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 […]
Cybersecurity
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 […]
Heavier Breach Notification Obligations for U.S. Companies Subject to the EU GDPR According to Proposed Regulatory Guidance from the EDPB
On October 18, 2022, the European Data Protection Board (“EDPB”) published a proposed updated version of its regulatory guidance on personal data breaches under the EU GDPR (the “Proposed Updated Guidance”). The Proposed Updated Guidance seeks to place heavier personal data breach notification obligations on controllers established in the U.S. (and other non-EU countries) but […]
SEC Sends a Message to Investment Advisers: Take Secure Data Disposal Seriously
On September 20, 2022, the Securities and Exchange Commission (SEC) settled an enforcement action with a large, registered investment adviser (the Firm) for alleged violations of the Safeguards Rule and the Disposal Rule of Regulation S-P that arose in the context of a data disposal process, imposing a $35 million penalty. Specifically, the SEC […]
NHTSA Updates its Guidance on Cybersecurity Best Practices for the Safety of Modern Vehicles
On September 7, 2022 the U.S. Department of Transportation’s National Highway Traffic Safety Administration (NHTSA) released an updated edition of its Cybersecurity Best Practices for the Safety of Modern Vehicles, the last edition of which was published in 2016. This most recent edition of this non-binding guidance leverages agency research, industry voluntary standards, and […]