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European Data Protection Board Releases Guidelines on the Territorial Scope of the GDPR

On November 23, the European Data Protection Board released guidelines for public comment (the “Guidelines”) on the territorial scope of the General Data Protection Regulation (“GDPR”). Specifically, the Guidelines address...more

California Amends Consumer Data Privacy Act, but Leaves Material Provisions Unchanged and Questions Unanswered

On August 31, 2018, the California State Legislature passed Senate Bill 1121, amending the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA, which contains the broadest consumer data privacy protections in the...more

Follow the Leader: NYDFS Cybersecurity Regulation Leads the Way for Other States and Industries

The New York Department of Financial Services (NYDFS) blazed a cybersecurity trail with its 2017 regulation for the protection of information collected and processed in, and systems used in the operation of, the financial...more

South Carolina Department Clarifies Confusing Change in Its New Insurance Data Security Act

As reported on Locke Lord’s InsureReinsure blog, the NAIC adopted a model law for the protection of the data and systems used by the insurance industry, and South Carolina became the first state to enact legislation based on...more

South Carolina Department clarifies confusing change in its new Insurance Data Security Act

As reported, the NAIC adopted a model law for the protection of the data and systems used by the insurance industry, and South Carolina became the first state to enact legislation based on the NAIC model. In doing so,...more

South Carolina becomes First State to enact Insurance Data Security Law based on NAIC Model

The NAIC adopted an Insurance Data Security Model Law. On May 3, 2018, the South Carolina Governor made South Carolina the first state in the nation to adopt a comprehensive cybersecurity statute for the insurance industry,...more

NYDFS Cybersecurity Update: Two Transition Dates Remaining

Several of the new requirements of the New York State Department of Financial Services (DFS) Cybersecurity Regulation are now operative for firms and individuals engaged in financial services (including insurance companies...more

A Closer Look at the NAIC Insurance Data Security Model Law

Following New York’s lead after the Department of Financial Services (the NYDFS) promulgated its Cybersecurity Regulation, in October 2017 the NAIC adopted its Insurance Data Security Model Law (the NAIC Model) to establish...more

NY DFS Cybersecurity Compliance Certificate Required Today; Additional Requirements Looming

As previously warned, February 15, 2018 is the first annual deadline for individuals and companies licensed or otherwise authorized under the New York Insurance, Banking and Financial Services laws (defined as Covered...more

Cybersecurity Reminder and Heads Up from NY DFS: File Cybersecurity Reg Compliance Certificates, and Prepare for Cybersecurity...

A press release issued by the New York Department of Financial Services on January 22, 2018 reminds Covered Entities (including banks, insurers and producers, and others regulated by DFS) of their obligation to file a...more

New York DFS Cybersecurity Regulation Update: Lots Left To Do

Insurers and producers, banks, lenders and others licensed by the New York Department of Financial Services (DFS) have already had to comply with several of the requirements of the new DFS Cybersecurity Regulation, but for...more

Developing Cybersecurity Requirements in Banking, Insurance and Other Financial Services

The financial services industry has been dealing with requirements for cybersecurity since 1999, but 2017 brought new, significant, and proliferating obligations. The bar for the whole industry was clearly raised by the...more

Forward Vision: New York’s Cybersecurity Regulation Imposes a Series of Deadlines

New York’s cybersecurity regulation that went into effect in March has far reaching implications. The first transition date for implementation of several requirements of the state’s Department of Financial Services regulation...more

NAIC Adopts Model Cybersecurity Law

Based largely on the NY DFS Cybersecurity Regulation that became effective March 1, 2017, the NAIC has adopted a Model Cybersecurity Law that would, once adopted by the various states, establish significant requirements for...more

NY DFS Cybersecurity Exemption Filings due October 30

October 30, 2017 is the extended deadline for most Covered Entities claiming an exemption to file the Notice of Exemption required by the NY DFS Cybersecurity Regulation (23 NYCRR 500.19(e)). The filing deadline is 30 days...more

New York DFS Cybersecurity Regulation Update: Lots Left To Do

Insurance companies and producers, banks, lenders and others licensed by the New York Department of Financial Services (DFS) have already had to comply with several of the requirements of the new DFS Cybersecurity Regulation,...more

New York’s Cybersecurity Requirements for DFS Licensees: A New Item at the Top of the To-Do List

With the compliance date only a few months away, licensees of the New York Department of Financial Services (DFS) must start taking action immediately to comply with the coming cybersecurity requirements, which will be more...more

New York's Cybersecurity Requirements for DFS Licensees: A New Item at the Top of the To-Do List

With a compliance date a few months away, licensees of the New York Department of Financial Services (DFS) must start taking action in response to coming cybersecurity requirements, which will be more onerous and difficult...more

Privacy & Cybersecurity Newsletter

New York’s Cybersecurity Requirements for DFS Licensees: A New Item at the Top of the To Do List - With a compliance date a few months away, licensees of the New York Department of Financial Services (DFS) must start...more

EU Cyber Security Directive (CSD) Introduces Cross Sector Data Breach Notification

The European Parliament, the Council and the Commission have agreed on the first EU-wide legislation on cybersecurity. Under the new measure, internet companies such as Google, Amazon, eBay and Cisco, but not social...more

Expect New Cybersecurity Regs from New York DFS

DFS identified several areas that would be the subject of specific requirements in the potential regulations. These include requirements for (i) cyber security policies and procedures, (ii) third-party service provider...more

NAIC Cybersecurity Bill of Rights: The Awkward New Guest at the Data Breach Law Party

On October 14, 2015, the NAIC’s Cybersecurity (EX) Task Force adopted a Cybersecurity Bill of Rights, an aspirational, well-intended document outlining the rights insurance consumers should (or could? or might? this point...more

Insurance Regulatory Bellwether: NAIC Adopts 12 Principles for Effective Cybersecurity for Regulators

The National Association of Insurance Commissioners (“NAIC”) is all over cybersecurity. On April 16, 2015, as a part of its aggressive work plan to help the insurance sector come up with an effective cybersecurity framework...more

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