Alston & Bird Senior Counsel Peter Swire recently published an article in Lawfare titled, “Towards OECD Principles for Government Access to Data.” Peter and his co-authors discuss recent efforts of the Organization for Economic Cooperation and Development (OECD) to formulate common principles regulating governmental access to personal data held by the private sector for national […]
Privacy & Cyber Regulatory Enforcement
Update: FTC Amendments to the Safeguards Rule and Request for Comment on Proposed Reporting Requirement Published to the Federal Register
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 […]
NYDFS Issues Guidance on Multi-Factor Authentication
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 […]
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 […]