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Data Security Enforcement Actions Civil Monetary Penalty

Husch Blackwell LLP

Texas Files First Privacy Law Enforcement Action

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On January 13, 2025, Texas Attorney General’s Office filed its first lawsuit enforcing the Texas Data Privacy and Security Act (“TDPSA”). The law went into effect on July 1, 2024. The complaint also states claims under Texas’...more

Saul Ewing LLP

Two CMPs and One Settlement Close Out 2024 HIPAA Enforcement

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December 2024 was an active month for the U.S. Department of Health and Human Services ("HHS"), Office for Civil Rights ("OCR"). OCR announced (i) a $1.19 million civil monetary penalty ("CMP") against Gulf Coast Pain...more

Robinson+Cole Data Privacy + Security Insider

Marriott and Starwood Settle on Consent Agreement with FTC for Data Breaches

This week, Marriott International, Inc. and its subsidiary Starwood Hotels & Resorts Worldwide LLC (collectively, Marriott) agreed to settle on the terms of a settlement order with the Federal Trade Commission (FTC) for its...more

Nelson Mullins Riley & Scarborough LLP

And T-Mobile Makes Three: More Information Security Guidance for Telecommunications Carriers from the FCC

Close on the heels of its Consent Decrees with TracFone and AT&T, on September 27, 2024, the Enforcement Bureau of the Federal Communications Commission (FCC) announced that it reached a Consent Decree with T-Mobile US, Inc....more

WilmerHale

FTC Penalizes Cloud-Based Physical Security Company for Data Security and CAN-SPAM Violations

WilmerHale on

On August 30, the Federal Trade Commission (FTC) entered into a proposed settlement order with cloud-based physical security solutions provider, Verkada Inc. (“Verkada”), settling allegations of data security violations and...more

WilmerHale

FTC Calls Out Genetic Data as an Enforcement Priority

WilmerHale on

The Federal Trade Commission (FTC) recently published a post on their Business Guidance Blog discussing lessons learned from three enforcement actions against sellers of genetic testing products. These guidelines address...more

Clark Hill PLC

GoodRx Pays $1.5 Million Settlement in the FTC’s First Enforcement Action Under the Health Breach Notification Rule

Clark Hill PLC on

For the first time since it became law on Aug. 25, 2009, the Federal Trade Commission (“FTC”) has taken enforcement action under 16 C.F.R. § 318, also known as the Health Breach Notification Rule, with a $1.5 million civil...more

Venable LLP

Twitter Will Pay $150 Million to Settle Charges That It Misrepresented Its Privacy and Security Practices

Venable LLP on

Last week, the United States Department of Justice, acting on behalf of the Federal Trade Commission, took action against Twitter, Inc. for allegedly using private account security data to sell targeted advertisements without...more

Health Care Compliance Association (HCCA)

OCR: Current Fines Too Low to Spur Compliance; Agency Also Seeks Funding Boost, Injunctive Relief

Report on Patient Privacy 22, no. 5 (May, 2022) - Compared to other agencies, the HHS Office for Civil Rights (OCR) is a little fish in the big federal pond, but it has an outsize effect on HIPAA covered entities (CEs) and...more

Mintz - Privacy & Cybersecurity Viewpoints

A New Decade of HIPAA – What Can We Expect?

As the decade winds down, it’s hard to believe that the HIPAA Privacy and Security Rules are almost twenty years old. It has been ten years since the U.S. Department of Health and Human Services (HHS) Office for Civil Rights...more

Harris Beach Murtha PLLC

A HIPAA Compliance Program “In Disarray” Leads to OCR Imposing a $2.15 Million Civil Monetary Penalty

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Last week, the U.S. Department of Health and Human Services Office for Civil Rights (“OCR”) imposed a civil monetary penalty (“CMP”), to the tune of $2.15 million, against Jackson Health System (“JHS”). The CMP stemmed from...more

K&L Gates LLP

K&L Gates Triage: HIPAA Enforcement Discretion, Disputes, and Data

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The U.S. Department of Health and Human Services recently released a notice of enforcement discretion announcing changes in how the agency will assess civil monetary penalties for violations of the Health Insurance...more

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

HHS to Reduce Top HIPAA Fines Based on “Level of Culpability”

In a Notification of Enforcement Discretion Regarding HIPAA Civil Money Penalties issued on April 23, 2019, the Department of Health and Human Services (HHS) exercised “its discretion in how it applies HHS regulations...more

UB Greensfelder LLP

The SEC Released A Risk Alert On Reg S-P, a/k/a How To Avoid A $1 Million Penalty

UB Greensfelder LLP on

I am hardly saying that SEC Regulation S-P is the sexiest of regulations. I mean, has any customer is history actually read one of those exciting statement stuffers that discloses in some dense font a BD’s privacy policy?...more

McDermott Will & Emery

2018 Digital Health Data Developments – Navigating Change in 2019

Data privacy and security legislation and enforcement saw significant activity in 2018 and early 2019. McDermott’s 2018 Digital Health Year in Review: Focus on Data report – the first in a four-part series – highlights...more

Mintz - Health Care Viewpoints

Physician's Response to a Public Patient Complaint Leads to Penalty under HIPAA

The U.S. Department of Health and Human Services (HHS), Office for Civil Rights (OCR) recently announced a no-fault settlement, including a $125,000 penalty and a two year corrective action plan for Allergy Associates of...more

Bradley Arant Boult Cummings LLP

Summary Judgment: Recent HIPAA Case Emphasizes Encryption, Action on Risk Analysis - AHLA Health Information and Technology...

On June 18, 2018, the U.S. Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) announced that an HHS Administrative Law Judge (“ALJ”) granted summary judgment to OCR in an enforcement action...more

Perkins Coie

Recent HIPAA Privacy and Security Settlements and Lessons Learned

Perkins Coie on

Although the fate of the Affordable Care Act remains undecided, enforcement of the HIPAA privacy and security regulations by the Office for Civil Rights (OCR) of the U.S. Department of Health and Human Services is ongoing,...more

Kelley Drye & Warren LLP

CFPB’s First Data Security Action; Fines Online Platform Dwolla for Alleged Weak Security Practices

On March 2, the CFPB settled its first data security enforcement action against Iowa-based Dwolla Inc. Launched as a startup in 2009, Dwolla is an online payment platform that enables customers to transfer money directly...more

Morrison & Foerster LLP

Is the CFPB the New Cop on the Data Security Beat?

On March 2, 2016, the Consumer Financial Protection Bureau (“CFPB”) broke new ground (at least for the CFPB) when it released a consent order against Dwolla, Inc. (“Dwolla”), an online payment platform, regarding data...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

King & Spalding

Investment Adviser Settles SEC Cybersecurity Enforcement Action; SEC Issues Investor Alert

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On September 22, the U.S. Securities and Exchange Commission (“SEC”) and R.T. Jones Capital Equities Management, Inc. (“R.T. Jones”), a St. Louis-based investment adviser, settled charges that R.T. Jones failed to adopt...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

Proskauer on Privacy

SEC Announces Cybersecurity Enforcement Action

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On September 22, 2015, the Securities and Exchange Commission (SEC) announced the settlement of an enforcement action against a St. Louis-based registered investment adviser (Adviser) brought under Rule 30(a) of Regulation...more

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