The Advocate General’s Opinion of December 19, 2019 deemed valid the Standard Contractual Clauses (SCCs) adopted by the European Commission for the transfer of personal data from controllers to processors. Currently, many companies rely on SCCs as a mechanism for transferring personal data from the EU to non-EU countries in compliance with the GDPR. […]
Privacy & Cyber Regulatory Enforcement
Treasury Announces Sanctions Against Cybercriminal Group Behind ‘Dridex’ Malware, Offering Mitigation Strategies for Businesses
On December 5, 2019, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued sanctions against Evil Corp, a Russian cybercriminal organization that is known for distributing the Dridex malware. Dridex is a banking trojan that has been used to target financial institutions across the globe and has resulted in more than $100 million […]
Critical Audit Matters Disclosure Implicates Information Technology and Security
As independent auditors to public companies and business development companies begin to make required disclosure of Critical Audit Matters (CAMs) to the audit committee, such reports are beginning to include discussion of information security programs and information technology controls. Independent auditors have treated material weaknesses in certain information technology controls as material weaknesses in internal […]
SHIELD Act Overhauls New York’s Data Breach Notification Framework
On October 23, 2019, New York’s new breach notification provisions came into effect, a result of New York’s passage of the Stop Hacks and Improve Electronic Data Security Act (SHIELD Act) in July. That Act overhauled New York’s data privacy framework, expanding the list of data elements that are considered “private information” while growing the […]
Alston & Bird Details 21 Potentially Significant Impacts from Draft CCPA Regulations
Late last week, the Californa Attorney General published much-anticipated proposed Regulations under the California Consumer Privacy Act (“CCPA”). The Regulations are extensive and contain a number of potentially material business impacts. To help companies work through the Regulations, Alston & Bird’s Privacy & Data Security team published a client advisory outlining “21 Potentially Significant […]