Virtually all organizations have an obligation to safeguard their personal data against unauthorized access or use, and, in some instances, to notify affected individuals in the event such access or use occurs. Those obligations are, in some instances, relatively nebulous, and organizations—for better or worse—have flexibility to determine what pre-incident safeguards and post-incident responsive actions
Downstream Breaches Cause Headaches for Healthcare Providers, as State AG Seeks Law Change to Require AG Notification
For healthcare providers and health systems covered by the privacy and security regulations under the Health Insurance Portability and Accountability Act (HIPAA), a breach of unsecured protected health information (PHI) likely triggers obligations to notify affected individuals, the federal Office of Civil Rights (OCR), potentially the media and other entities. The breach also may require
A New Low For Hackers – Threatening to Disclose Patient Medical, Mental Health Records as Ransom for Payment
Ransomware is a scary term for many business leaders and CISOs who dread being hit with a malware attack that locks up their data and could shut down operations. They expect to find that oddly-worded ransom note advising how they could recover access to their data, for a sizable fee of course. For a variety
Stolen Databases Obtained In Transaction Leads to $400K Settlement with PA and OH Attorneys General
This post deals with another data breach, yes, hackers were able to compromise the organization’s systems and exfiltrate personal information relating to over 45,000 Pennsylvania and Ohio residents. However, there are several important takeaways from this case, including cybersecurity in corporate transactions, data retention and destruction, and incident response planning.
According to the Assurance of
OCR Reminds Healthcare Providers and Their Business Associates – You Need an Incident Response Plan!
We have been quite busy this October, which happens to be National Cybersecurity Awareness Month. But, we did not want to let the month go by without some recognition; and we are grateful to the HHS Office for Civil Rights (OCR) for this always timely reminder for HIPAA covered entities and business associates – have
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,
FBI/CISA Alert: Increased Likelihood of Ransomware Attacks Over Labor Day Weekend
Watch out! A spike in ransomware attacks may be headed our way over Labor Day weekend. Yesterday, the FBI jointly with the Cybersecurity and Infrastructure Security Agency (CISA) issued a warning to be on high alert for ransomware attacks this weekend, after recent targeted attacks over Mother’s Day, Memorial Day and Fourth of July weekends.
NIST Preliminary Draft Cybersecurity Framework Profile for Ransomware Risk Management Provides Risk Management Strategies
The National Institute of Standards and Technology (NIST) recently released a preliminary draft of its Cybersecurity Framework Profile for Ransomware Risk Management. The public comment period for this draft runs through July 9, 2021. NIST says “The profile can be used as a guide to managing the risk of ransomware events. That includes helping
Connecticut on its Way to an Enhanced Data Breach Notification Law
UPDATE: On June 16, Gov. Ned Lamont signed HB 5310 into law which becomes effective October 1, 2021.
State legislatures across the nation are prioritizing privacy and security matters, and Connecticut is no exception. This week, Connecticut Attorney General William Tong announced the passage of An Act Concerning Data Privacy Breaches, a measure that
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