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SEC Cybersecurity Incidents Disclosures: Materiality, Decryptors, and Ransom Payments - Dear Mary – Incidents + Investigations...

I work for a public company that recently experienced a ransomware attack. Fortunately, we were able to restore our business operations quickly by obtaining a decryption key from the threat actor. Given that we managed to get...more

Notifying Law Enforcement of Security Incidents - Dear Mary – Incidents + Investigations Cybersecurity Advice Column

“Dear Mary” is Troutman Pepper’s Incidents + Investigations team’s advice column. Here, you will find Mary’s answers to questions about anything and everything cyber-related — data breaches, forensic investigations, how to...more

Ensuring Proper Legal Involvement in the Incident Response Process - Dear Mary – Incidents + Investigations Cybersecurity Advice...

“Dear Mary” is Troutman Pepper’s Incidents + Investigations team’s advice column. Here, you will find Mary’s answers to questions about anything and everything cyber-related — data breaches, forensic investigations, how to...more

Restrictions on Paying a Ransom Demand - Dear Mary – Incidents + Investigations Cybersecurity Advice Column

“Dear Mary” is Troutman Pepper’s Incidents + Investigations team’s advice column. Here, you will find Mary’s answers to questions about anything and everything cyber-related — data breaches, forensic investigations, how to...more

Understanding Access vs. Acquisition - Dear Mary – Incidents + Investigations Cybersecurity Advice Column

Each of the 50 states has its own definition of what constitutes a reportable data breach. For some, it requires “unauthorized access” to personal information. For others, it requires “unauthorized acquisition.” And then,...more

Understanding Breach Notification Obligations Under California Law: What Does the CCPA Require? - Dear Mary – Incidents +...

‘Dear Mary,’ is Troutman Pepper’s Incidents + Investigations team’s advice column. Here, you will find Mary’s answers to questions about anything and everything cyber-related – data breaches, forensic investigations, how to...more

Preserving Forensic Artifacts Following Incident Detection - Dear Mary – Incidents + Investigations Cybersecurity Advice Column

‘Dear Mary,’ is Troutman Pepper’s Incidents + Investigations team’s advice column. Here, you will find Mary’s answers to questions about anything and everything cyber-related – data breaches, forensic investigations, how to...more

Can Vendors Notify Affected Individuals on Behalf of Businesses After a Data Breach? - Dear Mary – Incidents + Investigations...

‘Dear Mary,’ is Troutman Pepper’s Incidents + Investigations team’s advice column. Here, you will find Mary’s answers to questions about anything and everything cyber-related – data breaches, forensic investigations, how to...more

How to Respond When Your Service Provider Suffers a Cyberattack - Dear Mary – Incidents + Investigations Cybersecurity Advice...

‘Dear Mary,’ is Troutman Pepper’s Incidents + Investigations team’s advice column. Here, you will find Mary’s answers to questions about anything and everything cyber-related – data breaches, forensic investigations, how to...more

Understanding Regulatory Response Times Following a Cybersecurity Incident - Dear Mary – Incidents + Investigations Cybersecurity...

‘Dear Mary,’ is Troutman Pepper’s Incidents + Investigations team’s advice column. Here, you will find Mary’s answers to questions about anything and everything cyber-related – data breaches, forensic investigations, how to...more

Does Every Incident Require a Forensic Report? - Dear Mary – Incidents + Investigations Cybersecurity Advice Column

‘Dear Mary,’ is Troutman Pepper’s Incidents + Investigations team’s advice column. Here, you will find Mary’s answers to questions about anything and everything cyber-related – data breaches, forensic investigations, how to...more

Should Companies Conduct Their Own Forensic Investigations? - Dear Mary – Incidents + Investigations Cybersecurity Advice Column

‘Dear Mary,’ is Troutman Pepper’s Incidents + Investigations team’s advice column. Here, you will find Mary’s answers to questions about anything and everything cyber-related – data breaches, forensic investigations, how to...more

More Privacy, Please – February 2024

Editor’s Note: In recent regulatory and enforcement developments, the White House announced a new executive order aimed at strengthening cybersecurity at U.S. ports, and another executive order was issued to protect sensitive...more

2023 Privacy Year in Review

Troutman Pepper’s 2023 Privacy Year in Review is a comprehensive analysis of the year’s key developments in privacy, security, and artificial intelligence and offers practical advice for companies navigating the bewildering...more

Iowa on Cusp of Enacting Privacy Legislation

Recently, the Iowa Legislature sent a bill to Iowa Governor Kim Reynolds for her signature that would make Iowa the sixth state to enact a comprehensive privacy law. The Iowa Senate unanimously passed Senate File 262 (SF 262)...more

Piecing It All Together: OFAC Combines Seven Years of Regulations, Amendments, and Interpretations All in One

Your business was hit with a ransomware attack over the weekend, and the critical systems are locked up (i.e., encrypted). To unlock those valuable systems and continue operating the business, the threat actor demands...more

More Privacy, Please - September 2022

Editor’s Note: In the U.S. laws and regulation space, the California attorney general announced the first-ever CCPA settlement, the California Privacy Protection Agency raised objections to the ADPPA, and the FTC announced...more

Not So Pretty: Top Takeaways From First CCPA Settlement With Sephora and Updated Enforcement Case Examples

With the notice and cure set to expire on January 1, 2023, California Attorney General Rob Bonta (CA AG) provided a glimpse at what to expect with its first settlement of alleged violations of the California Consumer Privacy...more

Troutman Pepper Weekly Consumer Financial Services COVID-19 Newsletter - June 2022 #2

Like most industries today, Consumer Finance Services businesses continue to be significantly impacted by COVID-19. To help you keep abreast of relevant activities, below find a breakdown of some of the biggest legislative...more

California Privacy Protection Agency Publishes Draft Rules

The California Privacy Rights Act (CPRA) established the California Privacy Protection Agency (CPPA), and requires the CPPA to adopt, amend, and rescind regulations on 22 topics — including, among other things, definitions,...more

Troutman Pepper Weekly Consumer Financial Services COVID-19 Newsletter - May 2022 # 5

Like most industries today, Consumer Finance Services businesses continue to be significantly impacted by COVID-19. To help you keep abreast of relevant activities, below find a breakdown of some of the biggest legislative...more

CPRA Series: Part Four – Data Processing Obligation

The California Privacy Rights Action (CPRA) will significantly impact how entities process personal information requiring covered businesses to review and update their existing vendor agreements. The CPRA also includes...more

Connecticut Legislature Passes Comprehensive Privacy Legislation, Awaiting Governor’s Signature

On April 28, the Connecticut House passed Senate Bill 6, an act concerning personal data privacy and online monitoring (SB 6 or Connecticut Act). The Senate unanimously passed SB 6 on April 20, and is now currently under...more

Troutman Pepper Weekly Consumer Financial Services COVID-19 Newsletter - April 2022

Like most industries today, Consumer Finance Services businesses are being significantly impacted by the novel coronavirus (COVID-19). Troutman Pepper has developed a dedicated COVID-19 Resource Center to guide clients...more

Utah Becomes Fourth State to Adopt Privacy Legislation

On March 24, Governor Spencer J. Cox signed the Utah Consumer Privacy Act (UCPA), making Utah the fourth state in the country to adopt a comprehensive privacy law. The UCPA is set to take effect on December 31, 2023, and this...more

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