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Jenner & Block

Client Alert: New York Issues Significant Amendments to its Forward-Leaning Cyber Regulations

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In 2017, the New York Department of Financial Services (“NYDFS”) enacted a landmark regulation requiring financial services institutions such as banks and insurance companies in the state to meet substantial cybersecurity...more

Health Care Compliance Association (HCCA)

11 Years After First Disclosure, L.A. Care Pays $1.3M, Says ‘Processing Errors’ Caused Breaches

Report on Patient Privacy 23, no. 10 (October, 2023) By 2016, it should have been clear to HIPAA covered entities that a security risk analysis—and corresponding risk management plan—were compliance basics. Yet, a new...more

Akin Gump Strauss Hauer & Feld LLP

NYDFS Fines OneMain $4.25M for Cybersecurity Failures

On May 25, 2023, the New York Department of Financial Services (NYDFS) announced that  OneMain Financial Group (OneMain) will pay a $4.25 million fine pursuant to a consent order to settle alleged violations of NYDFS’s...more

Faegre Drinker Biddle & Reath LLP

Feds Hope to Tighten Timeline for Agency Reporting of Cyberattacks as Congress Debates Federal Data Breach Notification Law

On December 6, 2021, in the Memorandum for the Heads of Executive Departments and Agencies, the Office of Management and Budget took a more aggressive position on strengthening the nation’s cybersecurity posture. Under this...more

NAVEX

4 Ways to Protect ePHI Beyond HIPAA Compliance

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Given the choice between credit card data and digital health records, cybercriminals prefer the latter. A stolen credit card can be canceled. Electronic protected health information (ePHI) with its treasure-trove of...more

Hogan Lovells

New York State Expected to Increase Enforcement of Cybersecurity Practices

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Companies should take note of two imminent developments in New York in the area of cybersecurity regulation: enforcement of the New York Department of Financial Services (NYDFS) Cybersecurity Regulation (Regulation) and the...more

Robinson+Cole Data Privacy + Security Insider

Privacy Tip #191 – Trying to Protect Your Medical Information—Let’s Ask Questions About Data Security

In the top three of the list of highly sensitive personal data to be concerned about is our medical information. It’s so sensitive because it is so personal. It used to be that our medical information was located in paper...more

Hogan Lovells

New Obligations Under the NYDFS Cybersecurity Regulation Come Online September 4

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The New York State Department of Financial Services (NYDFS) Cybersecurity Regulation (23 NYCRR Part 500) came into effect March 1, 2017...more

Akin Gump Strauss Hauer & Feld LLP

Five New Requirements Under New York DFS Cybersecurity Regulation Go Into Effect on September 1, 2018

On September 1, 2018, five new requirements included in the New York State Department of Financial Services’ (DFS) Cybersecurity Regulation go into effect – (1) audit trails, (2) application security, (3) data disposal...more

Poyner Spruill LLP

Five Frequently Overlooked Mistakes in HIPAA Compliance

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HIPAA was enacted in 1996. In the years since, most healthcare entities have adapted to the major requirements imposed by HIPAA, HITECH, and the Privacy and Security Rules. Nevertheless, the thicket of regulations still...more

Robinson+Cole Data Privacy + Security Insider

New York Department of Financial Services Updates Cybersecurity Guidance: Coverage of Cybersecurity Requirements Addressed in 4...

On March 1, 2018, the New York Department of Financial Services (NYDFS) “cybersecurity regulations” (23 NYCRR Part 500) took effect, placing a number of cybersecurity requirements on banks, insurance companies, and other...more

Winstead PC

Is it HIPAA or HIPPA? Either way, it still applies.

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I have negotiated hundreds of SaaS agreements for dozens of software companies and I always hated when the company on the other side was a healthcare provider. Invariably, they would bring up Protected Health Information...more

Orrick, Herrington & Sutcliffe LLP

New York DFS Cyber Rules Go Live: Here’s Your Roadmap

August 28, 2017 marks the end of the initial 180-day grace period for compliance under the New York Department of Financial Services’ “first-in-the-nation” cybersecurity regulations (the “Rules”). The initial regulations...more

A&O Shearman

New York State Cybersecurity Regulations: First milestone in sight, what is next on the horizon?

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The New York State Department of Financial Services (“NYDFS”) enacted final cybersecurity regulations (“Regulations”) for NYDFS regulated entities that went into effect on March 1, 2017. The first deadline for compliance...more

Farrell Fritz, P.C.

New York’s New Cybersecurity Regulations and its Impact on your Sensitive Health Information

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Effective March 1, 2017, the New York State Department of Financial Services promulgated regulations to help protect against cybercriminals and their efforts to exploit sensitive electronic data. These cybersecurity...more

Ballard Spahr LLP

NYDFS Updates FAQs to Clarify Cybersecurity Regulations

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The New York Department of Financial Services (NYDFS) recently updated frequently asked questions (FAQs) about its cybersecurity regulations, 23 NYCRR 500, to address four new issues. NYDFS published its initial set of FAQs...more

Kramer Levin Naftalis & Frankel LLP

Funds Talk: June 2017 - Incident Response Plans Form an Essential Part of Cybersecurity Frameworks

Cybersecurity has increasingly moved into the spotlight in recent years, with regulators and financial firms alike clambering to keep pace with rapidly changing demands as threats continue to evolve....more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

Financial Industry Developments - New York Department of Financial Services Promulgates First-in-the-Nation State Cybersecurity Regulation - On February 16, 2017, the New York Department of Financial Institutions...more

Troutman Pepper

Mark Your Calendars: NY Cybersecurity Regulations to Go into Effect

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A covered entity will need to arrange for someone to perform the CISO function, dedicate resources to conduct periodic risk assessments, develop and implement policies and procedures, and retain appropriate personnel and...more

Cadwalader, Wickersham & Taft LLP

New York State Revises “First-In-Nation” Cybersecurity Rules

The New York Department of Financial Services (“DFS”) recently issued a revised version of the cybersecurity rules that it first announced in the fall of last year. The rules apply to a wide range of insurance, banking, and...more

Proskauer on Privacy

New York Department of Financial Services Revises Cybersecurity Proposal: Greater Flexibility and Delayed Compliance Deadlines

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As we previously reported, in December 2016 the New York Department of Financial Services (the “DFS”) announced that it was revising its proposed regulation that would require banks, insurance companies and other financial...more

Carlton Fields

Banks to Broaden Reporting of Suspicious Cyber Activity; Regulators Propose “Enhanced” Cybersecurity Standards

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The fourth quarter of 2016 has seen an uptick in regulatory activity respecting the financial services sector in the cybersecurity space, both at the state level as previously discussed (here) and on the federal level....more

Robinson+Cole Data Privacy + Security Insider

The Cyber Regulation Drops

On September 13, 2016, Governor Andrew Cuomo announced the first proposed broadly applicable cyber regulation in the U.S. (the “Regulation”). The Regulation covers banks, insurance companies and other financial institutions...more

Skadden, Arps, Slate, Meagher & Flom LLP

Privacy & Cybersecurity Update: New York State Proposes Cybersecurity Regulation for Financial Institutions

New York state has proposed a new regulation — to go into effect January 1, 2017 — that would require banks, insurance companies and other financial services institutions regulated by the New York State Department of...more

Mintz - Privacy & Cybersecurity Viewpoints

OCR Warns of HIPAA Risks in Third-Party Apps

The U.S. Department of Health and Human Services Office for Civil Rights (OCR) recently issued a warning regarding vulnerabilities in third-party applications used by entities covered by HIPAA. The OCR warning applies...more

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