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
Damon W. Silver
New SEC Cybersecurity Disclosure Requirements Place Pressure On Public Companies To Investigate Potential Breaches Quickly And Involve Leadership In Data Security Compliance
This summer, the Securities and Exchange Commission (SEC) adopted rules to enhance and standardize disclosures by public companies regarding cybersecurity risk management, strategy, governance, and incidents.
The rules will impose a number of new requirements, including disclosures regarding:
- Material cybersecurity incidents, which must be made within four (4) business days – a tight timeline
CCPA-Covered Businesses Be On the Look Out for a Letter from the California Attorney General
Though enforcement of the California Privacy Rights Act (CPRA) which amended the California Consumer Privacy Act (CCPA) has been paused for now, the State of California is not resting when it comes to compliance with the CCPA.
On July 14, 2023, California’s Attorney General announced an “investigative sweep” regarding compliance with the CCPA.
New York Legislature and Enforcement Agencies Remain Active on the Data Privacy and Security Fronts
At the start of 2023, the New York State legislature introduced several privacy-related bills. One of those bills, S365, appears to be gaining momentum. It was reported and committed to the Internet and Technology Committee on April 25, was amended on May 18, and was further amended and recommitted to the Finance Committee on…
New York AG Releases Guide for Businesses on Effective Data Security
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…
Iowa’s Governor Signs Comprehensive Consumer Privacy Law
On March 28, 2023, Iowa’s Governor signed Iowa’s new statute relating to consumer data protection. Iowa joins California, Colorado, Connecticut, Utah, and Virginia in the ever-growing patchwork of consumer privacy laws across the country.
The new law takes effect on January 1, 2025.
Iowa’s consumer privacy law covers businesses…
Iowa to Be Sixth State to Pass a Consumer Privacy Statute
On March 15, 2023, the Iowa legislature unanimously passed Senate File 262, the Consumer Privacy Act, which relates to consumer data and privacy protection. Once signed by Iowa’s governor, the statute will become operative on January 1, 2025, and Iowa will join California, Colorado, Connecticut, Utah, and Virginia in passing…
CPPA Starts Rulemaking on Cybersecurity, Risk Assessments, and Automated Decision-making
While the California Privacy Protection Agency (CPPA) only recently approved revised amended regulations pertaining to the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), it is already on to its next rulemaking.
On February 10, 2023, the CPPA issued an invitation for preliminary comments on proposed rulemaking pertaining to cybersecurity audits…
California Privacy Protection Agency Passes Revised Regulations
After a significant delay, on February 3, 2023, the California Privacy Protection Agency (CPPA) unanimously approved amended regulations. The new regulations have not yet gone into effect as they must first be approved by the Office of Administrative Law (OAL). The CPPA’s General Counsel advised that there is no guarantee that the regulations would be…
California Privacy Protection Act Ends 2022 Without CPRA Regulations, But CPPA Targets Risk Assessments and AI for Additional Rulemaking
On December 16, 2022, the California Privacy Protection Agency (CPPA) had its final meeting before the California Privacy Rights Act (CPRA) which amended the California Consumer Privacy Act takes effect on January 1, 2023. Despite the CPRA taking effect at the start of the year, the CPPA, the agency charged with implementing the law…