News & Analysis as of

Data Breach Data Security Disclosure Requirements

Constangy, Brooks, Smith & Prophete, LLP

Data Privacy Day Checklist: Top 10 ways to protect your organization's data

Tomorrow is International Data Privacy Day, so a happy day to all! More seriously, data privacy concerns and legislation continue to rapidly increase. It has been estimated that by the end of 2024 more than 75 percent of...more

Osano

Privacy by Design: Understanding and Implementing the Framework

Osano on

As of this writing, the CAM4 security incident remains the largest data breach in history. The attack on the website exposed nearly 11 billion records, including users' names, email addresses, sexual orientations, chat...more

Mayer Brown

Trends in US Cybersecurity Regulation

Mayer Brown on

As cybersecurity rules proliferate, companies must navigate a maze of new, and often overlapping, proactive and reactive cybersecurity requirements and guidance. This Legal Update surveys new cybersecurity rules and...more

Troutman Pepper Locke

Cyber Incident Response Checklist for SEC Compliance

Troutman Pepper Locke on

By now, public companies are generally aware of the cybersecurity rules adopted by the U.S. Securities and Exchange Commission a year ago, requiring public companies to disclose material cybersecurity incidents under Item...more

Woodruff Sawyer

The New Hacker Playbook: Weaponizing the SEC’s Cyber Disclosure Rules

Woodruff Sawyer on

Hackers are now weaponizing the SEC’s cyber disclosure rules as a new way to pressure corporations. You may recall that the Securities and Exchange Commission has new rules for timely disclosure of cyberattacks. One major...more

Orrick, Herrington & Sutcliffe LLP

Ginnie Mae now requires issuers to disclose cybersecurity incidents within 48 hours

On March 4, the President of Ginnie Mae released All Participants Memorandum (APM) 24-02, which set forth a new requirement applicable to all issuers, including issuers that subservice loans for others. The memo mandated that...more

Sheppard Mullin Richter & Hampton LLP

For Limited Use Only: Guidance on National Security Delay Determinations under the SEC Cyber Reporting Rule

On December 12, 2023, the Department of Justice (“DOJ”) issued guidance related to the process by which companies may request the United States Attorney General authorize delays of cyber incident disclosures, pursuant to a...more

Blank Rome LLP

The BR Privacy & Security Download: January 2024

Blank Rome LLP on

Welcome to this month's issue of The BR Privacy & Security Download, the digital newsletter of Blank Rome’s Privacy, Security & Data Protection practice....more

Nelson Mullins Riley & Scarborough LLP

[Webinar] Creating a Data Privacy & Security Playbook for 2024: An Overview of Compliance and Regulations, AI, and Data Breach...

Nelson Mullins invites you to the two-day webinar, Creating a Data Privacy & Security Playbook for 2024: An Overview of Compliance and Regulations, AI, and Data Breach Concerns, on Feb. 7 and 8 in honor of Privacy Day...more

Nelson Mullins Riley & Scarborough LLP

SEC Adopts New Cybersecurity Disclosure Requirements

The Securities and Exchange Commission (“SEC”) adopted the final rules (the “Final Rules”) on July 26, 2023 that will require disclosure of material cybersecurity incidents, cybersecurity risk management, strategy, and...more

Constangy, Brooks, Smith & Prophete, LLP

Cyber governance for executive boards: Understanding the new SEC breach notification rules

Boards of Directors for public companies across the country are likely to be taking stock of their companys’ cybersecurity practices and strategies after the Securities and Exchange Commission’s adoption of the Cybersecurity...more

Brownstein Hyatt Farber Schreck

SEC Releases Aggressive New Cybersecurity Disclosure Requirements

“Material Cybersecurity Incident” Standard Will Have a Monumental Impact on Current Cyber Disclosure Requirements - On July 26, 2023, the U.S. Securities and Exchange Commission (SEC) adopted the Cybersecurity Risk...more

