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Our Privacy, Cyber & Data Strategy Team discusses how to overcome five challenges companies face in the wake of a data security incident when reviewing impacted data to comply with legal obligations....more
As described in an earlier alert, the Department of Justice (DOJ) recently announced a 90-day pause in enforcement of the "Bulk Data Rule" for entities engaging in good faith compliance. That 90-day grace period ends on July...more
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
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
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
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
Colorado is the latest state to introduce a bill focused on consumer protection issues when companies develop AI tools. The bill imposes obligations on developers and deployers of AI systems. Additionally, the bill provides...more
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
On July 26, the Securities and Exchange Commission (“SEC”) finalized a much anticipated rule addressing cybersecurity risk management, strategy, governance, and incident disclosure. Public companies registered with the SEC...more
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
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
At an Open Meeting on July 26, 2023, the US Securities and Exchange Commission (SEC) adopted final rules and amendments that impose new cybersecurity-related disclosure requirements for public companies subject to the...more
In yet another indication of the increasing weight being given by government officials to cybersecurity, on July 26, 2023, the Securities and Exchange Commission adopted new rules requiring public companies to disclose...more
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
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
For most large companies, a frictionless flow of information and the ability to transfer customer data, employee files, financial records and other information around the world quickly and cost-effectively is a critical...more
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
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
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
The charitable organization sector faces many compliance challenges, including: - unique tax exemption issues - fundraising registration and related issues - privacy and data security - complex reporting...more
White & Case Technology Newsflash - Fulfilling a company's data breach and cybersecurity incident notification and disclosure requirements is an increasing challenge. Companies operating across industry sectors and around...more
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
The fundamental principle of SEC’s market regulation is the power of sunshine, transparency and disclosure. In other words, the SEC seeks to ensure that companies disclose important information to the public so that...more
The Commission's "new" cybersecurity guidance largely rehashes existing guidance, as is highlighted by objections from two commissioners. At most, the additional qualitative guidance is incremental. It reiterates the need to...more
In February 2018 the SEC outlined its views with respect to cybersecurity disclosure requirements under the federal securities laws as they apply to public reporting companies. Set forth below is a checklist of items included...more