On October 31, 2022, the Federal Trade Commission (FTC) announced it has taken action against education technology provider Chegg Inc. (“Chegg”) for its “careless” cybersecurity practices that exposed sensitive personal information of millions of its customers and employees. This action highlights the FTC’s continued efforts to aggressively protect consumer personal data. The FTC’s complaint alleges […]
Crisis & Data Breach Response
Recent FTC Order Has Implications for Executive Liability and Corporate Data Minimization Practices
On October 24, 2022, the Federal Trade Commission (“FTC”) announced a proposed consent order against both Drizly LLC, an online marketplace for alcohol delivery, and its CEO over the company’s alleged security failures that led to a data breach in 2020, which exposed the personal information of approximately 2.5 million Drizly customers. Drizly and its […]
NYDFS Announces Significant Cybersecurity Settlement with EyeMed Vision Care
On October 18, 2022, EyeMed Vision Care LLC (“EyeMed”) entered into a Consent Order with the New York Department of Financial Services (“DFS”) relating to a cybersecurity event from 2020 that exposed consumer nonpublic information (“NPI”) to an unauthorized individual. EyeMed agreed to pay DFS a $4.5 million penalty, in addition to implementing mandatory remediation […]
CISA Issues Request for Information Prior to Required CIRCIA Rulemaking
On September 12, 2022, the Cybersecurity and Infrastructure Security Agency (CISA) issued a request for information (RFI) seeking input from stakeholders on the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA). Signed by President Biden in March, CIRCIA requires CISA to develop and implement regulations requiring covered entities to report information about covered […]
UK Information Commissioner’s Office Issues Warning on Ransomware Payments
On July 8, 2022, the UK Information Commissioner’s Office (UK ICO) together with the UK National Cyber Security Centre (NCSC), published a joint letter asking the Law Society of England & Wales to remind its members that they should not advise clients to pay ransomware demands should they fall victim to a cyber-attack. The Law […]