After a three-year investigation/enforcement action by the New York Department of Financial Services (“NYDFS”), NYDFS entered into a Consent Order with a large title insurer (the “Company”) for its violation of NYDFS’s Cybersecurity Regulation (23 NYCRR Part 500) (the “Regulation”), specifically, its failure to protect non-public information (“NPI”). NYDFS originally brought the enforcement action in […]
Privacy & Cyber Regulatory Enforcement
FCC Plans to Update Data Breach Notification Rules
After a decade and a half under the current data breach notification rules for telecommunications carriers and telecommunications relay services (TRS) providers, the FCC recently unveiled plans to update and expand them. On November 22, 2023, the FCC issued a Report and Order that it intends to consider at its December 13th meeting that would […]
Companies Prepare for Change as EU Legislators Agree on EU Artificial Intelligence Act
On December 8, 2023, following marathon negotiations, European Union (‘EU’) legislators reached a political agreement on the much-anticipated EU Artificial Intelligence Act (‘AI Act’). The AI Act is billed as the first comprehensive legal framework on AI systems worldwide, and will impose obligations on both private and public sector actors which develop, import, distribute, or […]
CPPA Publishes Revised Cybersecurity Audit Regulations in Advance of Board Meeting
On December 8, 2023, the California Privacy Protection Agency (CPPA) will hold a board meeting seeking public comment on various privacy regulations. The meeting, which will take place on Zoom, will cover several topics listed in its published agenda. The New CPRA Rules Subcommittee will provide an update and present on the Draft Regulations on […]
Colorado AG Publishes Shortlist of Universal Opt-Out Mechanisms
On November 21, 2023, the Colorado Attorney General (the “AG”) published a shortlist of potential universal opt-out mechanisms (“UOOMs”) that the AG is considering recognizing as binding under the Colorado Privacy Act (the “CPA”). Beginning on July 1, 2024, the CPA will require covered controllers to comply with Colorado consumers’ requests to opt out of […]