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Enforcement

Update: FTC Amendments to the Safeguards Rule and Request for Comment on Proposed Reporting Requirement Published to the Federal Register

December 15, 2021 By Kim Peretti, Kathleen Benway, Kate Hanniford and Kristen Bartolotta

As an update to prior coverage of the FTC’s final revisions to the Gramm-Leach-Bliley Safeguards Rule (Final Rule), following its publication in the Federal Register on December 9, 2021, the Final Rule now will take effect on January 8, 2022, 30 days after publication in the Federal Register. Revisions to the Final Rule include an […]

Filed Under: Cyber Risk, Cybersecurity, Data Security, Enforcement

NYDFS Issues Guidance on Multi-Factor Authentication

December 14, 2021 By Kim Peretti, Kate Hanniford and Kristen Bartolotta

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 […]

Filed Under: Cybersecurity, Data Protection, Data Security, Enforcement, NYDFS Tagged With: cybersecurity

Federal Bank Regulatory Agencies Release Final Rule to Require Notification of Cyber Incidents

November 22, 2021 By Kate Hanniford and Kristen Bartolotta

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 […]

Filed Under: Cybersecurity, Data Breach, Data Protection, Data Security, Enforcement, Regulation, Security Breach Tagged With: Data Breach Notification

Belgian Supreme Court rules that Data Protection Authority may impose administrative fines even where a data subject’s personal data were not processed

November 2, 2021 By Yung Shin Van Der Sype, Paul Greaves and Wim Nauwelaerts

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 […]

Filed Under: Belgium, Data Protection, Enforcement, GDPR, International, Privacy Tagged With: Belgium, Data Protection

FTC Revises the Safeguards Rule and Proposes Mandatory Reporting of Cybersecurity Events

November 1, 2021 By Kathleen Benway, Kim Peretti and Kate Hanniford

On October 27, 2021, the FTC released its much-anticipated final revisions to the Gramm-Leach-Bliley Safeguards Rule (Safeguards Rule or Final Rule), following a 3-2 vote along party lines and also released a notice of proposed rulemaking that would  require reporting to the FTC of certain cybersecurity events. Revisions to the Safeguards Rule Effective since 2003, […]

Filed Under: Cyber Risk, Cybersecurity, Data Security, Enforcement, FTC

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