Written Information Security Program

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

The annual Cost of a Data Breach Report (Report) published by IBM is reliably full of helpful cybersecurity data. This year is no different. After reviewing the Report, we pulled out some interesting data points. Of course, the Report as a whole is well worth the read, but if you don’t have the time to

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

The Federal Trade Commission updated its “Standards for Safeguarding Customer Information” (“Safeguards Rule”) and extended the compliance deadline to June 9, 2023. Some entities still may be wondering – “Do these regulations apply to my business?” and “What do I have to do?”

Back in 2021, we provided a high-level summary of the Safeguards Rule

Websites play a vital role for organizations. They facilitate communication with consumers, constituents, patients, employees, donors, and the general public. They project an organization’s image and promote goodwill, provide information about products and services and allow for their purchase. Websites also inform investors about performance, enable job seekers to view and apply for open positions,

Last month, the U.S. Department of Health and Human Services (HHS) Office for Civil Rights (OCR) issued a bulletin with guidance concerning the use of online tracking technologies by covered entities and business associates under the Health Insurance Portability and Accountability Act (HIPAA). The OCR Bulletin follows a significant uptick in litigation concerning these technologies

It usually happens after a reported data breach. The organization experiencing the breach sends notifications to affected individuals, as well as federal and or state agencies where appropriate and perhaps other parties. Not long thereafter, the organization receives an inquiry from one or more government agencies. These inquiries typically seek more information about the breach

On December 22, 2022, the Nevada Gaming Commission (NGC) adopted regulations creating new cybersecurity requirements for certain gaming operators. This action joins agencies in other jurisdictions moving quickly to protect consumers and their personal information in the gaming industry. The NGC adopted the October 17, 2022 version of the regulations, which become effective January