Companies relying on the SCCs as a data transfer tool have less than a month to update their existing contracts (if they haven’t done so already). WHAT HAPPENED? The EU General Data Protection Regulation (GDPR) allows companies that want to transfer personal data protected by the GDPR to third countries outside the EU/EEA to do […]
Regulatory Enforcement
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 […]
SEC Settles Enforcement Actions with Broker-Dealers and Investment Advisors for Identity Protection Deficiencies
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 […]
UK Information Commissioner’s Office Issues Warning on Ransomware Payments
On July 8, 2022, the UK Information Commissioner’s Office (UK ICO) together with the UK National Cyber Security Centre (NCSC), published a joint letter asking the Law Society of England & Wales to remind its members that they should not advise clients to pay ransomware demands should they fall victim to a cyber-attack. The Law […]
EDPB Issues Draft Guidelines on the Calculation of Administrative Fines
On May 16, 2022, the European Data Protection Board (‘EDPB’) published draft regulatory guidelines (‘draft guidance’) on the calculation of administrative fines for infringements of the EU General Data Protection Regulation (‘GDPR’). In the draft guidance, the EDPB sets out its methodology, consisting of five steps, for calculating administrative fines. The EDPB adopted these guidelines […]