Our Securities and Privacy, Cyber & Data Strategy teams unpack the Department of Justice’s (DOJ) process for companies seeking to delay Form 8-K disclosures under the Securities and Exchange Commission’s (SEC) cybersecurity...more
After a decade and a half under the current data breach notification rules for telecommunications carriers and telecommunications relay services (TRS) providers, the FCC recently unveiled plans to update and expand them....more
Just a month before the Security and Exchange Commission’s (“SEC’s”) Material Cybersecurity Incidents Rule is set to take effect, a ransomware group has apparently taken compliance with reporting requirements into its own...more
With an amendment to its Safeguards Rule, the Federal Trade Commission has joined other federal agencies regulating cybersecurity breaches. Our Privacy, Cyber & Data Strategy Team analyzes how the amendment will affect...more
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
11/13/2023
/ Chief Information Security Officer (CISO) ,
Corporate Liability ,
Cybersecurity ,
Data Security ,
Disclosure Requirements ,
Enforcement Actions ,
Fraud ,
Popular ,
Publicly-Traded Companies ,
Securities and Exchange Commission (SEC) ,
SolarWinds
Our Privacy, Cyber & Data Strategy and Privacy & Cybersecurity Litigation teams examine the New York Department of Financial Services’ finalized Second Amendment to its Cybersecurity Regulation....more
On October 27, 2023, the FTC approved an amendment to the Safeguards Rule (the “Amendment”) requiring that non-banking financial institutions notify the FTC in the event of a defined “Notification Event” where customer...more
Our Privacy, Cyber & Data Strategy Group considers the nationwide repercussions of Colorado’s new regulation of insurers’ use of artificial intelligence models to prevent race-based discrimination....more
The Federal Bureau of Investigation (FBI) issued a Private Industry Notification on September 27, 2023, highlighting two concerning ransomware trends and providing companies with guidance on mitigating potential threat actor...more
At the end of September 2023, the Cyberspace Administration of China (CAC) released draft regulations (see the unofficial English translation) regulating the cross-border flow of personal information and important data out of...more
On October 4, 2023, the National Security Agency (NSA) and Cybersecurity and Infrastructure Security Agency (CISA) published Identity and Access Management: Developer and Vendor Challenges, an advisory document developed by...more
On September 27, 2023, The U.S. National Security Agency (NSA), the U.S. Federal Bureau of Investigation (FBI), the U.S. Cybersecurity and Infrastructure Security Agency (CISA), the Japanese National Police Agency (NPA), and...more
New York Attorney General Letitia James recently announced two agreements related to data breaches with entities that operate in the education industry. In both instances the entities paid the ransom and received evidence of...more
In late August 2023, the California Privacy Protection Agency (“CPPA” or “Agency”) released a discussion draft of proposed regulations under California’s data privacy law, the California Consumer Privacy Act (“CCPA”)....more
Publications and Advisories - July 31, 2023 – Dave Brown, Kate Hanniford, Kim Peretti, Julia Mediamolle, Cara Peterman, Sierra Shear, Kristen Bartolotta, and Kezia Osunsade published “Securities Law, Securities Litigation,...more
8/10/2023
/ Artificial Intelligence ,
California Consumer Privacy Act (CCPA) ,
Civil Investigation Demand ,
COPPA ,
Cybersecurity ,
Data Privacy ,
Data Protection ,
Federal Trade Commission (FTC) ,
Hackers ,
International Data Transfers ,
Online Safety for Children ,
Popular ,
Ransomware ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Standard Contractual Clauses ,
Telehealth
Our Securities, Securities Litigation, and Privacy, Cyber & Data Strategy teams highlight the key aspects of the Securities and Exchange Commission’s final changes to its cybersecurity reporting rules for public companies...more
In mid-July, the Federal Trade Commission (FTC) reportedly opened an investigation into OpenAI, the maker of ChatGPT, sending the company an extensive Civil Investigative Demand (CID). While FTC investigations are normally...more
On June 18, 2023, Texas Governor Greg Abbott signed the Texas Data Privacy and Security Act (HB 4) (“TDPSA”) into law, making Texas the latest contributor to the growing patchwork of comprehensive U.S. state privacy laws....more
The New York Department of Financial Services (“NY DFS”) published an updated proposed Second Amendment to its Cybersecurity Regulation (23 NYCRR Part 500) in the New York State Register on June 28, 2023, updating its...more
On June 13, 2023, the Securities and Exchange Commission (“SEC”) published its Spring 2023 rulemaking agenda that delayed finalizing the proposed Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure...more
On June 7, 2023, the Federal Bureau of Investigation (FBI) and the Cybersecurity and Infrastructure Security Agency (CISA) released a Joint Cybersecurity Advisory in connection with a recent zero-day (or previously...more
On May 1, 2023, bitFlyer USA, Inc. (“bitFlyer”) entered into a Consent Order with the New York Department of Financial Services (“DFS”) for multiple deficiencies in bitFlyer’s cybersecurity program, most notably for failure...more
Publications and Advisories - April 5, 2023 – Kate Hanniford and Elinor Hiller published “Healthy Byte: White House and HHS Both Update Their Cybersecurity Guidance.”...more
On February 24, 2023, the Cyberspace Administration of China (“CAC”) released its final version of the Standard Contract Measures for Exporting Personal Information (“Standard Contract Measures”), accompanied by a template...more
Our Privacy, Cyber & Data Strategy Team breaks down how the two dozen strategic objectives in Biden’s National Cybersecurity Strategy will fundamentally shift how the United States allocates roles, responsibilities, and...more