On October 18, 2022, EyeMed Vision Care LLC (“EyeMed”) entered into a Consent Order with the New York Department of Financial Services (“DFS”) relating to a cybersecurity event from 2020 that exposed consumer nonpublic information (“NPI”) to an unauthorized individual. EyeMed agreed to pay DFS a $4.5 million penalty, in addition to implementing mandatory remediation […]
Board Governance & Cyber Risk Management
Heavier Breach Notification Obligations for U.S. Companies Subject to the EU GDPR According to Proposed Regulatory Guidance from the EDPB
On October 18, 2022, the European Data Protection Board (“EDPB”) published a proposed updated version of its regulatory guidance on personal data breaches under the EU GDPR (the “Proposed Updated Guidance”). The Proposed Updated Guidance seeks to place heavier personal data breach notification obligations on controllers established in the U.S. (and other non-EU countries) but […]
The White House Introduces new Blueprint for an AI Bill of Rights
On October 4, 2022, the White House Office of Science and Technology released the Blueprint for an AI Bill of Rights (the Bill) to guide the development and use of artificial intelligence (AI) in the United States. The White House recognized that while AI is a powerful driver of innovation, the technology can also be […]
SEC Sends a Message to Investment Advisers: Take Secure Data Disposal Seriously
On September 20, 2022, the Securities and Exchange Commission (SEC) settled an enforcement action with a large, registered investment adviser (the Firm) for alleged violations of the Safeguards Rule and the Disposal Rule of Regulation S-P that arose in the context of a data disposal process, imposing a $35 million penalty. Specifically, the SEC […]
NHTSA Updates its Guidance on Cybersecurity Best Practices for the Safety of Modern Vehicles
On September 7, 2022 the U.S. Department of Transportation’s National Highway Traffic Safety Administration (NHTSA) released an updated edition of its Cybersecurity Best Practices for the Safety of Modern Vehicles, the last edition of which was published in 2016. This most recent edition of this non-binding guidance leverages agency research, industry voluntary standards, and […]