On December 28, 2018, the Department of Health and Human Services (HHS) issued new voluntary cybersecurity guidance for the health care industry titled, “Health Industry Cybersecurity Practices: Managing Threats and Protecting Patients.” This four-volume set of consensus-based principles and practices (the “HICP”) reflects the recommendations of the 405(d) Task Group, a HHS and industry-led collaborative […]
Data Security
Michigan Enacts Insurance Data Security Model Law
Michigan enacted the Michigan Data Security Act on December 28, 2018, imposing stringent cybersecurity measures on any person (individual or corporate) licensed by the Michigan Department of Insurance and Financial Services. Based on the 2017 NAIC data security model law and nearly identical to the South Carolina Insurance Data Security Act, the Michigan statute will […]
South Carolina Insurance Data Security Law Now Effective
South Carolina’s prescriptive data security law for insurers took effect on January 1, 2019. Subject to specified exemptions, the law requires any person licensed pursuant to South Carolina insurance laws to take certain steps, including among other things notification of specified cybersecurity events to the South Carolina Department of Insurance. Covered persons are also required […]
FTC Publishes Report Regarding Privacy Workshop
In October 2018, the Federal Trade Commission (“FTC”) published a report that summarized discussions at a December 2017 workshop discussing the potential impact to consumers of privacy and security incidents. The purpose of the workshop was to explore whether government intervention in this arena is warranted under the enforcement authority granted to the FTC under […]
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 […]