP

DHS Implements New Security and Privacy Measures for Controlled Unclassified Information

The Department of Homeland Security amended its regulations due to the urgent need to protect Controlled Unclassified Information. On June 21, 2023, the Department of Homeland Security (DHS or Department) issued a final...more

Jenner & Block

Client Alert: SEC’s Approach to Enforcement After Cyber Incidents: Key Takeaways for Public Companies from a Recent Speech

Jenner & Block on

Last month, Gurbir Grewal, the Director of the SEC’s Division of Enforcement, spoke at the Financial Times Cyber Resilience Summit. During the remarks, he outlined the importance of cybersecurity and signaled that the SEC is...more

Bass, Berry & Sims PLC

DHS Publishes Long-Awaited Final Rule on Controlled Unclassified Information

Bass, Berry & Sims PLC on

On June 21, the Department of Homeland Security (DHS) published a final rule to implement security measures that safeguard controlled unclassified information (CUI) from unauthorized access and disclosure and improve incident...more

Dechert LLP

SEC Proposes New Cybersecurity Rules for SEC Registered Advisers and Funds

Dechert LLP on

At an open meeting on February 9, 2022, the Securities and Exchange Commission voted three-to-one to propose new and amended rules regarding cybersecurity risk management, cyber incident reporting and cyber risk disclosure...more

Ward and Smith, P.A.

Upside Down: Privacy and Data Security LARP

Ward and Smith, P.A. on

A Ward and Smith attorney, Information Technology professional and Privacy Officer outlined a variety of best practices and tips for businesses dealing with data security and privacy issues. The webinar, one in a series...more

Orrick, Herrington & Sutcliffe LLP

Tips for Surviving the First 24 to 48 Hours After an Incident

As cybersecurity incidents become increasingly complex, your initial response to a potential cybersecurity crisis matters. The decisions that you make in the first 24 to 48 hours of a potential cybersecurity incident can have...more

Goodwin

SEC Makes Cybersecurity Top Priority; Sanctions Firms for Cybersecurity Failures

Goodwin on

There is little doubt that the U.S. Securities and Exchange Commission is making cybersecurity a top priority. SEC Chair Gary Gensler told a Senate committee on Tuesday, September 14, 2021 that the agency is developing a...more

Goodwin

Nowhere To Hide: Controllers have “Constructive Awareness” Of Processor Data Breaches

Goodwin on

On December 15, 2020, Ireland’s Data Protection Commission (“DPC”) announced its decision to fine Twitter International Company (“Twitter”) €450,000 for failing to notify the DPC promptly of a data breach affecting EU...more

Proskauer Rose LLP

OCIE Publishes Cybersecurity and Resiliency Observations

Proskauer Rose LLP on

Background - On January 27, 2020, the U.S. Securities and Exchange Commission's Office of Compliance Inspections and Examinations ("OCIE") published its Cybersecurity and Resiliency Observations. Cybersecurity and data...more

Society of Corporate Compliance and Ethics...

Compliance Perspectives: Cybervigilance and Cyber-resiliency

Mark Lanterman, Chief Technology Officer of Computer Forensic Services lives technology at its most terrifying, helping organizations manage the risks of the IT we all use constantly. Recently he authored an article...more

Fisher Phillips

Don’t Take the Bait! “Spear Phishing” and “Whaling” Take Scams to the Next Level

Fisher Phillips on

For several years now, we’ve been alerting employers about the dangers of phishing scams that attempt to obtain private and personal information from employers... Many of these scams rear their ugly head around tax season,...more

Akin Gump Strauss Hauer & Feld LLP

NFA Issues Interpretive Notices for CPOs Regarding Internal Controls Systems and Cybersecurity

• The NFA has determined that registered CPOs must implement an internal controls system and highlighted best practices for such a framework. • In response to certain frequently asked questions, the NFA has also updated its...more

White and Williams LLP

DoD Issues New Guidance to Drive Compliance with NIST 800-171 Cybersecurity Requirements

Is this a Start of Something New for Third-Party Management? The demand for responsible cybersecurity in business is ubiquitous. The need to protect information is not limited to the financial services, insurance and...more

Proskauer on Privacy

SEC Cybersecurity Update

Proskauer on Privacy on

Results from the SEC’s First Round of Cybersecurity Examinations - On February 3, 2015, the OCIE published a risk alert summarizing its findings from its examinations of over 100 registered investment advisers and...more

Snell & Wilmer

SEC Announces Second Wave of Cyber Exams of Broker Dealers and Advisors – Is Your Firm Ready?

Snell & Wilmer on

In April 2014, the Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert announcing its first cybersecurity sweep initiative. Pursuant to that initiative,...more

Morgan Lewis

Proactive Approach To Cybersecurity: Recent SEC guidance and enforcement actions suggest that reactive firms may be in the SEC’s...

Morgan Lewis on

In an environment where even the largest and most powerful corporations have fallen victim to data breaches, it can be challenging to fathom how to protect against the sophisticated and ever-evolving threat of cyber attacks....more

Foley & Lardner LLP

SEC Brings First Cybersecurity Enforcement Proceeding in Wake of Risk Alert

Foley & Lardner LLP on

Highlights Areas of High Risk and Examination Priorities for Financial Industry Firms - On September 15, the U.S. Securities and Exchange Commission’s (SEC’s) Office of Compliance, Inspections and Examinations (OCIE),...more

Foley Hoag LLP - Security, Privacy and the...

The SEC Charges Investment Adviser with Violating Regulation S-P by Failing to Adopt Cybersecurity Policies and Procedures

In recent years, the SEC has been focused on cybersecurity. It has issued risk alerts, conducted examinations and provided guidance about what the agency sees as widespread weaknesses in many policies and procedures to...more

Broker-Dealer Compliance + Regulation

SEC Charges Investment Adviser With Failure to Adopt Proper Cybersecurity Policies and Procedures

A registered investment adviser agreed to settle SEC charges that it failed to adopt adequate cybersecurity policies and procedures reasonably designed to protect customer records and information as required by Rule 30(a) of...more

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