On March 2, the federal Consumer Financial Protection Bureau (CFPB) for the first time brought an enforcement action related to data security. The CFPB consent order imposes a $100,000 fine and five years of regulatory oversight for online payments provider Dwolla. The action sends a clear message that the CFPB intends to actively regulate the […]
Board Governance & Cyber Risk Management
WP 29 Issues Statement on EU-U.S. Privacy Shield
On the same day that the European Commission debuted the EU-U.S. Privacy Shield, the Article 29 Working Party (WP29) issued a statement welcoming the publication of the draft “adequacy decision” of the European Commission as well as the legal texts that constitute the Privacy Shield arrangement. In accordance with its mission, WP29 said that it would […]
European Commission Debuts EU-U.S. Privacy Shield
In a development eagerly anticipated by businesses on both sides of the Atlantic, the European Commission has published the legal instruments needed to put in place the “EU-U.S. Privacy Shield” for transfers of personal data from Europe to the United States. The issued documents include a draft adequacy decision by the Commission finding that the […]
HHS Issues HIPAA Security Rule Crosswalk with NIST Cybersecurity Framework
Last week, the HHS Office for Civil Rights (OCR) released a crosswalk between the requirements of the HIPAA Security Rule and the NIST Cybersecurity Framework. The crosswalk – which was developed in conjunction with the National Institute of Standards and Technology (NIST) and the HHS Office of the National Coordinator for Health IT – maps each […]
SEC Continues to Focus on Cyber-related Disclosures
Participating in a panel at the “SEC Speaks” event on February 19, Deputy Director of the SEC’s Enforcement Division Stephanie Avakian expressed that the Commission continues to focus on cybersecurity as a top priority in 2016. Avakian discussed the Commission’s cybersecurity concerns in three contexts: (1) failure of registered entities to follow Rule 30(a) of […]