A&O Shearman

SEC Mandates New Cybersecurity Disclosures

A&O Shearman on

On July 26, 2023, the SEC adopted final rules that require public companies to promptly disclose material cybersecurity incidents on Form 8-K and detailed information regarding their cybersecurity risk management and...more

Polsinelli

SEC Adopts Cybersecurity Incident and Risk Management Disclosure Rules

Polsinelli on

On July 26, 2023, the Securities and Exchange Commission (the “SEC”) adopted new rules requiring public companies to disclose within four business days material cybersecurity incidents they experience and to disclose annually...more

Thomas Fox - Compliance Evangelist

SEC Formalizes New Rules on Cyber Breach Disclosures

The SEC has recently voted on new rules that will require companies to disclose material cybersecurity incidents within four days and to make disclosures about their broad cybersecurity risks in their annual report. Tom Fox...more

Pierce Atwood LLP

First Circuit Offers Lessons to Businesses Facing Cybersecurity Incidents and Class Action Litigation Risk

Pierce Atwood LLP on

In Webb v. Injured Workers Pharmacy, LLC, the First Circuit recently reversed a lower court’s dismissal of class action claims brought by former pharmacy patients alleging that their sensitive personal information had been...more

Robinson+Cole Data Privacy + Security Insider

SEC Adopts New Cybersecurity Rules for Public Companies

In a 3-2 vote, the Securities and Exchange Commission (SEC) adopted new cybersecurity rules yesterday (July 26, 2023) applicable to public companies. The rules, which will become effective thirty days after publication in...more

Bilzin Sumberg

SEC’s New Cyber Incident Disclosure Requirements Will Go Into Effect in December

Bilzin Sumberg on

Come December 2023, public companies will have a very narrow window to report cybersecurity incidents that materially affect their companies. Companies will also have to report annually how they assess and manage...more

Cooley LLP

SEC adopts final rules on cybersecurity disclosure

Cooley LLP on

In remarks to the audience at a Financial Times summit earlier this month, Gurbir Grewal, SEC Director of Enforcement, citing a recent poll from Deloitte, observed that over “a third of executives reported that their...more

Reveal

Information Governance 101: Everything You Need to Know To Get Started in 2023

Reveal on

Information governance (IG) plays an increasingly significant role of the way corporations do business. But what do organizations do with all their data? Where do they store it—and is it secure, well organized, and...more

Orrick, Herrington & Sutcliffe LLP

Utah amends disclosure requirements for data breaches

On March 23, the Utah governor signed SB 127, which, among other things, requires additional disclosure requirements for system security breaches and creates the Utah Cyber Center....more

Walkers

Data Protection in the British Virgin Islands

Walkers on

The British Virgin Islands ("BVI") Data Protection Act, 2021 ("DPA") came into force on 9 July 2021. It was introduced so the BVI would have a data protection framework which is broadly similar to EU and UK standards. To...more

Ballard Spahr LLP

Unpacking the FTC’s Recent  Blog Post Regarding Breach Notification

Ballard Spahr LLP on

The Federal Trade Commission (FTC) recently issued a blog post stating that a failure to disclose a data breach may be a violation of Section 5 of the FTC Act. The May 20 blog post, titled Security Beyond Prevention: The...more

Stinson - Corporate & Securities Law Blog

SEC Issues Proposed Rules on Disclosure of Cybersecurity Incidents

The SEC has issued proposed rules on disclosure of cybersecurity incidents.  Specifically, the SEC is proposing to: Amend Form 8-K to add Item 1.05 to require registrants to disclose information about a cybersecurity...more

Cooley LLP

SEC votes to propose new rules for cybersecurity disclosure and incident reporting

Cooley LLP on

In remarks in January before the Northwestern Pritzker School of Law’s Annual Securities Regulation Institute, SEC Chair Gary Gensler addressed cybersecurity under the securities laws. (See this PubCo post.) Gensler suggested...more

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