News & Analysis as of June 22, 2025

Customer Information

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Follow this channel for advisories on one of the biggest threats to businesses today. Read a morning brief of fresh guidance and commentary by leading lawyers on security, privacy, risk management, global regulations, data protection, leaks, hacking, cyber insurance, compliance, HIPAA, and every other aspect of cybersecurity of import to corporate readers right now. less -

AT&T Customer Data Resurfaces on Dark Web in Enhanced, Decrypted Format

HaystackID on 6/13/2025

According to an AT&T spokesperson, this is not accurate. Social Security Numbers and Dates of Birth were already available in plain text in the original compromised dataset from 2024 (in separate files that could be...more

Data Breach Notification Requirements Under the Safeguards Rule Now in Effect

Alston & Bird on 6/13/2024

For years, the Gramm-Leach-Bliley Act (GLBA) has required financial institutions to maintain reasonable safeguards for consumer data, but has only had limited breach-reporting requirements. To the extent financial...more

SEC Adopts Amendments To Regulation S-P

Paul Hastings LLP on 6/5/2024

On May 15, 2024, the Securities and Exchange Commission (the “SEC”) adopted amendments to Regulation S-P. Originally passed in 2000, Regulation S-P regulates the treatment of non-public personal information of consumers by...more

SEC Adopts Amendments to Regulation S-P That Require Reporting Breaches of "Sensitive Customer Information"

Davis Wright Tremaine LLP on 5/28/2024

On May 15, the Securities and Exchange Commission adopted amendments to Regulation S-P, which covers broker-dealers, registered investment advisors (RIAs), and investment companies (funds). These entities are now required to...more

FTC Adds Data Breach Notification Requirement to Safeguards Rule

Davis Wright Tremaine LLP on 11/2/2023

The Federal Trade Commission (FTC or Commission) has amended its Standards for Safeguarding Customer Information, commonly known as the "Safeguards Rule," to require non-bank financial institutions to report certain data...more

Cybersecurity Regulation: Key Takeaways From an Unusual FTC Order That Will Follow CEO for a Decade

Farella Braun + Martel LLP on 11/16/2022

The FTC recently issued a proposed order that would settle an enforcement action against Drizly, LLC and its co-founder and CEO, James Rellas, arising from data breaches in 2018 and 2020 that affected over 2.5 million...more

Non-Banking Institutions Will Want to Review Security Measures in Light of Update to Safeguards Rule

Sheppard Mullin Richter & Hampton LLP on 11/5/2021

The FTC recently announced a final rule updating its GLBA Safeguards Rule to “strengthen the data security safeguards” of consumer financial information. The FTC reported that it was making these changes in response to...more

FTC Amends Standards for Safeguarding Customer Information

Saul Ewing LLP on 11/3/2021

On October 27, 2021, the Federal Trade Commission (“FTC”) issued a Final Rule amending the Standards for Safeguarding Customer Information (also known as the “Safeguards Rule”), 16 C.F.R. Part 314. The Safeguards Rule sets...more

Why It Matters Whether Hashed Passwords Are Personal Information Under U.S. Law

Bradley Arant Boult Cummings LLP on 2/2/2021

On January 22, 2021, Bleeping Computer reported about yet another data dump by the hacker group Shiny Hunters, this time for a clothing retailer. Shiny Hunters is known for exfiltrating large databases of customer...more

Data Privacy and E-Commerce: Considerations for the Food and Beverage Industry

International Lawyers Network on 9/17/2020

The global food and beverage e-commerce market is expected to grow to $22.4 billion in 2020, possibly reaching $36.4 billion in 2023. That’s up from $14.9 billion in 2019. Food and beverage e-commerce revenue in the United...more

Beware Compromised Business Email... and the Litigation that Follows

Moore & Van Allen PLLC on 5/2/2020

Businesses are facing this system hack with ever-increasing frequency: An accounts payable employee receives new or updated payment instructions from a vendor via email. The email appears to be from a familiar counterpart at...more

SEC Warns Registered Firms about Client Privacy and Data Security

Akin Gump Strauss Hauer & Feld LLP on 4/29/2019

• The SEC released a Risk Alert summarizing key areas in which it continues to see compliance deficiencies related to Regulation S-P, the primary SEC rule regarding privacy notices and safeguard policies of investment...more

SEC Issues Risk Alert on Privacy Issues

Bass, Berry & Sims PLC on 4/26/2019

The SEC has again signaled that now is the time for investment advisers and broker-dealers to get serious about compliance with Reg. S-P. For years, the SEC’s examination priorities have included a focus on cybersecurity...more

SEC To Focus on Cybersecurity in 2019

Sheppard Mullin Richter & Hampton LLP on 3/28/2019

For the fourth year running, the Securities and Exchange Commission’s Office continues to list cybersecurity as one of the top enforcement priorities for 2019. As it relates to cybersecurity, the SEC will be focusing on...more

Payment Card Data is Not Trade Secret Information under the DTSA

Holland & Knight LLP on 11/6/2018

In a recent case involving hackers that stole "payment card data" from Chipotle, Judge William J. Martinez in the United States District Court for the District of Colorado found on an issue of first impression that payment...more

SEC Issues $1 Million Identity Theft Rule Fine

Sheppard Mullin Richter & Hampton LLP on 10/23/2018

The Securities and Exchange Commission recently settled with Voya Financial Advisors, Inc. for alleged violation of Regulation S-ID (otherwise known as the Identity Theft Red Flags Rule) and Regulation S-P (otherwise known as...more

Can You Survive Identity Theft?

Searcy Denney Scarola Barnhart & Shipley on 7/20/2018

Identity Theft in the Digital and Physical Worlds - Common sense is the best defense against identity theft – creating strong passwords for online accounts and monitoring personal credit reports and credit card statements...more

The Impact of the California Consumer Privacy Act of 2018 on Businesses and Consumers

Foster Garvey PC on 7/6/2018

On Thursday, June 28, 2018, the California Consumer Privacy Act of 2018 (the Act) passed with resounding support from both Republicans and Democrats, who voted in favor of the bill 73-0-7 in the Assembly and 38-0-3 in the...more

Two More Circuits Find Data Breach Standing without Proof that Plaintiffs’ Data Was Misused

Bradley Arant Boult Cummings LLP on 4/24/2018

Data breaches have become commonplace. Despite the best efforts of many, identity thieves and hackers always seem to find a new vulnerability somewhere in the system of virtually every company that conducts business online....more

Busy Data Breach Week

Robinson+Cole Data Privacy + Security Insider on 4/16/2018

Unfortunately, it was another busy data breach week. Here’s a summary of the major ones. Delta Airlines admitted in a statement that the payment card data of several hundred thousand customers may have been compromised by...more

OTA & Travel Distribution Update - Brazilian antitrust authorities adopt narrow approach to rate parity; Group segment moves to...

Foster Garvey PC on 4/9/2018

This week’s OTA & Travel Distribution Update for the week ending March 30, 2018 is below. This week’s Update features a heavy dose of OTA updates....more

Tougher Privacy and Data Security Protections Coming to North Carolina

Fisher Phillips on 1/25/2018

A bi-partisan privacy and data security bill, which will significantly impact companies with North Carolina employees, is in the works. North Carolina State Representative Jason Saine (R), Appropriations Chairman of...more

The FTC Data Security Settlement with Uber

Bilzin Sumberg on 8/23/2017

The Risks of Overpromising and Underperforming - Demonstrating its authority over all things cybersecurity, the Federal Trade Commission (FTC) announced that it has entered into a proposed consent order with Uber for the...more

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