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 […]
Regulatory Enforcement
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On May 16, 2022, the European Data Protection Board (‘EDPB’) published draft regulatory guidelines (‘draft guidance’) on the calculation of administrative fines for infringements of the EU General Data Protection Regulation (‘GDPR’). In the draft guidance, the EDPB sets out its methodology, consisting of five steps, for calculating administrative fines.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 […]
Georgia Introduces Privacy Bill Stricter than CCPA – the Top 10 Issues
On January 26, 2022, the Georgia General Assembly introduced a bill titled the Georgia Computer Data Privacy Act (GCDPA). Despite its title, the GCDPA is not a “computer”-focused bill. It is instead is an omnibus privacy statute modeled after California’s Consumer Privacy Act (CCPA). The GCDPA was introduced by the Republican leadership in Georgia’s state […]