When Massachusetts issued its data security regulations in 2009 (Regulations), it led the way for states on data security. The Regulations became effective 12 years ago, almost to the day, March 1, 2010. The Bay State is now contemplating comprehensive privacy legislation, the Massachusetts Information Privacy and Security Act (MIPSA), similar to what has been
SEC to Advisors and Funds – Adopt and Implement Cybersecurity Policies and Procedures
On February 9, the Securities and Exchange Commission (“SEC”) voted to propose rule 206(4)-9 under the Advisers Act and 38a-2 under the Investment Company Act (collectively, “Proposed Rule”). In general, the Proposed Rule would require all advisers and funds to adopt and implement cybersecurity policies and procedures containing several elements. While acknowledging spending on cybersecurity
Fraud, Data Breaches Continuing to Crush Federal and State Unemployment Benefit Departments, Pennsylvania’s Next?
Few want to get past the COVID-19 pandemic more than leaders of federal and state unemployment benefit departments. For the last 2 years they have been successfully targeted for fraud and data breaches, racking up billions in losses. Thousands of employees across the country, including yours truly, have had false claims submitted in their name.
California Consumer Privacy Act, California Privacy Rights Act FAQs for Covered Businesses
The California Consumer Privacy Act (CCPA), considered one of the most expansive U.S. privacy laws to date, went into effect on January 1, 2020. The CCPA placed significant limitations on the collection and sale of a consumer’s personal information and provides consumers new and expansive rights with respect to their personal information.
Less than one
Preventing “Credential Stuffing” Attacks, Guidance from NY State Attorney General Letitia James
After reading New York Attorney General Letitia James’ Business Guide for Credential Stuffing Attacks (“Guide”), I promptly reminded my family (and myself!) to change passwords. The practice of using the same password for multiple online accounts is one that most, if not all of us, use from time to time. According to a recent study,
Does a Poor ESG, Social Responsibility Rating Increase an Organization’s Cyber Risk?
With ransomware and other cyber threats top of mind for most in the c-suite these days, a question frequently raised is whether a particular organization is a target for hackers. Of course, nowadays, any organization is at risk of an attack, but the question is whether some organizations are targeted more than others. A recent
Does Your Cyber Insurance Policy Look More Like Health Insurance?
Over the past several years, if your organization experienced a cyberattack, such as ransomware or a diversion of funds due to a business email compromise (BEC), and you had cyber insurance, you likely were very thankful. However, if you are renewing that policy (or in the cyber insurance market for the first time), you are
OSHA ETS: What Records Must Covered Employers Collect, Retain, Safeguard, and Make Available Upon Request
Last week, the Occupational Safety and Health Administration (OSHA) issued an Emergency Temporary Standard (ETS) implementing President Joe Biden’s COVID-19 vaccine mandate covering employers with at least 100 employees. The ETS is summarized here, including the general compliance deadline of 30 days from November 5, 2021, with an additional 30 days for testing to
DOJ Announces Cybersecurity Enforcement Initiative Targeting Federal Contractors
Last week, the Department of Justice (“DOJ”) announced the launch of its Civil Cyber-Fraud Initiative (“the Initiative”) aimed at combating “new and emerging cyber threats to the security of sensitive information and critical systems” specifically targeting accountability of cybersecurity obligations for federal contractors and federal grant recipients, by way of the False Claims Act. The
The Key to NYC and Other Cities’ COVID-19 Vaccine Proof Mandates, and Potential Privacy Issues
Cities step up their efforts to combat the COVID-19 Delta variant. New York City, New Orleans, and San Francisco have all announced requirements for certain persons to produce evidence of COVID vaccination status in order to patronize or work indoors at certain establishments. Adding to an already complex patchwork of COVID-related regulation –