News & Analysis as of

Personal Information Cybersecurity Gramm-Leach-Blilely Act

Foley & Lardner LLP

Rolling With the Punches in a Networked World: CCOE Cybersecurity Panel Discussion

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Whether the game is football, baseball, hockey, or Indy Car racing, no team goes into their major championship matchup without training. Companies need to train as well if they intend to operate on the internet and expect to...more

Davis Wright Tremaine LLP

SEC Adopts Amendments to Regulation S-P That Require Reporting Breaches of "Sensitive Customer Information"

On May 15, the Securities and Exchange Commission adopted amendments to Regulation S-P, which covers broker-dealers, registered investment advisors (RIAs), and investment companies (funds). These entities are now required to...more

Troutman Pepper

Nebraska Enacts Comprehensive Privacy Law

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On April 12, Nebraska Governor Jim Pillen signed Legislative Bill 1074 into law, making Nebraska the 16th U.S. state to enact a comprehensive privacy law. The Nebraska Data Privacy Act (NEDPA) will take effect on January 1,...more

Paul Hastings LLP

New Jersey Privacy Act Kicks off New Year with New Comprehensive State Privacy Law

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Earlier this month New Jersey became the thirteenth state to pass a comprehensive privacy law aimed at protecting residents’ personal information and starting a new round of comprehensive state privacy laws providing such...more

Troutman Pepper

More Privacy, Please - September/October 2023

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Editor’s Note: The FTC continues to crack down on privacy and cybersecurity, including issuing a new warning to tax preparation companies and entering into a consent decree with 1Health.io. VPPA and BIPA litigation continues...more

Cooley LLP

FTC Adds New Data Breach Reporting Obligations Under Safeguards Rule

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On October 27, 2023, the Federal Trade Commission (FTC) unanimously approved an amendment to the Gramm-Leach-Bliley Act (GLBA) Safeguards Rule to require certain covered financial institutions to report a broad range of data...more

Constangy, Brooks, Smith & Prophete, LLP

FTC Non-Banking Financial Institutions Safeguards Rule

The Federal Trade Commission has approved an amendment to the Safeguards Rule under the Gramm-Leach-Bliley Act that creates a new data privacy regulatory reporting requirement for non-banking financial entities. Covered...more

Jones Day

FTC Requires Non-Bank Financial Institutions to Report Data Security Breaches Under Amended Safeguards Rule

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On Friday, October 27, the Federal Trade Commission ("FTC") announced new amendments to the Safeguards Rule, requiring covered financial institutions to report certain data breaches to the FTC and reflecting its continuing...more

Holland & Knight LLP

A New General Notice Requirement for Financial Institutions

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The Federal Trade Commission (FTC) on Oct. 27, 2023, announced further amendments to the Gramm-Leach-Bliley Safeguards Rule (Safeguards Rule). The Safeguards Rule became effective in 2003, requiring certain financial...more

Jackson Lewis P.C.

Federal Trade Commission Expands Rule Regarding Reporting of Data Security Breaches

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The Federal Trade Commission (FTC) has approved an amendment to its Safeguards Rule that will require non-banking financial institutions to report certain data breaches (or “notification events”) to the FTC (not affected...more

White & Case LLP

Tennessee Passes Comprehensive Data Privacy Law

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On May 11, 2023, Governor Bill Lee signed the Tennessee Information Protection Act (TIPA) into law. Tennessee now joins the rapidly increasing group of states, California, Utah, Colorado, Connecticut, Virginia, Iowa and...more

Dechert LLP

SEC Proposes Robust Amendments to Regulation S-P

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At an open meeting on March 15, 2023, the U.S. Securities and Exchange Commission voted unanimously to propose rule amendments to Regulation S-P (Proposed Rule) and published an accompanying release (Release). The Proposed...more

Spilman Thomas & Battle, PLLC

Cybersecurity Rules and Colleges – Approaching Deadline

With only four months left before most changes to the federal Standards for Safeguarding Customer Information (“Safeguards Rule”) – a component of the Gramm-Leach Bliley Act (“GLBA”) that provides for the protection of...more

J.S. Held

Data Privacy in 2023: Expectations, Responsibilities & Cyber Security Tactics to Safeguard Your Information

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INTRODUCTION - As more of our lives and work become digitized, an inherent overlap continues to grow between data privacy and cyber security programs. Think of two similarly sized circles: in the past, data privacy and cyber...more

Katten Muchin Rosenman LLP

December 9 Looms as Compliance Date for Private Investment Funds and Certain Investment Advisers to Comply With New Cybersecurity...

Additional Requirements to Go Into Effect June 9, 2023 - As we discussed in our March 3 Advisory, on October 27, 2021, the Federal Trade Commission (FTC) announced revisions (the 2021 Revisions) to its information...more

Shutts & Bowen LLP

Changes to GLBA Safeguards Rule Affect More Than Traditional Financial Institutes

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The Gramm-Leach-Bliley Act (“GLBA”) was a bi-partisan regulation passed by Congress in 1999 in an attempt to update and modernize the financial industry. One component of the GLBA, its Safeguards Rule, requires financial...more

Hudson Cook, LLP

The FTC's Sweeping Changes to the Safeguards Rule - Time to Reexamine Your Information Security Program

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On October 27th, the Federal Trade Commission (“FTC”) finalized its long-awaited updates to the Safeguards Rule. The Safeguards Rule implements provisions of the Gramm-Leach-Bliley Act requiring the safeguarding of customer...more

Hinshaw & Culbertson - Privacy, Cyber & AI...

FTC Overhauls Safeguards Rule Regarding Customer Information Applicable to Auto-Dealers and Other "Financial Institutions"

On October 27, 2021, the FTC announced that it intends to publish (1) a final rule to amend the Standards for Safeguarding Customer Information (Safeguards Rule); (2) a supplemental notice and request for public comment on...more

Morgan Lewis

Expanded Safeguards Rule Applicable to More Financial Institutions; Gives More Specificity on Security Requirements

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The Federal Trade Commission recently finalized a long-discussed update to its cybersecurity Safeguards Rule that includes more specific criteria for what financial institutions must implement as part of their information...more

WilmerHale

FTC Finalizes Financial Institution Safeguards Rule

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On October 27, 2021, the Federal Trade Commission (FTC) announced a newly updated rule under the Gramm-Leach-Bliley Act (GLBA) intended to require financial institutions to strengthen their data security safeguards to protect...more

Hogan Lovells

New York State Expected to Increase Enforcement of Cybersecurity Practices

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Companies should take note of two imminent developments in New York in the area of cybersecurity regulation: enforcement of the New York Department of Financial Services (NYDFS) Cybersecurity Regulation (Regulation) and the...more

McDermott Will & Emery

CCPA and ‘Reasonable Security’: A Game Changer

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On January 1, 2020, the California Consumer Privacy Act of 2018 (CCPA) went into effect. The CCPA applies to a wide range of companies and broadly governs the collection, use and sale of personal information of California...more

Jackson Lewis P.C.

Professional Tax Preparers – You Need A Written Information Security Plan, Say The IRS And FTC

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Tax season will soon be upon us and many not-so-eager taxpayers will share sensitive personal information about themselves, their dependents, their employees, and others with their trusted professional tax preparers for...more

White and Williams LLP

Employers: New York’s SHIELD Act Imposes Data Security Requirements on Companies Outside of New York, Too

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New York’s recently enacted Stop Hacks and Improve Electronic Data Security Act (SHIELD Act) enhances data breach notification requirements and requires covered organizations to “develop, implement and maintain” a...more

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