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Data Breach Data Protection Information Commissioner's Office (ICO)

Dechert LLP

Dechert Cyber Bits - Issue 56

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SEC Fines the New York Stock Exchange’s Parent Company $10 million for Failure to Promptly Notify Its Subsidiaries of Cybersecurity Breach - On May 22, 2024, the Securities and Exchange Commission (“SEC”) imposed a $10...more

Thomas Fox - Compliance Evangelist

The Importance of Effective Policies and Training in Data Protection: Lessons from a Scottish Hospital Breach

I recently had the chance to visit with Jonathan Armstrong on a recent data breach case that occurred in the health service provider NHS Lanarkshire (Scotland) during the COVID-19 pandemic. This breach serves as a stark...more

Sheppard Mullin Richter & Hampton LLP

UK App Code Provides Privacy and Security Compliance Direction

The UK’s new Code of Practice for App Store Operators and App Developers provides companies with privacy-related resources. It also highlights ICO privacy expectations. Participating in the code is done by voluntarily...more

Orrick, Herrington & Sutcliffe LLP

UK Data: A New Direction – UK Government Responds to Consultation

On 16 June 2022, the UK government’s Department for Digital, Culture, Media and Sport (“the DCMS”) published its response to its Data Reform consultation. The response sets out the UK government’s key data protection reform...more

Skadden, Arps, Slate, Meagher & Flom LLP

Privacy & Cybersecurity Update - May 2022

In this month’s Privacy & Cybersecurity Update, we review Connecticut’s passage of a comprehensive privacy law (making it the fifth state to do so), the newly enacted federal Better Cybercrime Metrics Act, New York’s new law...more

Faegre Drinker Biddle & Reath LLP

Significant Changes Proposed to UK GDPR

On September 10, the U.K. government launched a consultation “Data: A New Direction” (Consultation), which proposes significant changes to the U.K.’s data protection framework. The U.K. government has signalled its...more

Orrick, Herrington & Sutcliffe LLP

Warren v DSG Retail Ltd – Shifting the Liability Landscape in Post‐Cyberattack Litigation

Since the General Data Protection Regulations ("GDPR") came into force in 2018, companies in the United Kingdom (UK) that have suffered cybersecurity attacks often face civil claims from individuals whose data has been...more

McGuireWoods LLP

CNPD vs. Amazon, the largest GDPR fine on record – what do we know so far?

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Amazon’s financial records have revealed that the Luxembourg data protection supervisory authority, the Commission Nationale pour la Protection des Données (“CNPD”), is fining the retailer’s European arm (Amazon Europe Core...more

BCLP

The Data & Brexit Digest – Drafting tips for contracts and policies

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With the UK now unambiguously out of the EU, the EU General Data Protection Regulation (2016/679) (“EU GDPR”) has been replaced by the United Kingdom General Data Protection Regulation (“UK GDPR”). In this third instalment of...more

Jones Day

Jones Day Global Privacy & Cybersecurity Update | Vol. 27

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United States - Regulatory—Policy, Best Practices, and Standard - NIST Unveils Draft Guidance to Protect Critical Infrastructure - On October 22, 2020, the National Institute of Standards and Technology ("NIST")...more

Jones Day

Jones Day Global Privacy & Cybersecurity Update | Vol. 26

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UNITED STATES - Regulatory—Policy, Best Practices, and Standards - NIST Releases Revision to Security Standard - On September 23, the National Institute of Standards and Technology ("NIST") released Revision 5 to...more

Orrick, Herrington & Sutcliffe LLP

Marriott Secures 80% Reduction in ICO Fine, but Here’s What You Missed…

Hot on the heels of the £20 million fine issued to British Airways, the Information Commissioner’s Office (“ICO“) has issued Marriott International Inc. (“Marriott“) with a long-awaited penalty notice for its failure to...more

A&O Shearman

What Might The BA And Marriott Fines Tell Us About The ICO’s Approach To Penalties?

