On January 6, 2023, the FCC released a Notice of Proposed Rulemaking (the “Notice”) proposing to “modernize the Commission’s data breach rules,” and thereby launching a formal effort to gather information from the industry on the issue of data breach reporting. The Notice, adopted on December 28, 2022, seeks to strengthen its rules with the […]
Board Governance & Cyber Risk Management
CPPA Anticipates April Effective Date for CPRA Regulations
The California Privacy Protection Agency (“CPPA”) announced during its Board meeting on December 16, 2022 that the regulations implementing the California Privacy Rights Act (“CPRA”) will not likely go into effect until April 2023. CPPA Executive Direct Ashkan Soltani stated that the CPPA Staff plans to publish the final draft of the CPRA regulations in […]
European Commission Takes Significant Step Towards New Solution for Transatlantic Transfers of Personal Data
What Happened? On December 13, 2022, the European Commission (the “Commission”) took a significant step towards the adoption of the EU-U.S. Data Privacy Framework (“DPF”). The DPF is a new framework designed to replace the EU-U.S. Privacy Shield (“Privacy Shield”), which was struck down by Court of Justice of the European Union in the Schrems […]
EU Standard Contractual Clauses (SCCs) Deadline is Looming
Companies relying on the SCCs as a data transfer tool have less than a month to update their existing contracts (if they haven’t done so already). WHAT HAPPENED? The EU General Data Protection Regulation (GDPR) allows companies that want to transfer personal data protected by the GDPR to third countries outside the EU/EEA to do […]
NYDFS Releases Significant Enhancements to its Cybersecurity Regulation in the Proposed Second Amendment
The New York Department of Financial Services (“DFS”) released their proposed second amendment to the Cybersecurity Regulation, 23 NYCRR Part 500 (“Proposed Second Amendment”) on October 9, 2022. DFS issued a minor amendment on April 2, 2020, revising the certification of compliance date (from February to April). The Proposed Second Amendment follows DFS’s “pre-proposed” draft […]