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Data Security Enforcement Actions Disclosure Requirements

Polsinelli

Recent Developments Relating to the SEC’s Cybersecurity Disclosure Requirements

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The U.S. Securities and Exchange Commission (SEC) is becoming one of the federal agencies at the forefront of driving transparency, cybersecurity awareness and cyber incident reporting. As we reported in last year’s...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

Alston & Bird

The SEC Sues SolarWinds and Its CISO for Alleged Fraud and Disclosure Controls Failures

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Our Securities Litigation, Securities, and Privacy, Cyber & Data Strategy teams outline vital takeaways for public companies and their directors and officers in light of the Securities and Exchange Commission’s recent civil...more

Perkins Coie

Answers to Common Questions Regarding New CIRCIA

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President Biden signed into law the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA) on March 15, 2022. The enactment of CIRCIA follows attacks on critical infrastructure, such as the May 2021...more

Holland & Knight LLP

SEC Proposes Substantial New Cybersecurity Requirements for Investment Advisers and Companies

Holland & Knight LLP on

Following U.S. Securities and Exchange Commission (SEC) Chairman Gary Gensler's recent speech directing the agency to expand cybersecurity requirements on regulated entities, the SEC on Feb. 9, 2022, voted to propose new...more

Health Care Compliance Association (HCCA)

[Event] Research Compliance Conference - June 8th - 10th, Anaheim, CA

Hear about the latest in research compliance - Do you want to learn… - How to prepare for upcoming changes in Medicaid? - Ways to build and maintain a better research compliance work plan for your program? - How...more

Holland & Knight LLP

SEC Chair Gensler Remarks Indicate 2022 Action Expanding Cyber Requirements

Holland & Knight LLP on

U.S. Securities and Exchange Commission (SEC) Chair Gary Gensler made remarks on Jan. 24, 2022, at Northwestern University Pritzker School of Law's Annual Securities Regulation Institute regarding the SEC's work to improve...more

Brownstein Hyatt Farber Schreck

When Should a Public Company Disclose a PCI Breach?

As companies collect growing amounts of data about their customers and other consumers, sophisticated adversaries, recognizing the value of this information, have increased their efforts to pilfer it. For publicly traded...more

BCLP

Privacy, Vulnerabilities, and Breaches, Oh My

BCLP on

A recent SEC settlement shed light on data security and privacy concerns that public companies should keep in mind when drafting and filing periodic reports. The SEC settlement concerned a 2018 data breach at Pearson Plc that...more

Bracewell LLP

SEC Gets Cyber-Serious About Disclosures

Bracewell LLP on

As cyberattacks continue to attract greater attention, the SEC has taken an additional step in its efforts to bring enforcement actions related to cyber disclosures. On June 14, the SEC announced settled charges against a...more

Alston & Bird

SEC Settles Enforcement Action for Disclosure Controls Violations Stemming from Data Security Incident

Alston & Bird on

The SEC has settled an enforcement action against a large title insurer in connection with public statements and disclosures made by the company in May 2019 relating to a data security incident.  The underlying data security...more

Goodwin

CCPA 2.0 Passes: The California Privacy Rights Act To Become Law

Goodwin on

On November 3, 2020, California voters convincingly approved the California Privacy Rights Act (“CPRA”) ballot initiative. The CPRA builds upon and amends the California Consumer Protection Act (“CCPA”), aligning it more with...more

McDermott Will & Emery

Republicans and Democrats Introduce Competing Privacy Bills to Protect Consumers’ Health Information Related to the COVID-19...

McDermott Will & Emery on

As the federal government, state governments, businesses and other entities continue their response efforts related to the COVID-19 pandemic, the privacy and security of consumers’ personal health information remains a top...more

Akin Gump Strauss Hauer & Feld LLP

In Principle: 10 Things Authorised Firms Need to Know for 2020

Welcome to the 2020 edition of In Principle. With the United Kingdom (UK) leaving the European Union (EU) on31 January 2020, and moving into a transition period which will last until 31 December 2020, Brexit of courselooms...more

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

Move over, CCPA? New York Considers Sweeping Data Privacy Law

New York’s state legislature is considering a new data privacy law that would set the standard for data privacy in the U.S. The New York Privacy Act (the “NYPA” or the “Act”), which is currently being considered by the state...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

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

GDPR Alert: Google Gets Biggest Fine Ever Issued by a European Data Protection Authority

On 21 January 2019, the French Data Protection Authority (the “French DPA”) fined Google LLC 50 million euros for breach of the GDPR. As we reported on this blog, just after GDPR became applicable, noyb.eu (None of Your...more

Fenwick & West LLP

Deregulation is the New Buzzword in Washington — Except in the Tech Industry

Fenwick & West LLP on

The past year has been a volatile one, from trade wars to the government shutdown to a stock market dive. One constant that U.S. businesses have become accustomed to, however, is deregulation across a wide variety of...more

Akin Gump Strauss Hauer & Feld LLP

Top 10 Topics for Directors in 2019

1. Corporate Culture - The corporate culture of a company starts at the top, with the board of directors, and directors should be attuned not only to the company’s business, but also to its people and values across the...more

Patterson Belknap Webb & Tyler LLP

SEC Cyber Briefing: Enforcement Expectations for 2019

In our second installment of a three-part series, we look at the U.S. Securities and Exchange Commission’s cyber-related enforcement actions in 2018....more

Mayer Brown Free Writings + Perspectives

SEC Strategic Plan

The Securities and Exchange Commission recently released its Strategic Plan for fiscal years 2018 to 2022. The plan identifies three goals. ...more

Moore & Van Allen PLLC

SEC Issues Disclosure Guidance as Part of Continued Focus on Cybersecurity

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As cybersecurity attacks have continued to gain prominence as a threat posing critical risk management and compliance challenges for financial institutions, the Securities and Exchange Commission (SEC) has emerged as an...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

Akin Gump Strauss Hauer & Feld LLP

California Passes Landmark Consumer Privacy CCPA—What it Means for Businesses

• California recently passed the landmark California Consumer Privacy Act that goes into effect in 2020, which grants California residents new privacy rights. • The CCPA creates a private right of action for California...more

Patterson Belknap Webb & Tyler LLP

Uber’s Latest Headache

An expanded settlement by the Federal Trade Commission with ride-sharing giant Uber Technologies should serve as a lesson to other businesses about what happens when a company fails to disclose a data breach during an ongoing...more

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