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The Department of Commerce announced the approval of the United States’ participation in the Asia-Pacific Economic Cooperation Cross-Border Privacy Rules system (CBPR). The CBPR promotes “a baseline set of data privacy practices for companies doing business in participating APEC economies. The goal of the system is to enhance electronic commerce, facilitate trade and economic growth, and strengthen […]

On June 26, 2012, the Federal Trade Commission (“FTC”) filed a complaint in federal district court in Arizona against Wyndham Worldwide Corporation and three subsidiaries (“Wyndham”) alleging that the company’s failure to adequately safeguard customers’ personal information led to millions of dollars in losses to fraud. The FTC complaint alleges that repeated security failures exposed customers’ […]

This afternoon, Senators John McCain (R-AZ), Kay Bailey Hutchison (R-TX), Chuck Grassley (R-IA), Saxby Chambliss (R-GA), Lisa Murkowski (R-AK), Dan Coats (R-IN), Ron Johnson (R-WI), and Richard Burr (R-NC) reintroduced the Strengthening and Enhancing Cybersecurity by Using Research, Education, Information, and Technology (SECURE IT) Act, which now bears the number S. 3342. As outlined in […]

Despite recent indications from HHS and the Director of HHS’s Office for Civil Rights (OCR) that the HIPAA/HITECH Act Omnibus Final Rule is extremely close to publication, the White House’s Office of Management and Budget (OMB) has extended its review of the rule under Executive Order 12866. As we recently commented, in a report published […]

In what appears to be a growing trend, Vermont and Connecticut have added a requirement to separately notify the states’ Attorney General’s office of a data breach involving the personal information of Vermont and Connecticut residents. Last year, California amended its data breach notification statute with a similar requirement.   Vermont’s amended Security Breach Notification […]