No Password Required: Founder and Commissioner of the US Cyber Games, CEO of the Cyber Marketing Firm Katzcy, and Someone Who Values Perseverance Over Perfection
Biometric Litigation
Founder of Cyber Security Unity, Member of the Order of the British Empire, and Appreciator of '80s Soap Operas
Illinois Supreme Court Clarifies BIPA Violation Accruals, Opening the Door for “Annihilative” Damage
No Password Required: The Custom T-Shirt-Wearing CEO Who Not Only Appreciates Mega Man ... He Basically Is One
Hybrid Workforces and Compliance with Sheila Limmroth
Legislating Data Privacy Series: A Conversation with Massachusetts Representatives Dave Rogers and Andy Vargas
State Law Privacy Video Series | Privacy and Sensitive Information
Podcast: BIPA Trends in 2022
State Law Privacy Video Series | Applicability
Getting Personal—Wearable Devices, Data, and Compliance
Episode 8: Why brokers, not breaches, are America's greatest privacy threat (with Rob Shavell)
NGE On Demand: Personal Data Protection Travels: The New Standard Contractual Clause with John Koenigsknecht and David Wheeler
Inside Privacy Law: The Regulation of Personal Data
NGE On Demand: Cybersecurity Considerations for Emerging Companies with Michael Gray and David Wheeler
Oklahoma: Changing Data Privacy as We Know It?
The Convergence of AI and Data Privacy in eDiscovery: Using AI and Analytics to Identify Personal Information
Reducing Cybersecurity Burdens with a Customized Data Breach Workflow
Sitting with the C-Suite: Looking Ahead to Potential Compliance Issues Due to COVID-19
Sitting with the C-Suite: Information Governance and eDiscovery - Key Compliance Issues for In-House Counsel
On May 16, the Securities and Exchange Commission (“SEC”) announced the adoption of amendments to Regulation S-P, aimed at modernizing and enhancing the rules governing the treatment of consumers’ nonpublic personal...more
The Securities and Exchange Commission (“SEC”) has announced the adoption of amendments to Regulation S-P (“Amendments”) to modernize and enhance the rules that govern the treatment of consumers’ nonpublic personal...more
On May 15, 2024, the Securities and Exchange Commission (the “SEC”) issued final amendments (the “Amendments”) to Regulation S-P (originally adopted in 2000), which governs the treatment of a customer’s nonpublic personal...more
On May 16, 2024, the Securities and Exchange Commission (“SEC”) approved amendments to Regulation S-P to address unauthorized access to or use of “customer information” (a new defined term). Regulation S-P governs how...more
In a recent Securities and Exchange Commission (“SEC”) enforcement action, the SEC concluded that a registered broker-dealer and investment adviser (the “Firm”) violated Rule 30 of Regulation S-P by failing to adopt...more
In a speech to the Securities Regulation Institute conference last week, Chair Gary Gensler signaled the SEC may implement more stringent cybersecurity regulations, and in the meantime, would work to enforce existing...more
There is little doubt that the U.S. Securities and Exchange Commission is making cybersecurity a top priority. SEC Chair Gary Gensler told a Senate committee on Tuesday, September 14, 2021 that the agency is developing a...more
On August 30, 2021, the Securities and Exchange Commission announced three enforcement actions against registered investment advisers for alleged cybersecurity failures involving cloud-based email systems. All three actions...more
On August 30, 2021, the Securities and Exchange Commission (SEC) announced that eight broker-dealers and/or investment advisers will pay civil monetary penalties to resolve enforcement actions arising from cybersecurity...more
OCIE has released a risk alert regarding credential stuffing in the context of compliance with Regulation S-P and Regulation S-ID, and is encouraging firms to both (i) review and update their policies and procedures to...more
A cyber breach can have serious legal, financial, and reputational consequences for a fund sponsor, as described in our previous post. As such, cybersecurity threats must be treated as business risks, not just a potential IT...more
With more people working remotely than ever before in light of COVID-19, firms in the private equity and hedge fund space should review their Regulation S-P privacy and information-safeguarding policies to ensure they are...more
In today’s world, cybersecurity breaches and threats are pervasive concerns for any business entity, without exception. Working from home arrangements due to COVID-19 constraints only magnify the risk and create further...more
Cybersecurity breaches and threats are pervasive concerns for any entity storing valuable data or managing large sums of money: private investment funds are no exception. Recently three private equity firms suffered breaches...more
In the inaugural issue of Investment Management Update, we summarize regulatory, litigation and industry developments from February 2019 to May 2019 impacting the investment management sector....more
Are You Ready for Canada’s New Privacy Breach Rules? Mandatory privacy breach notification, reporting, and record-keeping obligations under Canada’s federal data protection law, the Personal Information Protection and...more
On April 16, 2019, the Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) released a new Risk Alert regarding Regulation S-P deficiencies found in recent examinations of...more
The Office of Compliance Inspections and Examinations (the “OCIE”) issued a risk alert that provides guidance to broker-dealers and investment advisors for complying with the requirements of Regulation S-P on April 16, 2019. ...more
Recently, the Financial Industry Regulatory Authority (“FINRA”) and the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) separately issued important guidance regarding customer communications surrounding the...more
On April 16, 2019, the Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert summarizing numerous issues it found in its recent examinations of SEC-registered...more
When it comes to information security, the Safeguards Rule of Regulation S-P (Safeguards Rule) requires SEC-registered investment advisers and brokers and dealers (Registrants) to adopt written policies and procedures that...more
• 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
The Securities and Exchange Commission is warning investment firms to step up their game when it comes to following the agency’s privacy rules. In a Risk Alert issued by the Office of Compliance Inspections and Examinations...more
On April 16, the SEC's Office of Compliance Inspections and Examinations (OCIE) published a Risk Alert outlining issues related to compliance with Regulation S-P that it identified in its inspections of SEC-registered...more
On April 16, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) issued a Risk Alert highlighting Regulation S-P compliance deficiencies and issues it found in recent examinations of broker-dealers and...more