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Few will have been surprised that, when the ICO eventually published details of the BA and Marriott fines, the final penalties were very much lower than the £183+ million and £99+ million proposed in the original notices of...more

Faegre Drinker Biddle & Reath LLP

Marriott Cyberattack Fine Reduced as ICO Shifts Penalty Policy

On 30 October 2020, the UK’s data privacy regulator, the Information Commissioner’s Office (ICO) issued a final penalty notice (Penalty Notice) to fine the hotel chain Marriott International, Inc. (Marriott) for a GDPR data...more

Morgan Lewis - Tech & Sourcing

ICO GDPR Fines Reduced to £20m and £18.4m to Reflect British Airways and Marriott Mitigating Factors

The UK Information Commissioner’s Office (ICO) has recently handed down two of the largest fines relating to a data breach in UK history. In August 2018, British Airways (BA) was subject to a cyberattack which breached the...more

Kramer Levin Naftalis & Frankel LLP

ICO and CNIL Levy Landmark Fines Against British Airways and Marriott for 2018 Data Breaches

On Oct. 30, 2020, the United Kingdom’s data protection authority, the Information Commissioner’s Office (ICO), in connection with France’s Commission nationale de l’informatique et des libertés (CNIL), announced the largest...more

Faegre Drinker Biddle & Reath LLP

British Airways Faces Significantly Reduced £20M Fine for GDPR Breach

At £20 million, the fine imposed on British Airways (BA) for its infringement of the General Data Protection Regulation is the biggest fine of its kind in the history of the U.K.’s Information Commissioner’s Office (ICO)....more

Akin Gump Strauss Hauer & Feld LLP

U.K.’s Data Protection Regulator’s Updated Guidance on “Empathetic and Pragmatic” Approach

On April 15, 2020, the Information Commissioner’s Office (ICO), the U.K.’s data protection authority, issued further guidance on its regulatory approach during the global COVID-19 pandemic. Following its March note that we...more

Jones Day

Jones Day Global Privacy & Cybersecurity Update | Vol. 25

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UNITED STATES - Regulatory—Policy, Best Practices, and Standards - Cybersecurity Standards Issued for Government Contractors - On January 31, the Office of the Under Secretary of Defense for Acquisition and...more

Orrick, Herrington & Sutcliffe LLP

ICO Fines: When Is An Appeal Appealing?

The decision to appeal a regulatory finding is never taken lightly. By the time a regulator has completed its investigation and notified a company of its intention to fine, the company will have invested significant time and...more

Shook, Hardy & Bacon L.L.P.

Privacy and Data Security Alert l January 2020

States Consider Privacy and Data Security Legislation - It’s that time of year again, when we see a flood of legislative activity at the state level on privacy and data security laws. A couple of recent examples are below....more

Jones Day

Jones Day Global Privacy & Cybersecurity Update | Vol. 24

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UNITED STATES - Regulatory—Policy, Best Practices, and Standards - FTC Submits Comment on the Preliminary Draft for the NIST Privacy Framework - On October 24, 2019, the Federal Trade Commission ("FTC") announced that...more

K&L Gates LLP

The Privacist - Volume 1

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BREXIT: DEAL OR NO-DEAL? DATA IS THE QUESTION - With the Brexit deadline looming ahead on 31 October 2019, the situation seemingly reaches new levels of uncertainty every day. Last week, the U.K. Supreme Court’s eleven...more

Epiq

Marriott Facing 124 Million GDPR Fine

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Everyone knows about the General Data Protection Regulation (GDPR). The GDPR is the EU’s new privacy regime in the region. Over a year has passed since its implementation and organizations are discovering how strict EU...more

Wilson Sonsini Goodrich & Rosati

Looking Back: The ICO’s Busy Year and Its Record-Breaking Fines

The UK Supervisory Authority (the ICO) has had a headline-busting month. On July 9, 2019, the ICO announced its intention to fine Marriott International more than £99 million under the GDPR (General Data Protection...more

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