Written Information Security Program

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Leaders charged with safeguarding data privacy and cybersecurity often assume that size equates to security—that large, well-resourced organizations must have airtight defenses against cyberattacks and data breaches. It’s a natural assumption: mature enterprises tend to have robust policies, advanced technology, and deep security teams. Yet, as recent events remind us, even the biggest organizations can…

Governor Gavin Newsom recently signed SB 446 into law, introducing significant changes to California’s data breach notification requirements. The bill establishes deadlines for notifying consumers and the state’s Attorney General when personal information of California residents has been involved in a data breach.

What’s Changed Under SB 446

Previously, California law required businesses to notify…

On June 20, 2025, Texas Governor Greg Abbott signed SB 2610 into law, joining a growing number of states that aim to incentivize sound cybersecurity practices through legislative safe harbors. Modeled on laws in states like Ohio and Utah, the new Texas statute provides that certain businesses that “demonstrate[] that at the time of the…

In late March 2025, the Florida Bar Board of Governors unanimously endorsed the recommendation of its Special Committee on Cybersecurity and Privacy Law that law firms should adopt written incident response plans (IRPs) to better prepare for and respond to data security incidents. The recommendation reflects a growing recognition across professional service industries—particularly law firms—of…

According to one survey, Florida is fourth on the list of states with the most reported data breaches. No doubt, data breaches continue to be a significant risk for all business, large and small, across the U.S., including the Sunshine State. Perhaps more troubling is that class action litigation is more likely to follow…

In 2024, Israel became the latest jurisdiction to enact comprehensive privacy legislation, largely inspired by the EU’s General Data Protection Regulation (“GDPR”). On August 5, 2024, Israel’s parliament, the Knesset, voted to approve the enactment of Amendment No. 13 (“the Amendment”) to the Israel Privacy Protection Law (“IPPL”). The amendment which will take effect on…

Announcing its fourth ransomware cybersecurity investigation and settlement, the Office for Civil Rights (OCR) also observed there has been a 264% increase in large ransomware breaches since 2018.

Here, the OCR reached an agreement with a medium-size private healthcare provider following a ransomware attack relating to potential violations of the HIPAA Security Rule.

A little more than three years ago, the U.S. Department of Labor (DOL) posted cybersecurity guidance on its website for ERISA plan fiduciaries. That guidance extended only to ERISA-covered retirement plans, despite health and welfare plans facing similar risks to participant data.

Last Friday, the DOL’s Employee Benefits Security Administration (EBSA) issued Compliance Assistance Release…

As organizations continue to take steps to prevent cyberattacks, a near-universal recommendation is that they should implement multi-factor authentication (MFA), and for good reason. Organizations subject to the updated FTC Safeguards Rule, for example, are required to implement MFA. The Cybersecurity & Infrastructure Security Agency (CISA) includes MFA as a best practice. And…