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Data Protection

FTC Delays Effective Date of Certain Changes to the Safeguard Rule

November 17, 2022 By Kathleen Benway and Hyun Jai Oh

On November 15, 2022, the Federal Trade Commission (FTC) announced that it is delaying the effective date of certain changes to the Gramm–Leach–Bliley Safeguards Rule. The Safeguards Rule, which first became operative in 2003, imposes certain security requirements on non-banking financial institutions. The FTC amended the Rule in December 2021, and several provisions under the […]

Filed Under: Cybersecurity, Data Protection, FTC, Uncategorized Tagged With: Data Protection, Federal Trade Commission (FTC)

Recent FTC Order Has Implications for Executive Liability and Corporate Data Minimization Practices

October 28, 2022 By Kim Peretti, Alysa Austin and Kristen Bartolotta

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 […]

Filed Under: Cybersecurity, Data Breach, Data Protection, Data Security, Enforcement, FTC Tagged With: Cybersecurity, Data Protection, Federal Trade Commission (FTC)

The White House Introduces new Blueprint for an AI Bill of Rights

October 6, 2022 By Kim Peretti

On October 4, 2022, the White House Office of Science and Technology released the Blueprint for an AI Bill of Rights (the Bill) to guide the development and use of artificial intelligence (AI) in the United States. The White House recognized that while AI is a powerful driver of innovation, the technology can also be […]

Filed Under: Data Protection, Data Security, Privacy, Regulation Tagged With: Algorithms, Artificial Intelligence, Automated Decision-making, Behavioral Tracking, Big Data, Data Protection

SEC Sends a Message to Investment Advisers: Take Secure Data Disposal Seriously

September 26, 2022 By Kate Hanniford

  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 […]

Filed Under: Cybersecurity, Data Protection, Data Security, Financial Privacy, Privacy, SEC Tagged With: Cybersecurity, Data Protection, Regulatory Enforcement, Securities and Exchange Commission

SEC Settles Enforcement Actions with Broker-Dealers and Investment Advisors for Identity Protection Deficiencies

August 1, 2022 By Alysa Austin and Kate Hanniford

On July 27, 2022, the Securities and Exchange Commission (SEC) separately settled three enforcement actions with broker-dealers and investment advisers for alleged deficiencies relating to the prevention of customer identity theft, in violation of the SEC’s Identity Theft Red Flags Rule, or Regulation S-ID. Regulation S-ID requires registered financial institutions, broker dealers, and investment advisers […]

Filed Under: Cybersecurity, Data Protection, Financial Privacy Tagged With: Cybersecurity, Data Protection, Identity Theft, Regulatory Enforcement, Securities and Exchange Commission

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