The Federal Trade Commission (FTC) has approved an amendment to its Safeguards Rule that will require non-banking financial institutions to report certain data breaches (or “notification events”) to the FTC (not affected individuals).

The “Safeguards Rule,” short for “Standards for Safeguarding Customer Information,” was created to ensure that businesses maintain safeguards to protect

In yet another example of its focus on imposing greater data security accountability, the New York Attorney General (“NYAG”) recently announced a significant settlement with Marymount Manhattan College (“the College”).  The settlement stems from a data breach to which the College was subject in 2021.  Following an investigation, which, according to the NYAG, revealed inadequacies

Many HIPAA covered entities and business associates struggle with developing and implementing a sanctions policy. What should it say, is zero-tolerance required, do we have to impose discipline in every case, etc. These are examples of frequent and thorny questions that arise in connection with the development and implementation of these policies. But they are

The Cyber Safety Review Board (Board) issued a report entitled, Review of the Attacks Associates with Lapsus$ and Related Threat Groups (Report), released by the Department of Homeland Security on August 10, 2023. The Report begins with a message from the Board’s Chair and Vice Chair discussing WarGames, a movie with interesting parallels to

In a 2019 post about increasing cyber risks in K-12 schools, we cited a report, “The State of K-12 Cybersecurity: 2018 Year in Review,” that contained sobering information about cybersecurity in local school districts across the country. According to that report, in 2018, there were 122 publicly-disclosed cybersecurity incidents affecting school districts across

Yesterday, New York’s Department of Financial Services (“DFS”) announced another enforcement action under the state’s Cybersecurity Requirements for Financial Services Companies, 23 N.Y.C.R.R. Part 500 (“Reg 500”).  According to the press release, OneMain Financial Group LLC (“OneMain”) will pay a $4.25 million penalty to New York State for alleged violations of Reg 500.  

In the

Ransomware is a scary term for many business leaders and CISOs who dread being hit with a malware attack that locks up their data and could shut down operations. They expect to find that oddly-worded ransom note advising how they could recover access to their data, for a sizable fee of course. For a variety

As noted in a prior post, New York’s Attorney General (“NYAG”) has made enforcement of the New York SHIELD Act  an enforcement priority. The SHIELD Act requires organizations handling personal information related to New York residents to maintain reasonable safeguards to protect that information.  Maintaining its focus on this area, the NYAG recently released