In late December 2024, the New York Governor signed two bills (S2659B and S2376B) amending the state’s data breach notification law (N.Y. Gen. Bus. Law § 899-aa), to expand the definition of reportable personal information and impose new covered entity reporting obligations in the event of a data breach. Effective immediately, companies will have 30 […]
Board Governance & Cyber Risk Management
UK’s National Cyber Security Centre Releases 2024 Annual Review
The United Kingdom’s National Cyber Security Centre (NCSC) has released its Annual Review for 2024. As in prior years, the report covers the UK’s cyber security position, both in terms of threats to the public and private sectors, as well as the country’s readiness to deal with those threats. Unsurprisingly, the NCSC notes that the […]
The D.C. Circuit’s TikTok Decision Could Portend Greater Regulation of Chinese-Owned Apps
On December 6, 2024, the United States Court of Appeals for the D.C. Circuit upheld the constitutionality of the Protecting Americans from Foreign Adversary Controlled Applications Act (“Act”). The Act, signed into law by President Biden on April 24, 2024, prohibits the “distribution or maintenance” in the U.S. of applications controlled by ByteDance, TikTok’s China-based […]
Department of Homeland Security Releases Recommended Framework for AI in Critical Infrastructure
On November 14, 2024, the Department of Homeland Security (“DHS”) announced a set of voluntary recommendations called the “Roles and Responsibilities Framework for Artificial Intelligence in Critical Infrastructure” (“Framework”). Recognizing the severe consequences associated with disruption to the nation’s critical infrastructure, DHS released the framework to address certain risks associated with the use of AI […]
Summary of Changes from DoD CMMC Proposed Rule to Final Rule
On October 11, 2024, the Department of Defense (“DoD”) issued its Final Program Rule for the Cybersecurity Maturity Model Certification (“CMMC”) Program. The Final Rule is a signal to federal contractors to develop compliance programs pertaining to CMMC in advance of the implementation of CMMC (likely next year). The CMMC program is designed to ensure […]