The Belgian Supreme Court ruled in a judgment of Oct. 7, 2021 that a data subject has the right to lodge a complaint with the Data Protection Authority against a processing practice that violates the GDPR (in this case, the data minimization principle in Article 6 of the GDPR), even where the data subject’s personal […]
Board Governance & Cyber Risk Management
FTC Revises the Safeguards Rule and Proposes Mandatory Reporting of Cybersecurity Events
On October 27, 2021, the FTC released its much-anticipated final revisions to the Gramm-Leach-Bliley Safeguards Rule (Safeguards Rule or Final Rule), following a 3-2 vote along party lines and also released a notice of proposed rulemaking that would require reporting to the FTC of certain cybersecurity events. Revisions to the Safeguards Rule Effective since 2003, […]
Treasury FinCEN Releases Financial Trend Analysis of Ransomware Trends in 2021
By Kim Peretti, Brian Frey, and Kristen Bartolotta On October 15, 2021 the Financial Crimes Enforcement Network (FinCen) of the Treasury Department issued a financial trend analysis on ransomware relating to Bank Secrecy Act (BSA) reporting filed in the first half of this year. FinCEN examined ransomware-related Suspicious Activity Reports (SARs) filed between January 1 […]
Department of Justice Announces New Civil Fraud Cybersecurity Enforcement Team
On October 6, 2021, Deputy Attorney General Lisa O. Monaco announced the launch of the Department of Justice’s Civil Cyber-Fraud Initiative. The Department plans to use civil enforcement tools to “pursue…those who are government contractors who receive federal funds, when they fail to follow required cybersecurity standards.” Stating the Department will pursue “very hefty fines,” […]
China’s First Comprehensive Personal Information Protection Law – Key Takeaways
On August 20, 2021, China’s first comprehensive Personal Information Protection Law (“PIPL”) was passed into law. The Cybersecurity Law, the Data Security Law, and the PIPL of China are the three pillars of China’s data protection framework, which govern cybersecurity, data security, and personal information protection respectively. The Cybersecurity Law largely governs cybersecurity requirements for […]