For years, the Gramm-Leach-Bliley Act (GLBA) has required financial institutions to maintain reasonable safeguards for consumer data, but has only had limited breach-reporting requirements. To the extent financial institutions were subject to breach-reporting obligations, these were set by non-GLBA legislation, such as state law, or by relatively narrow incident-reporting rules under Interagency Guidelines overseen by […]
Search Results for: Cybersecurity Regulation
CISA Posts Notice of Proposed Rulemaking Under CIRCIA
On March 27, 2024, the Cybersecurity and Infrastructure Security Agency (CISA) published a notice of proposed rulemaking (NPRM) implementing the Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA). For additional background on CIRCIA, see our prior advisory. CISA is required to issue a final rule by October 4, 2025. Who is required to report covered […]
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 […]
Penn State University Hit With False Claims Act Suit for Alleged Cyber Security Deficiencies
On September 1, 2023, the U.S. District Court for the Eastern District of Pennsylvania unsealed a qui tam False Claims Act (“FCA”) lawsuit (originally filed on October 5, 2022) alleging Penn State University failed to provide “adequate security” for Covered Defense Information, as contractually required by Defense Federal Acquisition Regulation Supplement (“DFARS”) 252.204-7012. DFARS requires […]
New NAIC Consumer Privacy Model Law Proposed for Insurers
The National Association of Insurance Commissioners (NAIC) Privacy Protections Working Group (the “Working Group”) released Insurance Consumer Privacy Protection Model Law #674 (“Model 674”) for comment on February 1, 2023. Model 674 is intended to modernize and replace the Insurance Information and Privacy Protection Model Act #670 (“Model 670”) and the Privacy of Consumer Financial […]