Mandatory privacy breach notification, reporting and record-keeping obligations under Canada’s federal data protection law called the Personal Information Protection and Electronic Documents Act (PIPEDA) will come into force as of November 1, 2018. Earlier this year, the Canadian government published new privacy-related obligations under PIPEDA. PIPEDA applies to private-sector organizations and sets the ground rules […]
Board Governance & Cyber Risk Management
SEC Investigative Report Cautions Public Companies to Consider Cyber Threats When Implementing Internal Accounting Controls
The Securities and Exchange Commission issued an investigative report last week cautioning public companies to consider cyber incidents and threats when implementing internal accounting controls. The report details the SEC Enforcement Division’s investigations of nine public companies that were victims of cyber-related fraud schemes to determine whether the companies may have violated the federal securities […]
Alston & Bird Hosts Webinar on Binding Corporate Rules – The Benefits Go Far Beyond Data Transfers
Binding corporate rules (BCRs) are a legally recognized mechanism that facilitate intra-group transfers of personal data from the European Economic Area (EEA) to the rest of the world. Adopting BCRs not only allows for the free flow of information across an organization but also builds a strong digital culture which is crucial in this data […]
DOJ Releases “Best Practices for Victim Response and Reporting of Cyber Incidents,” Version 2.0
On September 27, 2018, the Department of Justice Computer Crime and Intellectual Property (CCIPS) Cybersecurity Unit released Version 2.0 of its “Best Practices for Victim Response and Reporting of Cyber Incidents.” Originally issued in 2015, the updated guidance seeks to help organizations better equip themselves to be able to respond effectively and lawfully to cyber […]
SEC Brings First Enforcement Action for Violation of the Identity Theft Red Flags Rule
On September 26, 2018, the SEC brought its first ever enforcement action for violations of Regulation S-ID (the “Identity Theft Red Flags Rule”), 17 C.F.R. § 248.201, in addition to violations of Regulation S-P, 17 C.F.R. 30(a) (the “Safeguards Rule”). Regulation S-ID and Regulation S-P apply to SEC-registered broker-dealers, investment companies, and investment advisers, and […]