Entities registered with the U.S. Securities & Exchange Commission (SEC) must maintain certain books and records and can be subject to the SEC’s examination, inspection, and enforcement authority. Responding to SEC requests can require cross-border transfers of personal data, and this has historically risked non-compliance under foreign data protection law. The SEC has been proactive […]
Board Governance & Cyber Risk Management
Biden Administration To Issue Cybersecurity “Performance Goals” For Critical Infrastructure
Yesterday, the Biden Administration issued a National Security Memorandum on Improving Cybersecurity for Critical Infrastructure Control Systems (“Memorandum”). A short summary is below. However, the primary take away is that the government will be establishing preliminary cybersecurity performance goals for certain industries no later than September 2021. While we do not yet know what these […]
Securities Class Actions Filed Against Three Chinese Tech Titans After Announcement of Cyber-Related Investigations
In early July, investigations by a Chinese cybersecurity regulatory agency, the Cyberspace Administration of China (“CAC”), into at least three China-based technology companies—DiDi Global Inc. (“DiDi”), Full Truck Alliance Co. Ltd. (“FTA”), and Kanzhun Limited (“Kanzhun”)—were purportedly revealed weeks after each conducted a substantial initial public offering (“IPO”) on a United States stock exchange. These […]
EDPB publishes Guidelines on the Concepts of Controller and Processor in the GDPR
On July 7th, the European Data Protection Board (“EDPB”) adopted its finalized guidelines on the concepts of controller and processor in the General Data Protection Regulation (“GDPR”). While the EDPB’s predecessor – the Article 29 Working Party – had issued guidance on the concepts of controller/processor (Opinion 1/2010, WP169) back in 2010, many practical concerns […]
U.S. Government Launches StopRansomware.gov
On July 15, 2021, the DOJ and DHS together with additional federal partners launched StopRansomware.gov, a one-stop hub intended to help the private and public sector mitigate the threat of ransomware. The website includes a range of resources geared towards private organizations, public and private critical infrastructure sectors, K-12 educational institutions, and state, local, tribal, […]