Just a month before the Security and Exchange Commission’s (“SEC’s”) Material Cybersecurity Incidents Rule is set to take effect, a ransomware group has apparently taken compliance with reporting requirements into its own hands. On November 15, 2023, the ransomware group known as BlackCat (also known as “AlphV”) posted a notice on its leak site alleging […]
Crisis & Data Breach Response
FTC Approves New Data Breach Notification Requirement for Non-Banking Financial Institutions
On October 27, 2023, the FTC approved an amendment to the Safeguards Rule (the “Amendment”) requiring that non-banking financial institutions notify the FTC in the event of a defined “Notification Event” where customer information of 500 or more individuals was subject to unauthorized acquisition. The Amendment becomes effective 180 days after publication in the […]
New York Continues to Focus on Companies’ Data Security Practices
New York Attorney General Letitia James recently announced two agreements related to data breaches with entities that operate in the education industry. In both instances the entities paid the ransom and received evidence of deletion of the stolen data. Most recently, on October 5, 2023 the Office of the Attorney General (OAG) announced a $49.5 […]
CL0P Ransomware Gang’s Exploitation of MOVEit Vulnerability: What It Means for Companies
On June 7, 2023, the Federal Bureau of Investigation (FBI) and the Cybersecurity and Infrastructure Security Agency (CISA) released a Joint Cybersecurity Advisory in connection with a recent zero-day (or previously undetected) vulnerability in Progress Software’s managed file transfer software (MOVEit Transfer), exploited by the CL0P ransomware group. CL0P publicly claimed responsibility for exploiting the […]
International Data Transfers: Lessons from the EDPB’s “101 Task Force”
In August 2020, privacy activist organization NOYB – European Center for Digital Rights filed 101 complaints with the EU Supervisory Authorities (‘SAs’) in connection with the transfer of personal data from Europe to the U.S., by companies that had implemented “Google Analytics” and “Facebook Business Tools” on their websites. Following these complaints, the European Data […]