The New York Department of Financial Services (NYDFS) continues to refine its position regarding the importance of and requirements regarding Multi-Factor Authentication (MFA), as evidenced most recently with the release of new guidance. This new guidance is consistent with its June guidance, in which NYDFS clarified its expectation that NYDFS-regulated covered entities subject to 500.12 […]
Data Protection
China’s Initial Draft Regulations on the Management of Online Data Security: Important Takeaways
On November 14, 2021, the Cyberspace Administration of China (CAC) released draft Regulations on the Management of Online Data Security (the “Regulations”) for China’s data privacy and security laws, including the Cybersecurity Law (CSL), Data Security Law (DSL), and Personal Information Protection Law (PIPL). Consistent with such laws, the Regulations broadly apply to processing […]
Federal Bank Regulatory Agencies Release Final Rule to Require Notification of Cyber Incidents
On November 18, 2021, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation jointly announced the approval of a final rule to improve the sharing of information about cyber incidents that may affect the U.S. banking system. The rule applies to […]
EDPB issues draft guidelines on the interplay between the GDPR’s provisions on territorial scope and international data transfers
On November 18, the European Data Protection Board (“EDPB”) released draft guidelines on the interplay between Article 3 GDPR – which sets out the GDPR’s territorial scope – and the provisions in Chapter V of the GDPR, which impose restrictions on international data transfers. In this draft guidance, the EDPB clarifies which (cumulative) criteria must […]
Belgian Supreme Court rules that Data Protection Authority may impose administrative fines even where a data subject’s personal data were not processed
The Belgian Supreme Court ruled in a judgment of Oct. 7, 2021 that a data subject has the right to lodge a complaint with the Data Protection Authority against a processing practice that violates the GDPR (in this case, the data minimization principle in Article 6 of the GDPR), even where the data subject’s personal […]