September 4, 2018 marks the end of the transitional period for covered entities to comply with several key provisions of the NYDFS Cybersecurity Requirements that require certain systemic and sustained measures. These provisions include the encryption and audit trail requirements as well as ones relating to the implementation of monitoring policies, procedures, and controls, application […]
CFPB Changes Annual Notice Requirement Under Reg. P
On Friday, the Consumer Financial Protection Bureau announced its “finalized amendments” to Regulation P, an implementing regulation of the federal financial Gramm Leach Bliley Act. Regulation P governs the provision of privacy notices for covered financial institutions. In response to legislation passed by Congress in late 2015, the final rule issued Friday permits financial institutions […]
Alston & Bird Hosts Sept. 12 Webinar on California Consumer Privacy Act
Save the date! On Sept. 12, 1 – 2 PM ET, Alston & Bird will host a webinar to analyze the new California Consumer Privacy Act. (You can read our prior advisory.) The California Consumer Privacy Act has been compared to the European Union’s General Data Protection Regulation due to its creation of important new privacy […]
LabMD: The End of the FTC in Cyber or Just a New Path?
The U.S. Court of Appeals for the Eleventh Circuit recently issued its opinion in LabMD, Inc. v. FTC, No. 16-16270 (11th Cir. June 6, 2018), declaring unenforceable a Federal Trade Commission (FTC) order requiring LabMD to implement an extensive cybersecurity plan. The case is noteworthy for its lengthy procedural background—during which time LabMD became defunct—and its holding, which […]
European Parliament Calls to Suspend Privacy Shield
On the heels of the Committee on Civil Liberties, Justice and Home Affairs’ (LIBE) recent resolution, the full European Parliament on July 5 adopted a resolution calling for the suspension of the EU-U.S. Privacy Shield agreement if the U.S. fails to comply in full by September 1, 2018. With a vote of 303 in favor […]