Archives: Written Information Security Program

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Professional Tax Preparers – You Need A Written Information Security Plan, Says the IRS and FTC

Tax season soon will soon be upon us and many not-so-eager taxpayers will share sensitive personal information about themselves, their dependents, their employees, and others with their trusted professional tax preparers for processing. What many of these preparers might not realize is that federal law and a growing number of state laws obligate them to … Continue Reading

Massachusetts Governor Announces Cybersecurity Program

State and local governments have increasingly become targets of cybersecurity attacks. This year cybersecurity attacks on Baltimore and Lincoln County, North Carolina reportedly will cost those government entities $18.2 million and as much as $400,000, respectively to recover from the attacks. Last year, Atlanta spent more than $7 million to recover from a ransomware attack. … Continue Reading

US Senate Bill Passes, Seeking to Establish “Cyber Hunt and Incident Response Teams”

More than 500 United States schools (connected with 54 different education entities such as school districts and colleges) have been infected with ransomware during the first nine months of 2019, according to a recent report by cybersecurity firm Armor, making the education sector one of the leading ransomware targets, following only municipalities as the top … Continue Reading

CCPA Amendments Updated, Finalized, and Moving on to Governor Newsom

The California Consumer Privacy Act is almost here! The groundbreaking law takes effect January 1, 2020. Covered businesses and their service providers have already started preparing, as the CCPA continues to evolve since it was introduced. California’s legislative session ended on September 13th, with some final modifications to bills that would amend certain aspects of … Continue Reading

OCR Recognizes Insider Threats to HIPAA PHI, You Should Too

As we have observed here, news reports of security risks, hackings and breaches caused by individuals, terror groups or even countries around the world certainly are important and can be unsettling. But, for many organizations, including healthcare providers and business associates, a significant and perhaps more immediate area of data risk is malicious insiders. On … Continue Reading

Expansion of Technology at K-12 Schools Comes with Data Security Risks for Students and Parents

A new school year is upon us and some students are already back at school. Upon their return, many students may experience new technologies and equipment rolled out by their schools districts, such as online education resources, district-provided equipment, etc. to enhance the education they provide and improve district administration. However, a recent report, “The State … Continue Reading

Licensed by Your State’s Insurance Commissioner? Comprehensive Data Security Requirements Are Headed Your Way

Most businesses in the insurance industry have one thing in common – they collect and maintain significant amounts of sensitive, nonpublic information including personal information. Not surprisingly, insurance-related businesses are a target of cyberattacks and a few have faced some of the largest data breaches reported to date. Beyond the headlines, however, small and mid-sized … Continue Reading

Is Your Small Business Prioritizing Cybersecurity?

A recent study surveying small and mid sized businesses (SMBs) found that 67% had experienced a cyber attack in 2018, and yet that same study found that cybersecurity is still “not on the to do list” for SMBs – 60% of the SMBs surveyed responded that they did not have a cybersecurity plan in place, … Continue Reading

New York Enacts the SHIELD Act

On Thursday, New York Governor Andrew Cuomo signed into law the Stop Hacks and Improve Electronic Data Security Act (SHIELD Act), sponsored by Senator Kevin Thomas and Assemblymember Michael DenDekker. The SHIELD Act, which amends the State’s current data breach notification law, imposes more expansive data security and data breach notification requirements on companies, in … Continue Reading

Illinois’ Attorney General Wants to Know About Data Breaches

Possibly adding to the list of states that have updated their privacy and breach notification laws this year, the Illinois legislature passed Senate Bill 1624 which would update the state’s current breach notification law to require most “data collectors,” which includes entities that, for any purpose, handle, collect, disseminate, or otherwise deal with nonpublic personal information, to notify … Continue Reading

Upward Trend in Cyberattacks Targeting Senior Executives

Verizon recently published its 2019 Data Breach Investigations Report. This report is the 12th edition and contains an analysis of 41,686 security incidents with 2,013 confirmed breaches from 73 sources, including public and private entities. Included among its many findings, the report found high-level executives are twelve times more likely to be the target of … Continue Reading

“Help Me, Help You”: Defense Department Advises Contractors That Cybersecurity Is An Allowable Cost

During a presentation at the Professional Services Council Federal Acquisition Conference on June 13, 2019, a high-ranking Department of Defense (“DoD”) official announced, with dramatic flair, that cybersecurity is an allowable cost: “I need you all now to get out your pens and you better write this down and tell your teams: Hear it from … Continue Reading

The GDPR – One Year and Counting

The GDPR is wrapping up its first year and moving full steam ahead. This principles-based regulation has had a global impact on organizations as well as individuals. While there continue to be many questions about its application and scope, anticipated European Data Protection Board guidance and Data Protection Authority enforcement activity should provide further clarity … Continue Reading

EMR Provider Settles OCR Allegations for $100,000; Is Your EMR provider HIPAA compliant?

