On May 1, 2023, bitFlyer USA, Inc. (“bitFlyer”) entered into a Consent Order with the New York Department of Financial Services (“DFS”) for multiple deficiencies in bitFlyer’s cybersecurity program, most notably for failure to conduct periodic risk assessments to sufficiently inform the design of bitFlyer’s cybersecurity program (as required by 23 NYCRR § 500.09(a)). BitFlyer […]
cybersecurity
FCC Proposes to Change Data Breach Reporting Rules for Telecommunication Companies
On January 6, 2023, the FCC released a Notice of Proposed Rulemaking (the “Notice”) proposing to “modernize the Commission’s data breach rules,” and thereby launching a formal effort to gather information from the industry on the issue of data breach reporting. The Notice, adopted on December 28, 2022, seeks to strengthen its rules with the […]
European Parliament Adopts “NIS2” Cybersecurity Directive
On November 10, 2022, the European Parliament adopted a new cybersecurity directive (the “NIS2 Directive”), which is designed to replace and repeal the existing EU Directive on the Security of Network and Information Systems (Directive 2016/1148/EC) (the “NIS Directive”). The objective of the NIS2 Directive is to achieve a higher level of cybersecurity within the EU […]
UK’s National Cyber Security Centre Releases 2022 Annual Review
The United Kingdom’s National Cyber Security Centre (NCSC) recently released its 2022 Annual Review, which reports on the state of cyber security threats in the country. As the UK’s technical authority for cyber security, the NCSC releases an annual report covering the cyber threats from the prior 12 months as well as analysis of potential […]
Recent FTC Order Has Implications for Executive Liability and Corporate Data Minimization Practices
On October 24, 2022, the Federal Trade Commission (“FTC”) announced a proposed consent order against both Drizly LLC, an online marketplace for alcohol delivery, and its CEO over the company’s alleged security failures that led to a data breach in 2020, which exposed the personal information of approximately 2.5 million Drizly customers. Drizly and its […]