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 […]
Privacy & Cyber Regulatory Enforcement
California Privacy Protection Agency Releases Draft Regulations on Risk Assessments
On August 28, 2023, the California Privacy Protection Agency (the “Agency”) released two sets of draft regulations under the California Consumer Privacy Act (the “CCPA”), one for risk assessments and another for cybersecurity audits, as part of the Agency’s informal rulemaking process. We discuss the draft cybersecurity audits in California Proposes Annual Audits to Assess […]
California Proposes Annual Audits to Assess Sufficiency and Compliance of Company Cybersecurity
In late August 2023, the California Privacy Protection Agency (“CPPA” or “Agency”) released a discussion draft of proposed regulations under California’s data privacy law, the California Consumer Privacy Act (“CCPA”). Importantly, the proposed regulations set forth more detailed obligations for company cybersecurity programs, including routinely assessing and filing audits with the CPPA. Though these draft […]
Oregon Enacts Comprehensive State Privacy Law
On July 18, 2023, Oregon Governor Tina Kotek signed the Oregon Consumer Privacy Act (SB 619)(“OCPA”) into law, making Oregon the eleventh state to enact a comprehensive state privacy law. OCPA will take effect on July 1, 2024, however the effective date for covered non-profits is delayed until July 1, 2025. While OCPA aligns with […]
NIST Cybersecurity Framework 2.0 Released for Public Comment
On August 8, 2023, the National Institute of Standards and Technology (NIST) released the initial draft of its Cybersecurity Framework 2.0 and draft Implementation Examples for public comment. This marks the first significant update to the NIST Cybersecurity Framework (“Framework”) since its initial release in 2014, which is intended to address current and future cybersecurity […]