News & Analysis as of

Personal Information Data Breach Gramm-Leach-Blilely Act

Dechert LLP

SEC Adopts First Major Amendments to Regulation S-P Since 2000

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Incident Response Plans and Written Information Security Programs Continue to be Essential and Will Need to Be Reviewed. Most sophisticated organizations currently have in place incident response plans. Those organizations...more

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

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

Cooley LLP on

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

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

Dechert LLP

SEC Proposes Robust Amendments to Regulation S-P

Dechert LLP on

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

Genova Burns LLC

DoorDash Hacker Incident Illustrates Third-Party Vendor Risks and Potential Vulnerabilities

Genova Burns LLC on

​​​​​​​Hackers have increasingly focused on third-party vendors as avenues to data held by associated businesses. On August 25, 2022, DoorDash announced that it had experienced a data breach which impacted the personal...more

Foley & Lardner LLP

State Data Breach Notification Laws - March 2022

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While most state data breach notification statutes contain similar components, there are important differences, meaning a one-size-fits-all approach to notification will not suffice. What’s more, as data breaches continue to...more

Morgan Lewis

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

Morgan Lewis on

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

Oberheiden P.C.

5 Keys to Performing A GLBA Audit

Oberheiden P.C. on

Purpose and Background of the GLBA - The Gramm-Leach-Bliley Act (“GLBA”), also known as the Financial Services Modernization Act of 1999, is a federal statute enacted by Congress in 1999 that requires financial...more

Foley & Lardner LLP

State Data Breach Notification Laws - September 2020

Foley & Lardner LLP on

While most state data breach notification statutes contain similar components, there are important differences, meaning a one-size-fits-all approach to notification will not suffice. What’s more, as data breaches continue to...more

BCLP

Data Breach Litigation Preparation: What U.S. Laws Apply to Data Breaches?

BCLP on

As of January 1, 2020, California became the first state to permit residents whose personal information is exposed in a data breach to seek statutory damages between $100-$750 per incident, even in the absence of any actual...more

McDermott Will & Emery

CCPA and ‘Reasonable Security’: A Game Changer

McDermott Will & Emery on

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

BCLP

Do Companies Need a Written Security Information Plan?

BCLP on

As of January 1, 2020, California became the first state to permit residents whose personal information is exposed in a data breach to seek statutory damages between $100-$750 per incident, even in the absence of any actual...more

BCLP

CCPA Security FAQs: Does the CCPA open financial institutions to increased litigation?

BCLP on

Yes. While the CCPA provides a partial exemption for information collected by financial institutions that is subject to the Gramm Leach Bliley Act (e.g., information about individuals who have obtained personal financial...more

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