News & Analysis as of

Cyber Incident Reporting Encryption

Troutman Pepper Locke

6 Considerations to Determine if a Cyber Incident Is Material

Troutman Pepper Locke on

In late June, the staff of the U.S. Securities and Exchange Commission’s Division of Corporation Finance released five new compliance and disclosure interpretations regarding the disclosure of material cybersecurity incidents...more

Wiley Rein LLP

New FCC Data Breach Rules Draw Criticism For Problems Beyond the CRA

Wiley Rein LLP on

There has been a lot of coverage about the Federal Communications Commission’s (FCC and Commission) new and expansive data breach notification Order, approved on a 3-2 vote at the Commission’s December 13 Open Meeting. Much...more

Fox Rothschild LLP

Key Takeaways From the FTC's CafePress Settlement

Fox Rothschild LLP on

The Federal Trade Commission has reached a settlement in the matter of CafePress. Here are some things you should know: Data minimization: •Storing information indefinitely on your network without a business need creates...more

Robinson+Cole Property Insurance Coverage...

NAIC Releases Draft of Revised Insurance Data Security Model Law for Review

The National Association of Insurance Commissioners’ (NAIC) Cybersecurity Task Force released a revised draft of the Insurance Data Security Model Law (Model Law) last week. The Model Law’s goal is to “establish exclusive...more

Burr & Forman

Tennessee’s Data-Breach Notice Requirements Among the Nation’s Toughest

Burr & Forman on

On July 1, 2016, Tennessee’s new notice requirements for breaches of data security systems which compromise an individual’s personal information will take effect. The amendments to Tennessee’s current rules, found at T.C.A....more

Davis Wright Tremaine LLP

California Beefs Up Encryption & Notice in Data Breach Law

On October 8, 2015, California Governor Jerry Brown signed A.B. 964 and S.B. 570 into law, a pair of bills that amended the Golden State’s data breach notification statute (Ca. Civ. Code § 1798.82). The amendments...more

Orrick, Herrington & Sutcliffe LLP

California Updates its Data Breach Notice Statute (Again)—What You Need to Know

On October 6, California Governor Jerry Brown signed legislation updating California’s data breach notice statute for the third time in three years.  The news was quickly overshadowed by the CJEU’s decision invalidating the...more

Foley & Lardner LLP

California Amends Definition of Personal Identifiable Information and Breach Notification Content Requirements

Foley & Lardner LLP on

On October 6, 2015, California Governor Jerry Brown signed into law several changes to California’s Data Breach Notification Statute. The law, as amended, adds additional categories of information into the definition of...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

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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