Many health care providers, including small and medium-sized physician practices, rely on a number of third party service providers to serve their patients and run their businesses. Perhaps the most important of these is a practice’s electronic medical record (EMR) provider, which manages and stores patient protected health information. EMR providers generally are business associates … Continue Reading

California’s “Your Data, Your Way” Initiative

California keeps making privacy headlines for its trailblazing California Consumer Privacy Act (“CCPA”), set to take effect January 1, 2020, but there is another set of privacy bills making its way through the California state legislature, that, if passed, will provide consumers with further privacy protections. The “Your Data Your Way” initiative, comprised of four … Continue Reading

High-end Job Recruitment Site Exposes at least 13.7 million Users with Unprotected Server

A security lapse has exposed the data of at least 13.7 million user records of the high-end job recruitment site, Ladders. The company left a cloud-hosted search database exposed without a password. Ladders took the database offline less than an hour after the news website TechCrunch alerted the company after learning about the potential breach … Continue Reading

More Updates to the CCPA May Be Ahead

Ever since the California Consumer Privacy Act (CCPA) was enacted in June of 2018 it has been in a constant state of revision.   First, in September of 2018, Governor Jerry Brown signed into law Senate Bill 1121, which helped clarify and strengthen the original version of law. Then, in February of 2019, California Attorney General Xavier … Continue Reading

Can Hackers Break Into GPS Trackers Used For Your Fleet?

The answer may be yes. GPS trackers enable businesses to derive greater efficiencies and productivity from their employees and their vehicle fleets. But, when businesses deploy this technology, HR departments often raise valid concerns about employee privacy on and, in some cases, off the job. When employers install GPS trackers on company-owned vehicles, these privacy … Continue Reading

Washington Poised to Significantly Expand Its Data Breach Notification Law

It was looking like Washington state would be the first state to follow the California Consumer Privacy Act (CCPA), with a GDPR-like law of its own. That effort has stalled, perhaps temporarily. However, both Washington’s House and Senate voted unanimously to send HB 1071 to Gov. Jay Inslee, which would substantially expand the state’s current … Continue Reading

SEC Issues Privacy and Data Security Risk Alert

Following recent examinations of SEC-registered investment advisers and broker-dealers, the Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) published a privacy risk alert on April 16, 2019. OCIE is hoping to remind advisers and broker-dealers about providing compliant privacy and opt-out notices, and adopting and implementing effective policies and procedures for safeguarding … Continue Reading

Small Michigan Medical Practice To Close Following Ransomware Attack

Small and midsized enterprises (SMEs) continue to be targeted by ransomware, phishing and other cyberattacks; the consequences of which could be devastating. Those consequences include putting SMEs out of business, which is unfortunately the case for one small medical practice in Battle Creek, Michigan, as reported by HIPAAJournal. The reality is that the effects of these attacks … Continue Reading

Updates to Massachusetts Breach Notification Law – Much More Than Mandatory Credit Monitoring

UPDATE: The changes to the Massachusetts data breach notification law described below are now in effect. Thus, if you have discovered a data incident involving the personal information of Massachusetts residents you will want to review these changes carefully – they are significant and the Commonwealth is intent on educating the public about them. Because we have coached … Continue Reading

Bill Which Would Expand the CCPA Private Right of Action Moves Forward

As we reported, in late February, California Attorney General Xavier Becerra and Senator Hannah-Beth Jackson introduced Senate Bill 561, legislation intended to strengthen and clarify the California Consumer Privacy Act (CCPA). This week, the Senate Judiciary Committee referred the bill to the Senate Appropriations Committee by a vote of 6-2. This move came despite concerns raised … Continue Reading

Could This Be Your Retirement Plan?

As reported by CBC, B.C. Pension Corporation announced a data breach involving pension plan records after discovering a box containing microfiche could not be found following a recent office move. The box contained personal information (names, social insurance numbers and dates of birth) on approximately 8,000 pension plan participants. The company employed those participants during the period 1982 to … Continue Reading
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